Social Security Number Privacy Protection Policy
Your privacy is very important to All Waste, Incorporated (the “Company”). The Company has created this Privacy Protection Policy to comply with Public Act 08-167 of the Connecticut General Statutes and to demonstrate its commitment to protect the privacy of your Social Security number. It is the policy of the Company to (1) protect the confidentiality of Social Security numbers, (2) prohibit unlawful disclosure of Social Security numbers, and (3) limit access to Social Security numbers obtained and used in the course of business from its employees, applicants and other parties. All executives, officers, managers and employees of the Company are expected to rigorously adhere to this policy. Any executive, officer, manager or employee of the Company violating the provisions of this policy will be subject to discipline in accordance with Company rules and procedures.
1. Collection of Social Security Numbers.
A. Employees/Applicants. Social Security numbers will be collected from applicants and employees of the Company for verification purposes and as required in order to meet applicable legal requirements. These purposes include:
- To conduct pre-employment background checks.
- To verify eligibility for employment.
- To withhold federal and state taxes.
- To comply with other legal requirements.
- To facilitate enrollment and participation in the Company’s insurance arrangements and/or employee benefits plan(s).
B. Other Parties. Social Security numbers may also be collected in the course of the Company’s business from clients, customers, suppliers, independent contractors, creditors, debtors and others (“clients”). The Company will make reasonable efforts to restrict access to the Social Security numbers of clients to those Company employees who are required to have access to the Social Security numbers in order to provide business or professional services to clients. The Company will make reasonable efforts to train those employees to protect the privacy of client Social Security numbers and will maintain physical, electronic and procedural safeguards to guard client Social Security numbers as required by applicable laws.
It is the general policy of this Company to:
- Protect the confidentiality of Social Security numbers obtained in the ordinary course of business;
- Prohibit the unlawful disclosure of such Social Security numbers; and
- Limit access to such Social Security numbers.
2. Use of Social Security Numbers. Except for the purposes described in Paragraph 1.A. above, the Company will not utilize the Social Security numbers of employees, former employees or applicants. The Company may retain and use client Social Security numbers as necessary to provide services to clients. In so doing, the Company will comply with all applicable laws and, to the extent applicable, codes of professional responsibility and any ethical rules governing our conduct as professionals. In accordance with this Privacy Protection Policy, the following uses and transmission/distribution of a Social Security number are prohibited:
- Unacceptable Uses of Employee and Applicants Social Security Numbers. No Social Security number or portion of a Social Security number of an employee, former employee or applicant of the Company will be publicly displayed, or otherwise permitted to be used for: identification badges, parking permits, time cards, employee rosters, employee identification records, computer passwords, Company account records, licenses, agreements or contracts.
- Unacceptable Uses of Client Social Security Numbers. No Social Security number or portion of a Social Security number of a client or former client of the Company may be disclosed, except as expressly or impliedly authorized by the client to enable the Company to provide its business or professional services. This Privacy Protection Policy specifically means that the Company will protect the confidentiality of its clients’ and former clients’ Social Security numbers, prohibit unlawful disclosure of its clients’ and former clients’ Social Security numbers and limit access to its clients’ and former clients’ Social Security numbers.
- Transmission/Distribution of Any Social Security Number. No Social Security number or portion of a Social Security number of an employee, former employee, applicant, client or former client of the Company will be used in open computer transmissions through a Company Internet website or a computer system or network unless the connection is secure, the transmission is encrypted, or a password or other unique personal identification number or other authentication device is also required to gain access to the Internet website or computer system or network. No Social Security number or portion of a Social Security number will be mailed or otherwise sent to an employee, former employee, applicant, client or former client of the Company if it is visible on or, without manipulation, from outside of the envelope or packaging.
3. Storage of and Access to Social Security Numbers.
- Storage All documents and records containing Social Security numbers shall be physically stored in locked secured areas. All electronic computer applications containing Social Security numbers shall be maintained on secured, authorized-access computer stations only.
- Access Only authorized Company employees who have a legitimate business or professional reason will have access to Social Security numbers. No employee of the Company is permitted to access Social Security numbers without the express permission of the Company. Company access to Social Security numbers will be granted through executives, officers, or managers of the Company. Company personnel granted such access will be instructed to take all necessary precautions to ensure the integrity of records that include Social Security numbers when the records are not being used. All authorized Company personnel with access to Social Security numbers will be trained in coordination with the Company’s information technology (IT) department, on the requirements of this Privacy Protection Policy and on how to recognize a security breach and on what to do when a security breach occurs. All Company employees that use or have access to Social Security numbers shall be held to the highest degree of confidentiality and any applicable professional standards.
4. Destruction of Social Security Numbers. The Company will safeguard the data, computer files and documents containing your Social Security number and destroy, erase or make unreadable such data, computer files and documents prior to disposal. Paper documents that include Social Security numbers will be maintained in accordance with federal and state laws. When such documents are released for destruction, the records will be destroyed by shredding or other means prior to disposal.
5. Violation of Privacy Protection Policy. Any employee of the Company, including any executive, officer or manager of the Company, in violation of this Privacy Protection Policy will be subject to discipline up to and including termination of employment.
6. Conflicting Law. If this Privacy Protection Policy conflicts with the law of a jurisdiction in which the Company operates, the law of the applicable jurisdiction shall supersede this Privacy Protection Policy within that jurisdiction.
Changes to this Privacy Protection Policy
Please note that this Privacy Protection Policy may change from time to time. Each version of this Privacy Protection Policy will be identified by its effective date.
If you have any additional questions or concerns about this Privacy Protection Policy, please contact Allwaste Controller at 860-724-4575.
Implemented and Effective October 1, 2008
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