Continental Western Group (“CWG”, “we”, “us” or “our) a member company of the W. R. Berkley Corporation (collectively, the “Company) is committed to maintaining the confidentiality of Social Security numbers that we collect during the regular course of our business. Accordingly, Continental Western Group has established this Social Security Number Privacy Protection Policy (the “Policy”) to restrict access, disclosure, use and disposal of Social Security numbers that have been collected by the Company. The purpose of this Policy is to comply with federal, state and local law protecting the confidentiality of Social Security numbers, including but not limited to Connecticut Public Act No. 08-167, effective October 1, 2008.
II. PROCEDURES TO PROTECT THE CONFIDENTIALITY OF SOCIAL SECURITY NUMBERS
Authorized Collection and Access To Social Security Numbers
Continental Western Group collects the Social Security numbers of employees, applicants, independent contractors, interns and other individuals only for legitimate business reasons. Examples of such reasons may include:
- The handling of insurance claims and payments in connection with operating its insurance business;
- Background checks for applicants for employment;
- Determining eligibility for employment;
- Enrollment in employee benefits programs;
- Reporting that is required by law, such as for tax purposes.
Continental Western Group restricts access to the Social Security numbers that it collects only to Continental Western Group employees and certain third parties who are authorized to access this information. Authorized employees are those who the Company has determined have a legitimate business need to access this information. Authorized third parties are those who have a legitimate need to access this information and owe a duty to maintain its confidentiality (e.g. vendors who are provided Social Security numbers to run background checks and insurance providers).
Disclosure and Use of Social Security Numbers
Continental Western Group prohibits the disclosure and use of Social Security numbers unless such disclosure and use complies with this Policy and with federal, state and local law. Social Security numbers shall not be displayed on identification cards or badges, bulletin boards, or any similar materials that are publicly displayed. Documents, materials or computer screens that display Social Security numbers shall be shown only to authorized employees and third parties and shall be kept out of public view at all times.
Social Security numbers may only be used by authorized Continental Western Group employees for legitimate business reasons, including but not limited to those reasons described above.
Storage and Disposal of Personal Information Including Social Security Numbers
Continental Western Group shall take reasonable steps so that all documents and files (both electronic and in hard copy) that contain personal information such as Social Security numbers shall be stored in a physically secure manner. “Personal information” is defined under the law as information capable of being associated with a particular individual through one or more identifiers. Examples of personal information include a person’s Social Security number, driver’s license number, passport number, credit or debit card numbers, and health insurance identification numbers.
Continental Western Group requires that personal information be stored in a way that prevents unauthorized access. For example, hard copy documents that contain personal information should be stored in files that can only be accessed by authorized Continental Western Group employees or third parties, and computers or other electronic devices that contain personal information should be secured against unauthorized access, such as through the use of a password. Continental Western Group requires that any authorized personnel who maintains personal information must take appropriate steps consistent with this Policy to safeguard such information.
Documents or other materials (both electronic and in hard copy) that contain personal information shall be disposed of in a manner such that the personal information is erased or made unreadable at the time of disposal. It may be necessary to consult with Continental Western Group’s IT department to ensure proper disposal of personal information that is stored electronically.
III. NON-COMPLIANCE WITH THIS POLICY AND THE LAW
Failure to comply with this Policy may result in disciplinary action up to and including termination. Furthermore, the law provides civil and criminal penalties for individuals who violate laws protecting the confidentiality of Social Security numbers.
If you have any questions about this Policy, including about how to dispose of personal information, please contact the Office of General Counsel at (515) 473-4300.
Last updated January 4, 2018