4020
Policy
Personnel - All Employees
Shredding
Consumer Reports
It is the policy of Ashland-Greenwood Public Schools
to take reasonable measures to protect against unauthorized access to consumer
information from consumer reports.[1] A consumer report includes criminal
background checks performed on applicants or employees by a third party. It does not include criminal checks performed
by school staff.
Reasonable measures to protect
against unauthorized access to or use of consumer information in connection
with its disposal include the following examples. These examples are
illustrative only and are not exclusive or exhaustive methods for complying
with this directive.
(1) Shredding of papers containing consumer
information so that the information cannot practicably be read or
reconstructed. Burning or pulverising
such papers are also options where appropriate.
(2) Destruction or erasure of electronic
media containing consumer information so that the information cannot practicably
be read or reconstructed.
(3) After due diligence,[2]
entering into and monitoring compliance with a contract with another party
engaged in the business of record destruction to dispose of material in a
manner consistent with this directive.
This policy does not require
that the consumer reports information be disposed of; rather, it specifies the
action to be taken whenever such disposal occurs. Questions regarding the
disposal of consumer reports information should be directed to the
Superintendent or the Superintendent’s designee.
Legal
Reference: FTC Rule on Disposal of Consumer Report Information and Records,
16 CFR Part 682
Date of Adoption: November 21, 2005
[1]
“The term ‘consumer report’ means any written, oral, or other communication of
any information by a consumer reporting agency bearing on a consumer
[2]
The FTC rule states: “In this context, due diligence could include reviewing an
independent audit of the disposal company