Data Privacy Principles

Privacy Vision

Pension Benefit Information, LLC (“PBI”) is committed to the responsible use of information and protecting individual privacy rights. PBI strives to provide services to businesses, individuals, nonprofit organizations and government agencies that help reduce and prevent fraud and fulfill fiduciary responsibilities in ways that protect individuals’ privacy. We aspire to protect individuals’ privacy through the design of our products, by credentialing, monitoring, and auditing our customers as appropriate, and through other information security safeguards

Data Privacy Principles

The PBI Data Privacy Principles (the “Principles”) apply to the personally identifiable information, including sensitive personally identifiable information, collected, maintained, used or disseminated in connection with services offered by PBI.

PBI applies these Principles to our products and services where appropriate. In addition, other uses or disclosures may occur as required by applicable law, such as the Fair Credit Reporting Act and its state analogues (“FCRA”), the Driver’s Privacy Protection Act and its state analogues (“DPPA”), and the Gramm-Leach-Bliley Act (“GLBA”). If the law requires or upon request of law enforcement, or, if necessary, to prevent fraud or to protect our company systems, these principles may not apply. PBI also, from time to time, may revise our Principles by posting changes on PBI’s website.

1. SECURITY
Data security is a company imperative. PBI strives to protect the personally identifiable information that we maintain or disseminate, including through the use of appropriate administrative, physical, and technical safeguards.

2. DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION
PBI strives to provide additional safeguards for sensitive personally identifiable information, such as Social Security Numbers (“SSNs”). PBI strives to limit the availability and access to full SSNs. PBI strives to protect the confidentiality of SSNs by limiting access to SSNs to certain legitimate and authorized users, such as: state, local and federal government entities; financial institutions; insurers; employers; and other user types to which PBI may decide to provide such access. A limited number of public records may contain SSNs that are already available to the public and, if such public records are accessed through PBI services, our services may provide access to such SSNs. PBI prohibits the unlawful disclosure of SSNs.

3. ACCURACY
PBI strives to accurately report information in its products. PBI also strives to accurately report information that it receives from its data sources. PBI recognizes, however, that reporting errors may occur and offers individuals opportunities, where applicable, to dispute and correct information that we report as discussed further in Principle 7 on Access and Correction.

4. EDUCATION
PBI strives to inform its employees and client users about appropriate use of PBI products and services. PBI strives to inform its employees and client users about:
• Privacy and security issues associated with PBI information products and services; and
• The responsible use of personally identifiable information.

5. REPUTABLE SOURCES
PBI strives to acquire personally identifiable information from established, reputable sources in the government and private sectors. In support of this Principle, PBI takes reasonable steps to assess the reputation and reliability of its private sector data sources before incorporating personally identifiable information from the source into its products and services. PBI also strives to obtain assurances from its data suppliers that they have the legal right to license or sell the data to PBI.

6. NOTICE

PBI makes its Principles publicly known and publicly posts these Principles.

For additional information about the Pension Benefit Information, LLC Data Privacy Principles, contact the IT Operations team at 612.371.3008 or email help@pbinfo.com.

7. ACCESS & CORRECTION
PBI strives to provide individuals with a central point of contact regarding their questions about PBI and its commitment to the responsible use of personally identifiable information. PBI strives to inform individuals about the nature of the public records, nonpublic information, and publicly available information that PBI makes available in its information products and services. PBI also strives, as appropriate and practicable, to provide opportunities for individuals to dispute and correct information by assisting them in identifying the potential information sources at which corrections should be made. PBI strives to direct individuals to the government and private entities that collect and maintain public records and publicly available information to correct any claimed inaccuracies found in that data, and to direct individuals to consumer reporting agencies where such agency is the source of the information about the individual and where the individual seeks to correct claimed inaccuracies found in that data.

8. ACCOUNTABILITY
PBI supports accountability of information industry standards and practices, responsible and effective federal regulation of the data industry, and legislation governing the practices of all data providers. PBI also supports industry oversight and active engagement with the privacy community. PBI believes that strong privacy and information security protections are vital for an effective and trusted data industry.

9. ONLINE PRIVACY
PBI strives to protect the privacy of personally identifiable information obtained over the Internet and strives to apply our Principles and evolving standards to the online environment.

10. IDENTITY THEFT
PBI strives to prevent the acquisition of information from its products and services for improper purposes, such as identity theft. PBI believes that it is important that individuals who may have had their sensitive personally identifiable information acquired by an unauthorized individual be notified as appropriate.

11. COMPLIANCE
PBI will obtain assessments from an independent auditor, who uses procedures and standards generally accepted in the profession to assess PBI’s administrative, technical, and physical safeguards, as appropriate.

Last Revision: 3/20/19

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