Privacy Principles
Privacy Vision
Pension Benefit Information, LLC (“PBI,” “our,” or “we”) is committed to the responsible use of information and protection of individual privacy rights. PBI strives to provide products and services to businesses, individuals, nonprofit organizations and government agencies that help reduce and prevent fraud, mitigate risk, and fulfill fiduciary responsibilities in ways that protect individuals’ privacy. We aspire to protect individuals’ privacy through the design of our products and services, by credentialing, monitoring, and auditing our business clients as appropriate, and through other information security safeguards. We also strive to promote transparency through privacy principles and policies.
Privacy Principles
PBI’s Privacy Principles (the “Principles”) speak to personally identifiable information, including sensitive personally identifiable information, collected, maintained, used, disclosed, or processed in connection with products and services offered by PBI.
PBI offers products and services only for use in the U.S. and applies the Principles to our products and services where appropriate. In addition, other uses or disclosures may occur as required by applicable law, such as the Fair Credit Reporting Act and its state analogues (“FCRA”), the Driver’s Privacy Protection Act and its state analogues (“DPPA”), and the Gramm-Leach-Bliley Act (“GLBA”). The Principles may not apply (i) where the law requires or upon request of law enforcement, or (ii) where necessary, to prevent fraud or to protect our company systems. From time to time, we may revise the Principles by posting changes on PBI’s websites.
1. SECURITY
Data security is a company imperative. PBI strives to protect personally identifiable information that we collect, maintain, process, or disclose, including by using appropriate administrative, physical, and technical safeguards.
2. PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION
PBI strives to provide additional safeguards for sensitive personally identifiable information, such as government identifiers. PBI strives to limit the availability of and access to government identifiers. PBI strives to protect the confidentiality of government identifiers by limiting access to government identifiers to certain legitimate and authorized users, such as: state, local and federal government entities; financial institutions; insurers; employers; and other user types to which PBI may decide to provide such access. A limited number of public records may contain government identifiers that are already available to the public and, if such public records are accessed through PBI’s products and services, our products and services may provide access to such government identifiers. PBI prohibits the unlawful disclosure of government identifiers.
3. ACCURACY
PBI strives to accurately report information in our products and services. PBI also strives to accurately report information that we receive from our data sources and business clients. PBI recognizes that data sources and business clients’ records may be incomplete or inaccurate and reporting or data entry errors may occur. reporting errors may occur. PBI assists our business clients, where appropriate and practicable, to dispute and correct information that we report, as discussed further in Principle 7 on Access and Correction.
4. EDUCATION
PBI strives to inform our employees and business client users about:
- Appropriate use of PBI’s products and services;
- Privacy and security issues associated with PBI products and services; and
- The responsible use of personally identifiable information, including sensitive personally identifiable information.
5. REPUTABLE SOURCES
PBI strives to acquire personally identifiable information from established, reputable sources in the government and private sectors. PBI may also acquire personally identifiable information from public sources. In support of this Principle, PBI takes reasonable steps to assess the reputation and reliability of our data sources before incorporating personally identifiable information from the source into PBI products and services. PBI also strives to obtain assurances from our data suppliers that they have the legal right to provide data to PBI.
6. NOTICE
PBI publicly posts the Principles on our websites.
For additional information about these Principles, contact PBI at 415-482-9611 or by email to help@pbinfo.com.
7. ACCESS & CORRECTION
As appropriate and practicable, PBI strives to:
- Provide business clients with a central point of contact regarding their questions about PBI and our commitment to the responsible use of personally identifiable information;
- Inform business clients about the nature of public records, nonpublic information, and publicly available information that PBI makes available in our products and services;
- Provide opportunities for individuals to dispute and correct information by assisting them in identifying the potential information sources at which corrections should be made;
- Direct individuals to the government and private entities that collect and maintain public records and publicly available information to correct any claimed inaccuracies found in that data; and
- Direct individuals to consumer reporting agencies where such agency is the source of the information about the individual and where the individual seeks to correct claimed inaccuracies found in that data.
8. ACCOUNTABILITY
PBI supports accountability of information industry standards and practices, responsible and effective federal regulation of the data industry, and legislation governing the practices of all data providers. PBI also supports industry oversight and active engagement with the privacy community. PBI believes that strong privacy and information security protections are vital for an effective and trusted industry.
9. ONLINE PRIVACY
PBI strives to protect the privacy of personally identifiable information obtained over the Internet and strives to apply the Principles and evolving standards to the online environment.
10. IDENTITY THEFT
PBI strives to prevent the acquisition of information from our products and services for improper purposes, such as identity theft. PBI understands the importance of notifying data owners where individuals’ sensitive personally identifiable information was acquired by an unauthorized individual.
11. COMPLIANCE
PBI will obtain assessments from an independent auditor, who uses procedures and standards generally accepted in the profession to assess PBI’s controls relevant to security, availability, and confidentiality, as appropriate.
Last Revision: 5/1/2024