Understanding Pii: What Data Elements Are Considered Personally Identifiable?

which of the following data elements constitute pii

Personally Identifiable Information (PII) is a term that refers to any data that can be used to identify an individual. This includes information such as a person's name, date of birth, email address, Social Security Number (SSN), and biometrics. The Privacy Act of 1974 outlines the protections and restrictions related to PII, and it is important to understand which data elements constitute PII to ensure compliance with this Act and to protect individuals' privacy.

Characteristics Values
Name Any full name
Date of Birth Any date of birth
Email Address Any email address
SSN/Truncated SSN Social Security Numbers
Biometrics Fingerprints, facial patterns, voice or typing cadence

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Social Security Numbers (SSNs)

The Privacy Act of 1974 applies to groups of records retrieved by name or other personal identifiers, including SSNs. This means that the unauthorized use, acquisition, storage, or communication of SSNs is restricted by law. For example, New York law mandates reporting to state agencies and affected individuals when an SSN is disclosed in a manner not in compliance with the law.

Organizations that collect SSNs, such as the University of Rochester, are required to comply with legal requirements, support patient safety, or carry out necessary functions. They are responsible for implementing secure methods of storing and communicating SSNs to prevent unauthorized access or disclosure. The University of Rochester's policy, for instance, states that they will collect and record SSNs only when necessary and will use alternative identifiers whenever possible.

The consequences of mishandling SSNs can be severe. Violations of the University of Rochester's policy can result in disciplinary action, up to and including separation from the university and exclusion from its programs and facilities. Unauthorized disclosure of SSNs can also lead to fines, injunctions, and personal liability under New York law. Therefore, it is essential to promptly report any suspected unauthorized access or disclosure of SSNs to the appropriate contacts, such as the university's Privacy Officer or the listed contacts in their IT policy.

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Biometrics

Biometric data is a subset of Personally Identifiable Information (PII) that refers to an individual's unique physical or behavioural characteristics. This includes fingerprints, facial recognition data, iris scans, hand geometry, voice recognition information, and DNA. Biometric data is considered more dangerous than other types of PII as it is harder to change or fake, and it can be collected without an individual's full knowledge or consent, making it difficult for people to understand how their data is being used and shared. This has raised privacy concerns, and some states in the US have passed legislation to protect their citizens' biometric privacy rights. For example, Illinois was the first state to pass the Biometric Information Privacy Act (BIPA), and California and Oregon have also enacted similar laws.

Biometric data is much harder to alter or falsify than other types of PII, such as names, dates of birth, or email addresses, which can be changed or protected if compromised. Biometric data is unique to each individual and cannot be easily altered without significant effort and cost. This permanence makes it a valuable form of identification and authentication, but it also raises concerns about potential misuse or abuse.

The collection and use of biometric data is becoming increasingly common, with more than half of all organizations using it for authentication or other purposes. This trend is likely to continue as technology advances and offers new ways to identify and verify individuals' identities. While biometrics can provide a more secure and convenient way to access devices, accounts, and services, it is essential to balance this with the need to protect individuals' privacy and data.

The sensitivity of biometric data means that its collection, storage, and use must be carefully considered and regulated. Biometric data, if lost, compromised, or disclosed without authorization, could result in substantial harm, embarrassment, or unfairness to an individual. As such, it is categorized as High-Risk PII and is subject to stricter protection and consideration following a breach.

The lack of a clear national standard for limiting the collection of biometric data has led to a patchwork of state-level legislation in the US. This situation could make compliance challenging and costly for businesses operating across multiple states. However, it also demonstrates a growing recognition of the need to protect individuals' biometric privacy rights and the unique risks associated with this form of PII.

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Birthdates

As such, birthdates are attractive to cybercriminals, who steal PII to commit identity theft, sell on the black market, or hold captive via ransomware. The average cost of a data breach caused by a ransomware attack was USD 5.68 million, according to IBM's Cost of a Data Breach 2024 report.

To safeguard PII, organizations typically create data privacy frameworks. These frameworks vary depending on the organization, the PII it collects, and the data privacy regulations it must follow. For example, the National Institute of Standards and Technology (NIST) recommends identifying all PII in an organization's systems and minimizing its collection, use, and retention. Encryption and identity and access management (IAM) are also essential tools for protecting PII.

Individuals can also take steps to protect their PII, such as using complex passwords for online accounts and removing personal identification information from junk mail and other documents. While it is not possible to fully protect oneself from PII theft, these measures can help reduce the risk of becoming a victim of identity theft.

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Names

The National Institute of Security Technology (NIST) includes names in its widely referenced definition of PII. This definition encompasses any information that can be used to distinguish or trace an individual's identity, such as a name, in conjunction with other data. This is an example of "linkable information," which requires multiple pieces of personal data to identify a specific individual. For instance, the name "Jake" is a common first name in the US, but when combined with an address, it could be used to identify a specific person.

The US Department of Labor (DOL) also includes names in its definition of PII, listing "name" as an example of information that directly identifies an individual. DOL contractors and employees are responsible for safeguarding sensitive PII and other data, and must protect against the loss and misuse of such information. This includes refraining from careless or negligent behaviour regarding sensitive data and preventing unauthorized viewing of records.

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Email addresses

An email address is considered personally identifiable information (PII) as it can be used to associate an individual with their online activities. However, it is classified as non-sensitive PII, as it is often public knowledge. Nevertheless, it can still be misused by cybercriminals. For example, scammers can use your email address to send phishing emails to your contacts, tricking them into falling for scams. They can also use your email address to crack your passwords or sign you up for accounts.

To protect your email address from being so publicly available on the web, you can use email services that allow you to generate unlimited aliases. This way, you can create a new alias for each entity that asks for your email address. Apple's iCloud+ users can utilize the "Hide My Email" feature, which generates unique, random email addresses to be given out when filling out forms. These emails will then automatically forward to your private email.

Another method to safeguard your email address is by using a Virtual Private Network (VPN). A VPN directs your internet traffic through an encrypted tunnel, making it harder for hackers to trace your IP address back to your PII, such as your email address. Additionally, you can create a burner account on a separate email domain to use as your public email address, keeping your real email private.

In the context of the General Data Protection Regulation (GDPR), email addresses are considered personal data. This means that their use must be justified, and appropriate security measures must be in place to protect them.

Frequently asked questions

PII stands for Personal Identifiable Information. It includes any data that can be used to identify an individual, such as their name, date of birth, email address, and Social Security Number (SSN).

Some examples of PII include an individual's name, date of birth, email address, SSN, and biometrics. Biometrics refers to data derived from an individual's unique physical or behavioral characteristics, such as fingerprints, facial patterns, voice, or typing cadence.

The Privacy Act of 1974 applies to groups of records retrieved by name or other personal identifiers. It contains remedies and penalties pertaining to the misuse of Privacy Act systems of records, including the improper use of PII by employees.

If you suspect that PII has been lost, stolen, or improperly accessed, you should immediately report the incident to your supervisor, security manager, or the relevant privacy coordinator.

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