Confidentiality & Information Protection Policy
Disclaimer
The policies and examples provided are general in nature and intended for informational purposes only. They do not constitute legal advice, create an attorney–client relationship, or represent a legal engagement. These materials reflect federal-level considerations and must be reviewed and tailored to an organization’s specific operations, workforce, and applicable state and local laws.
Organizations should engage qualified advisors to develop company- and jurisdiction-specific policies or employee handbooks.
Purpose and Scope
This Confidentiality and Information Protection Policy ("Policy") establishes the framework for protecting the security and privacy of all confidential information, including nonpublic personal identifying information ("PII"), entrusted to the organization. This Policy applies to all employees, officers, directors, contractors, vendors, and third-party service providers operating under all applicable federal laws and regulations as jurisdiction.
Information Security and Protection Standards
2.1 Information Classification and Handling
All information shall be classified according to sensitivity levels and handled with appropriate security measures. Special care shall be extended to extremely sensitive information, including but not limited to employee records, payroll data, customer confidential information, social security numbers, and other nonpublic information protected under federal laws and regulations.
2.2 Security Safeguards
The organization shall implement and maintain appropriate administrative, technical, and physical safeguards designed to:
Ensure the security and confidentiality of PII and confidential information;
Protect against reasonably anticipated threats or hazards to the security or integrity of such information;
Ensure secure and proper disposal of confidential information and PII; and
Protect against unauthorized access to or use of such information that could create substantial risk of identity theft, fraud, or harm.
Risk Management
3.1 Risk Assessment
The Board of Directors and senior executive management, including designated staff, must be aware of risks that arise from failure to comply with this Policy and applicable federal regulations. The organization shall:
Identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of electronic and paper records containing confidential information;
Assess the likelihood and potential damage of these threats, taking into consideration the sensitivity of the information; and
Evaluate the sufficiency of existing policies, procedures, and information systems containing confidential information.
3.2 Risk Mitigation
Safeguards shall be designed and implemented to minimize identified risks consistent with the requirements of applicable federal laws and regulations.
Secure Destruction of Confidential Information
4.1 Destruction Procedures
The organization's confidential data and records must be disposed of using the same level of security provided when the information was retained. Destruction shall:
Occur in a secure location that prevents access by unauthorized individuals;
Be supervised by appropriate officers of the organization;
Be logged with destruction records retained separately; and
Follow established records retention schedules.
4.2 Special Handling Requirements
Extremely sensitive information shall be transported in secure bins when moved from office or department to the organization's information destruction area. Tardiness in following data destruction schedules may result in potential security risks and costs associated with storage, retrieval, and access.
Ongoing Monitoring and Compliance
5.1 Compliance Monitoring
The organization shall perform regular reviews to verify compliance with this Policy and all applicable federal regulations. Ongoing evaluations and audits shall be conducted to monitor conformity with standards. Identified exceptions shall be documented, and corrective actions initiated.
5.2 Third-Party Service Provider Oversight
All third-party service providers shall be subject to oversight to assure compliance with applicable federal legislation. Monitoring activities shall include:
Conducting comprehensive due diligence;
Reviewing policies, procedures, internal controls, and training materials;
Establishing clear contractual expectations related to compliance; and
Implementing appropriate and enforceable consequences for violations.