R 271812Z JUN 07
UNCLAS
MARADMIN 389/07
MSGID/GENADMIN/CMC WASHINGTON DC/ARS//
SUBJ/DISPOSAL PROCEDURES FOR DOCUMENTS CONTAINING PERSONALLY IDENTIFYING INFORMATION (PII)//
REF/A/MSGID:DOC/NAVAUDSVC N2006-NFO000-0066.000/-/MAR 07//
REF/B/MSGID:DOC/SECNAV WASHINGTON DC/28DEC2005//
REF/C/MSGID:MSG/CMC WASHINGTON DC MRA MI/262120ZJUL06//
NARR/REF A IS A DRAFT NAVAL AUDIT SERVICE REPORT PERTAINING TO THE DISPOSAL OF PROTECTED PERSONAL INFORMATION (PPI) AT DON FACILITIES. REF B IS SECNAVINST 5211.5E, DEPARTMENT OF THE NAVY PRIVACY ACT (PA) PROGRAM. REF C IS MARADMIN 348/06 WHICH PROVIDES AMPLIFYING GUIDANCE FOR THE STORAGE, TRANSPORTATION, POSTING, AND DISPOSAL OF PRIVACY ACT DATA.//
POC/TERESA D. ROSS/GS-14/HQMC ARSF/-/TEL:703-614-4008/ EMAIL:TERESA.D.ROSS@USMC.MIL//
GENTEXT/-/1. IN LIGHT OF RECENTLY ESTABLISHED CROSS-AGENCY REPORTING REQUIREMENTS PERTAINING TO ISSUES SURROUNDING THE LOSS OR BREACH OF PERSONAL INFORMATION BY FEDERAL AGENCIES, THE OFFICE OF MANAGEMENT AND BUDGET HAS ESTABLISHED ONE STANDARD TO DESCRIBE PERSONAL DATA. ANY INFORMATION ABOUT AN INDIVIDUAL THAT CAN BE USED TO IDENTIFY A PERSON UNIQUELY AND RELIABLY, INCLUDING BUT NOT LIMITED TO NAME, ADDRESS, TELEPHONE NUMBER, EMAIL ADDRESS, BIOMETRICS, DATE OF BIRTH, RACE, RELIGIOUS AFFILIATION, ETC., WILL BE CHARACTERIZED AS PERSONALLY IDENTIFABLE INFORMATION (PII). ALL PREVIOUS REFERENCES USED TO CHARACTERIZE PERSONAL DATA, SUCH AS PRIVACY ACT INFORMATION (PAI) OR PERSONAL PRIVACY INFORMATION (PPI), ARE OBSOLETE AND THEIR USE SHOULD BE DISCONTINUED.
2. SAFEGUARDING PII IS OF GREAT CONCERN TO THE MARINE CORPS, PARTICULARLY WITH REGARD TO ENSURING THAT PII IS PROPERLY DISPOSED OF WHEN ITS RETENTION IS NO LONGER REQUIRED. THE PROPER DISPOSAL OF PII AVOIDS A LOSS OR COMPROMISE THAT COULD PLACE AN UNDUE BURDEN UPON INDIVIDUAL MARINES AND THEIR FAMILIES, AS WELL AS CIVILIAN EMPLOYEES AND CONTRACTORS. ENSURING THAT PROPER HANDLING AND DISPOSAL PROCEDURES ARE FOLLOWED IS PARAMOUNT TO MARINE CORPS EFFORTS TO AVOID THE COMPROMISE OR LOSS OF PII.
3. MARINE CORPS OFFICIALS RESPONSIBLE FOR THE COLLECTION AND MAINTENANCE OF DOCUMENTS CONTAINING PII ARE TO: A. IMMEDIATELY IMPLEMENT PROCEDURES TO ENSURE DOCUMENTS CONTAINING PII ARE PROPERLY DISPOSED OF. B. ESTABLISH INTERNAL CONTROLS TO ENSURE THAT PERIODIC RANDOM CHECKS ARE MADE TO ENSURE PROPER DISPOSAL PROCEDURES ARE BEING FOLLOWED.
4. REF A DETAILS RESULTS OF RECENT NAVAL AUDIT SERVICE WORK AT EIGHT NAVY AND MARINE CORPS INSTALLATIONS WHERE IT WAS FOUND THAT PII WAS NOT BEING PROPERLY DISPOSED OF. DOCUMENTS SUCH AS MEDICAL RECORDS, TRAFFIC TICKETS AND OTHER POLICE RECORDS, TRAVEL DOCUMENTS, PERSONNEL ROSTERS, TRAINING FORMS, ETC., WERE FOUND AT BOTH ON-BASE AND OFF-BASE (COMMERCIAL) RECYCLING FACILITIES, AND IN OFFICE TRASH CANS, DUMPSTERS, AND OTHER WASTE STREAM LOCATIONS.
5. REF B DEFINES PROPER DISPOSAL AS ANY MEANS OF DESTRUCTION THAT RENDERS A DOCUMENT UNRECOGNIZABLE AND BEYOND RECONSTRUCTION (I.E., TEARING, BURNING, MELTING, CHEMICAL DECOMPOSITION, PULPING, PULVERIZING, SHREDDING, OR MULTILATION). PER PARAGRAPH 9 OF REF B, DOCUMENTS CONTAINING PRIVACY ACT INFORMATION (NOW CHARACTERIZED AS PII) WILL BE MARKED "FOR OFFICIAL USE ONLY" WHEN CREATED, AND THEN SHREDDED WHEN NO LONGER REQUIRED (WHEN SHREDDING, CROSS-CUT SHREDDING IS RECOMMENDED). FURTHER, PLACING DOCUMENTS CONTAINING PII IN RECYCLE BINS IS INSUFFICIENT TO MEET THIS DISPOSAL REQUIREMENT SINCE RECYCLING FACILITIES TYPICALLY BALE THE INTACT PAPER FOR TRANSPORT TO COMMERCIAL PAPER MILLS.
6. QUESTIONS REGARDING IMPLEMENTATION SHOULD BE DIRECTED TO THE USMC PRIVACY MANAGER, TERESA D. ROSS, AT 703-614-4008 OR TERESA.D.ROSS@USMC.MIL. INFORMATION REGARDING THE PRIVACY ACT OF 1974 AND PII HANDLING CAN ALSO BE FOUND AT HTTP:(SLASH)(SLASH)PRIVACY.NAVY.MIL.//