Model Identity Theft Policy and Adopting Resolution

____________________, Tennessee

1. Define sensitive information;

2. Describe the physical security of data when it is printed on paper;

3. Describe the electronic security of data when stored and distributed; and

4. Place the municipality in compliance with state and federal law regarding identity theft protection.

1. Identify risks that signify potentially fraudulent activity within new or existing covered accounts;

2. Detect risks when they occur in covered accounts;

3. Respond to risks to determine if fraudulent activity has occurred and act if fraud has been attempted or committed; and

4. Update the program periodically, including reviewing the accounts that are covered and the identified risks that are part of the program.

4.A.1: Definition of Sensitive Information

Sensitive information includes the following items whether stored in electronic or printed format:

4.A.1.a: Credit card information, including any of the following:

1. Credit card number (in part or whole)

2. Credit card expiration date

3. Cardholder name

4. Cardholder address

4.A.1.b: Tax identification numbers, including:

1. Social Security number

2. Business identification number

3. Employer identification numbers

4.A.1.c: Payroll information, including, among other information:

1. Paychecks

2. Pay stubs

4.A.1.d: Cafeteria plan check requests and associated paperwork

4.A.1.e: Medical information for any employee or customer, including but not limited to:

1. Doctor names and claims

2. Insurance claims

3. Prescriptions

4. Any related personal medical information

4.A.1.f: Other personal information belonging to any customer, employee or contractor, examples of which include:

1. Date of birth

2. Address

3. Phone numbers

4. Maiden name

5. Names

6. Customer number

4.A.1.g: Municipal personnel are encouraged to use common sense judgment in securing confidential information to the proper extent. Furthermore, this section should be read in conjunction with the Tennessee Public Records Act and the municipality’s open records policy. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact their supervisor. In the event that the municipality cannot resolve a conflict between this policy and the Tennessee Public Records Act, the municipality will contact the Tennessee Office of Open Records.

Each employee and contractor performing work for the municipality will comply with the following policies:

1. File cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with sensitive information will be locked when not in use.

2. Storage rooms containing documents with sensitive information and record retention areas will be locked at the end of each workday or when unsupervised.

3. Desks, workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing sensitive information when not in use.

4. Whiteboards, dry-erase boards, writing tablets, etc. in common shared work areas will be erased, removed, or shredded when not in use.

5. When documents containing sensitive information are discarded they will be placed inside a locked shred bin or immediately shredded using a mechanical cross cut or Department of Defense (DOD)-approved shredding device. Locked shred bins are labeled “Confidential paper shredding and recycling.” Municipal records, however, may only be destroyed in accordance with the city’s records retention policy.