Legal & Privacy
Altarama Information Systems Policy on
Protecting Personally Identifiable Information
Altarama uses the US Department of Commerce definition of Personally Identifiable Information
Sensitive PII is defined as PII which, when disclosed, could result in harm to the individual whose name or identity is linked to the information. Further, in determining what PII is sensitive, the context in which the PII is used must be considered. For example, a list of people subscribing to a government newsletter is not sensitive PII; a list of people receiving treatment for substance abuse is sensitive PII. As well as context, the association of two or more non-sensitive PII elements may result in sensitive PII. For instance, the name of an individual would be sensitive when grouped with place and date of birth and/or mother’s maiden name, but each of these elements would not be sensitive independent of one another.
For the purpose of determining which PII may be electronically transmitted, the following types of PII are considered sensitive when they are associated with an individual. Secure methods must be employed in transmitting this data when associated with an individual:
- Place of birth
- Date of birth
- Mother’s maiden name
- Biometric information
- Medical information, except brief references to absences from work
- Personal financial information
- Credit card or purchase card account numbers
- Passport numbers
- Potentially sensitive employment information, e.g., personnel ratings, disciplinary actions, and result of background investigations
- Criminal history
- Any information that may stigmatize or adversely affect an individual.
This list is not exhaustive, and other data may be sensitive depending on specific circumstances.
Social Security Numbers (SSNs), including truncated SSNs that include only the last four digits, are sensitive regardless of whether they are associated with an individual. If it is determined that such transmission is required, then secure methods must be employed.
The following additional types of PII may be transmitted electronically without protection because they are not considered sufficiently sensitive to require protection.
- Work, home and cell phone numbers
- Work and home addresses
- Work and personal e-mail addresses
- Resumes that do not include an SSN or where the SSN is redacted
- General background information about individuals found in resumes and biographies
- Position descriptions and performance plans without ratings
The determination that certain PII is non-sensitive does not mean that it is publicly releasable. The determination to publicly release any information can only be made by the official authorized to make such determinations. The electronic transmission of non-sensitive PII is equivalent to transmitting the same information by the U.S. mail, a private delivery service, courier, facsimile, or voice. Although each of these methods has vulnerabilities, the transmitted information can only be compromised as a result of theft, fraud, or other illegal activity.
Altarama Information Systems staff and contractors require approval to store PII on their computers and servers. Altarama stores and maintains PII only when required to meet specific needs of the organization or projects. Approval is granted for a specific computer only.
PII is stored in encrypted file system, and access is restricted to only those who need access by passwords and file system permissions.
On-site, computers and servers with PII are located in a restricted access area and are password protected.
PII may be stored on off-site servers when necessary in an encrypted file system.