Another thing to consider is that your business requirements for what constitutes non-public information (NPI) is guided by both Federal and State legislation, as well as the industry you're in. For instance, a Financial Services firm in California still has SB-1386 (California-specific Data Breach Disclosure law) and the Gramm-Leach-Bliley Act (governs Financial Services) to follow.
When it doubt, consult your Legal Team. If you do not have a Legal Team readily available, your HR Department should be able to help review this information.
Good luck!
Mike
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by: TolomirPosted on 2009-10-15 at 03:38:14ID: 25579123
Take a look at this:
/cwp/view. asp?a=2235 &q=297930
his tells you what you have to protect as private person. Check with those details of persons you keep in your database.
http://www.ct.gov/DOB
T
Tolomir