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« Compliance Q&A: Myths, mistakes and management advice | Main | Reasons for Throwing Away Evidence...People Say the Darnedest Things! »

Thief Steals Credit Card Information from Dumpster and Buys Computer; Remember the Disposal Rule

Today the Edmonton Sun reported that:

"A crook used stolen credit card information to buy a laptop computer after an Edmonton company dumped 2,606 credit and debit card sales receipts in an unlocked dumpster, says the Information and Privacy Commissioner's office. Monarch Beauty Supply came to the attention of Information and Privacy Commissioner Frank Work last September after Edmonton city cops advised that someone had turned over documents containing personal information from the Monarch Beauty Supply store in west Edmonton. The documents included the store's daily financial records along with customer credit and debit sales receipts containing customers' names, credit card numbers, expiry dates, customers' signatures and debit card numbers. The receipts were for transactions over a two-year period. Work investigated and found that Monarch Beauty Supply had contravened the Personal Information Protection Act by dumping the sensitive information in the unlocked dumpster."

I've seen multiple organizations that have invested huge amounts of financial and human resources to protect their networks, and then have non-existent security over the data and computers they dispose of...many doing similar things, such as dumping large amounts of papers with confidential information into open dumpsters.  This incident happened in Canada, but these types of situations happen all the time in the U.S., and other countries, as well. 

I don't think a lot of U.S. organizations, especially small- and medium-sized businesses, are aware of the Disposal Rule that is part of the U.S. Fair and Accurate Credit Transactions Act (FACTA).  The Disposal Rule went into effect on June 1, 2005.  The FTC provides a guidance document about how to comply with this rule.

Do you need to comply with the Disposal Rule?  The FTC says:

"The Disposal Rule applies to people and both large and small organizations that use consumer reports. Among those who must comply with the Rule are:

Consumer reporting companies
Lenders
Insurers
Employers
Landlords
Government agencies
Mortgage brokers
Automobile dealers
Attorneys or private investigators
Debt collectors
Individuals who obtain a credit report on prospective nannies, contractors, or tenants
Entities that maintain information in consumer reports as part of their role as service providers to other organizations covered by the Rule."

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Comments

Just whack off the front part to leave:

http://www.ftc.gov/bcp/conline/pubs/alerts/disposalalrt.htm

Thanks for the post, Rebecca. Good job, as usual!

Oops! I apologize for the dead link...sometimes when writing these entries I am HTML-challenged. :)

I have fixed it now...

Thanks for pointing it out!

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Rebecca Herold's Bio:

Rebecca Herold,CISSP, CIPP, CISM, CISA, FLMI, has been providing information security, privacy and regulatory assistance and services to organizations from a wide range of industries for over 18 years. Rebecca was instrumental in building the information security and privacy program while at Principal Financial Group, which was awarded the CSI Information Security Program of the Year Award in 1998. IT Security ranked Rebecca as one of the top 59 IT security influencers, and Computerworld put Rebecca their list of the 25 top privacy experts and on their list of the 9 best privacy consulting firms. Rebecca has been CPO for two consulting organizations, and has had her own information privacy, security and compliance business since 2004. Rebecca has written chapters for several books, dozens of articles, and has been writing a monthly privacy column for the CSI Alert newsletter since the beginning of 2001, and is working on her 11th book. Some of her other books include The Privacy Papers, Managing an Information Security and Privacy Awareness and Training Program, The Definitive Guide to Security Inside the Perimeter (Realtime Publishers), The Shortcut Guide to Improving IT Service Support through ITIL (Realtime Publishers), and The Practical Guide to HIPAA Privacy and Security Compliance. In addition, Rebecca is the leader of The Realtime IT Compliance Community where she posts to her IT Compliance weblog. You can contact Rebecca at: rebecca_herold@realtimepublishers.net.