A story came across our desk recently from the Central State Hospital in Georgia. They recently required hundreds of their employees to undergo fingerprinting and new background checks. The reason: hundreds of old files were lost or discarded during a move.
It’s a sobering thought to think of mass amounts of confidential, personal information just floating around somewhere. Employers have a responsibility to safeguard sensitive financial or personal data and prevent that data from falling into the hands of identity thieves or others with unauthorized access. Section 216 of the Fair and Accurate Credit Transaction Act of 2003 (FACTA) requires employers to take “reasonable measures” to secure information pertaining to or derived from a “consumer report.”
Employment Background Investigations, a background screening firm, recommends these best practices for the security of files and document destruction:
· Always properly secure consumer information. Do not allow information in either hardcopy or electronic format to be openly available and visible within your entire office and workspace.
· Secure all documents from outside vendors and contractors and any unauthorized personnel.
· Never discard consumer reports or information related to such in the general office garbage.
· When you have reached your designated timeframe for destruction of files, always place consumer reports and any supporting documentation in secured and locked garbage/recycle containers which can only be accessed by authorized personnel.
· Use a certified or reputable document destruction firm to carry out the functions of proper paper and even electronic document destruction.
· Audit and test your destruction policy on a regular basis.
· Continually train and update your staff on proper destruction strategies and policies.