In today's data-driven world, understanding and protecting different categories of data is crucial, especially when it comes to personally identifiable information (PII) and personal information. These categories are vital for ensuring data privacy and security, especially in industries that handle sensitive information, such as healthcare, finance, and human subjects research.
Personally Identifiable Information (PII)
PII refers to any data that can be used to identify a specific individual on its own. This type of information is highly sensitive because it can directly point to a single person without needing additional data.
- Social Security Number (SSN): A unique identifier issued by the government.
- Driver’s License Number: A unique identifier assigned by state governments.
- Full Name: A person's complete legal name.
- Full Street Address: The exact residential address of a person.
- Photograph: A clear image that can visually identify someone.
- Telephone Number: A personal phone number that can be traced back to an individual.
Personal Data or Personal Information
Personal Data, often referred to as Personal Information, encompasses a broader range of data points. This category includes not only data that can identify a person when combined but also data that an individual might consider sensitive or that could be used for discriminatory purposes.
- Combination of Birthdate and Surname: While each piece alone might not be unique, together they can identify a person.
- Combination of Birthdate and Zip Code: This can significantly narrow down the pool to identify an individual.
- Sensitive Data: Information that an individual deems private, such as medical records, financial status, or sexual orientation.
- Data Leading to Discrimination: Information that could be used to treat someone unfairly, like race, religion, or gender identity.
Key Considerations for Legally Protected Data
Individual-Level Data: For data to be legally protected under data privacy laws, it must be at the individual level and have the potential to be connected back to a single individual. Simply having data on 1,000 individuals that includes gender and zip code does not constitute personal data unless there is additional information that can narrow it down to specific individuals.
Combination of Data Points: The combination of certain data points increases the likelihood of identifying an individual. For example:
- Gender and Zip Code Alone: Not sufficient to identify a person as there are likely many people of a particular gender in any given zip code.
- Additional Data: Including age, birthdate, profession, race/ethnicity, or other identifiers increases the risk of pinpointing a specific person, making the data more sensitive and more likely to be protected under data privacy laws.
Additional Data Categories Protected Under Data Privacy Rules
- Identifiers: Real Name, Alias, Postal Address, Unique Personal Identifier, Online Identifier, IP Address, Email Address, Account Name, Passport Number.
- Protected Classifications: Race, Gender, Sexual Orientation, Religion.
- Commercial Information: Records of Personal Property, Purchase Histories.
- Biometric Information: Data derived from biological characteristics used for identification.
- Internet or Other Electronic Network Activity Information: Browsing History, Search History, Consumer Interactions with Websites, Applications, Advertisements.
- Geolocation Data: Latitude and Longitude Coordinates.
- Sensory Data: Audio, Electronic, Visual, Thermal, Olfactory.
- Professional or Employment-Related Information: Title, Employment Status, Years of Service, Past Employers, Salary/Wage.
- Education Information: Information not publicly available as defined by FERPA.
- Inferences: Profiles Reflecting Preferences, Characteristics, Psychological Trends.
Effective Strategies for Data Protection
- Data Minimization: Collect only the data you need for a specific purpose.
- Anonymization and Pseudonymization: Remove identifying information or replace it with fake identifiers.
- Encryption: Use strong encryption methods to protect data both in transit and at rest.
- Access Controls: Implement strict access controls and multi-factor authentication.
- Regular Audits and Monitoring: Conduct audits and continuous monitoring of data access.
- Data Breach Response Plan: Develop and maintain a data breach response plan.
- Employee Training: Educate employees about data privacy and security best practices.
- Data Retention Policies: Establish clear data retention policies and securely dispose of data.
- Compliance with Regulations: Ensure compliance with relevant data protection regulations.
- Use of Secure Third-Party Services: Ensure third-party services follow robust security practices.