New Connecticut Law On Safeguarding Social Security Numbers

Yesterday, I wrote about a law with no teeth. Last week, I wrote about a law on teeth.

Today, I’m writing about a law with teeth.

Connecticut Public Act 08-167 requires that anyone who collects social security numbers in the course of their business to publish a privacy protection policy that ensures the confidentiality of social security numbers, prohibits their unlawful disclosure and limits access to them.

Such a policy must be published or publically displayed including on the internet.

The legislature provides for a fine of up to $500.00 for each violation up to a maximum of $500,000 per event.

You’ll notice that this statute specifies a fine. Further, the statute does not come out and say that a violation is not an unfair trade practice.

It’s not everyday that I can both write about and comply with a new law in a single post. Enjoy:

LEONE, THROWE, TELLER & NAGLE

PRIVACY POLICY NOTICE 

Lawyers, as providers of certain personal services, are now required by the Gramm-Leach-Bliley Act and by Connecticut Public Act 08-167 to inform their clients of their policies regarding privacy of client information. Our law firm understands your concerns as a client for privacy and the need to ensure the privacy of all your information. Your privacy is important to us and maintaining your trust and confidence is a high priority. Lawyers have been and continue to be bound by professional standards of confidentiality that are even more stringent than those required by both Acts. Therefore, we have always protected your right to privacy. The purpose of this notice is to explain our Privacy Policy with regard to personal information about you that we obtain and how we keep that information secure.

It is the policy of our law firm to:

Protect the confidentiality of Social Security numbers and all nonpublic personal information of our clients; 

Prohibit the unlawful disclosure of Social Security numbers and all nonpublic personal information of our clients; and

Limit access to Social Security numbers and all nonpublic personal information of our clients.

 

 NONPUBLIC PERSONAL INFORMATION WE COLLECT 

If you have any concerns about our policy regarding your non public information that you have provided to us, please do not hesitate to discuss your concerns with any member of our firm.

We collect nonpublic personal information about our clients that is provided to us by them or obtained by us with their authorization or consent. We do not disclose social security numbers or any other nonpublic personal information about any current or former clients obtained in the course of representation of those clients, except as expressly or impliedly authorized by those clients to enable us to effectuate the purpose of our representation or as required or permitted by law or applicable provisions of codes of professional responsibility or ethical rules governing our conduct as lawyers.

CONFIDENTIALITY AND SECURITY

We retain records relating to professional services that we provide so that we are better able to assist you with your professional needs and to comply with professional guidelines or requirements of law. If we dispose of any records, any documents containing nonpublic personal information in those records are shredded. In order to guard your nonpublic personal information, we maintain physical, electronic, and procedural safeguards that comply with our professional standards.