Data Security/Personal Information Breach Protocols

If you are a service provider of RCOC and confidential and personally identifiable information related to individuals you are serving is lost, stolen, or obtained by an unauthorized entity, you must submit a Security Breach Report to RCOC’s Information Security Officer via email at iso@nullrcocdd.com using the following form:  Security Breach Report
In addition to submitting a Security Breach Report, you are required to inform each person via letter who may have been affected by the breach.  A sample notification letter template that includes the necessary elements is available here:  Security Breach Notification Letter Template
If you have any questions please contact RCOC’s Information Security Officer via email at iso@nullrcocdd.com.

Confidential and Personally Identifiable Information

Includes the following 19 individual identifiers:

  1. Name
  2. Address (all geographic subdivisions smaller than state, including street address, city, county, or ZIP code)
  3. All elements (except years) of dates related to an individual (including birth date, admission date, discharge date, date of death, and exact age if over 89)
  4. Telephone numbers
  5. FAX number
  6. Social Security number
  7. Medical record number
  8. Health plan beneficiary number
  9. Account number
  10. Online Account – User Name or Email Address, in combination with a password or security question and answer
  11. Certificate/license number
  12. Any vehicle or other device serial number
  13. Device identifiers or serial numbers
  14. Web URL
  15. IP address
  16. Finger or voiceprints
  17. Photographic images
  18. Any other unique identifying number, characteristic, or code (including UCI number)
  19. Vehicle license plate number (effective January 2016)

NOTE: In California, unauthorized disclosure of an individual’s “Name” and any other “notice-triggering” data element (underlined, bold) is considered a reportable breach.  In the U.S., a federally reportable breach is an unauthorized disclosure of any three (of the 18 individual identifiers) data elements. (Vehicle license plate number is not a Federal personal individual identifying data element).