Pursuant to Connecticut Public Act 08-167, An Act Concerning Confidentiality of Social Security Numbers, I am required to advise you of my firm’s policy about safeguarding personal information.
As defined in the Act, “personal information” means information capable of being associated with a particular individual through one or more identifiers, including, but not limited to, a Social Security number, a driver’s license number, a state identification card number, an account number, a credit or debit card number, a passport number, an alien registration number or a health insurance identification number, and does not include publicly available information that is lawfully made available to the general public from federal, state or local government records or widely distributed media.
The Act states that personal information that I acquire from you must be safeguarded against “misuse by third parties” and that I “shall destroy, erase or make unreadable such data, computer files and documents prior to disposal.”
My firm’s policy is to restrict access to my files to firm personnel and to destroy personal information when files are stripped or otherwise disposed of, and to (1) protect the confidentiality of Social Security numbers, (2) prohibit unlawful disclosure of Social Security numbers, and (3) limit access to Social Security numbers. In addition, I stringently adhere to the requirements of attorney-client confidentiality as set forth in Rule 1.6 of the Connecticut Rules of Professional Conduct, which provides:
(a) A lawyer shall not reveal information relating to representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation, or the disclosure is permitted by subsection (b), (c), or (d).
(b) A lawyer shall reveal such information to the extent the lawyer reasonably believes necessary to prevent the client from committing a criminal act that the lawyer believes is likely to result in death or substantial bodily harm.
(c) A lawyer may reveal such information to the extent the lawyer reasonably believes necessary to:
(1) Prevent the client from committing a criminal act that the lawyer believes is likely to result in substantial injury to the financial interest or property of another;
(2) Prevent, mitigate or rectify the consequence of a client’s criminal or fraudulent act in the commission of which the lawyer’s services had been used.;
(3) Secure legal advice about the lawyer’s compliance with these Rules;
(4) Comply with other law or a court order.
(d) A lawyer may reveal such information to establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and the client, to establish a defense to a criminal charge or civil claim against the lawyer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer’s representation of the client.
However, insofar as I am required by law to disclose your personal information to third parties in connection with litigation, Title IV-D filings, escrow accounts, and probate matters, or when you authorize me to release information to others (including banks), I cannot guarantee that third parties will not “misuse” the data.
If you have any questions, please contact me.