Virginia Regulatory Town Hall
Agency
Library of Virginia
 
Board
Library of Virginia (Library Board)
 
chapter
Regulations Governing the Destruction of Public Records Containing Social Security Numbers [17 VAC 15 ‑ 120]
Action Regulations Governing the Destruction of Public Records Containing Social Security Numbers
Stage Proposed
Comment Period Ended on 11/2/2007
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10/15/07  10:05 am
Commenter: Jerome Kendall / Chesterfield County VA Government

Suggestions for "Regulations Governing the Destruction of Public Records Containing Social Security"
 

Include "machine-readable" in the definition of electronic record.

Iclude a definition for "media".

In the very last paragraph, reference is made to "or other privacy-protected information" in addition to Social Security numbers.   This should be added into the paragraph that begins "Public records, regardless of media" as "that contain social security numbers OR OTHER PRIVACY-PROTECTED INFORMATION must be shredded...."

"Social Security" refers to the specific Social Security program, and should therefore be capitalized.

Section B, #2: The very idea that IT shops in every political subdivision of the Commonwealth are actually going to time the overwriting/degaussing of privacy-protected information residing on back-up tapes to be simultaneous with the destruction of the privacy-protected information which those tapes actually back-up is almost certainly going to be laughed at by those IT shops.  I suggest the language be modified to simply assert that the back-up tapes should be overwritten, wiped, or degaussed to the extent necessary to ensure the irretrievability of the data on them, but that a more reasonable period of time be allowed for; 30 - 60 days, perhaps.

 

CommentID: 505