In order to comply with the laws of the states of Connecticut, Michigan, New Mexico, Texas, and any other state where similar laws have been or will be adopted to specifically protect the security of individual Social Security Numbers, Philanthropies hereby adopts the following:
It is our policy not to collect Social Security Numbers through our web site(s) (except as otherwise required by law) or to use it as an identifier. To the extent we are required to have Social Security Numbers in our records it is our policy to protect the confidentiality of those Social Security Numbers by:
a. Ensuring encryption of the Social Security Numbers with storage in secured locations and not allowing documents with Social Security Numbers to be left on desks, other visible areas or in high traffic areas. Social Security Numbers may not be transmitted (e.g., email, any file transfer protocol, instant messaging, and so forth) to authorized parties without appropriate security controls, including encryption and authentication of receipt.
b. Destroying, erasing or making unreadable all data, computer files and documents that may contain Social Security Numbers before disposal;
c. Restricting access to Social Security Numbers, allowing use only on a "need to know" basis to meet the government reporting or other specific legal purposes for which Social Security Numbers were provided and collected; and
d. Actively ensuring that there are no unlawful or inadvertent disclosures of Social Security Numbers by conducting periodic reviews and audits of existing files and by purging Social Security Numbers from existing files within a reasonable time when the need for having the Social Security Numbers on file no longer exists.
Some Social Security Numbers are present on historical records in our archived databases or the databases of our affiliates that we access to support the affiliate's activities. Such historical records cannot be altered, but are to be considered sensitive information and must be handled accordingly.
We will not release any Social Security Numbers to a third party unless required by law, authorized by the individual providing the Social Security Numbers, or the third party is acting as our authorized agent or an agent of our affiliated entities to help meet government reporting requirements or other specific legal purposes.
We reserve the right to change this policy in our discretion and encourage interested parties to check back periodically to determine if any material changes have been made. The current policy as drafted is effective as of September 1, 2008.