PRIVACY PROTECTION POLICY

Employees are permitted to access and use “personal information” only as necessary and appropriate for such persons to carry out their assigned tasks for Harvard and in accordance with Company policy. “Personal information” means information capable of being associated with a particular individual through one or more identifiers, including, but not limited to, a Social Security number (SSN), a driver’s license number, a state identification card number, an account number, a credit or debit card number, a passport number, an alien registration number or a health insurance identification number, and does not include publicly available information that is lawfully made available to the general public from federal, state or local government records or widely distributed media. Accessing and using such information without authorization by Harvard or contrary to Harvard’s policies and procedures can result in discipline up to and including termination of employment. Employees who come into contact with SSNs or other sensitive personal information without authorization from Harvard or under circumstances outside of their assigned tasks may not use or disclose the information further, but must contact the Human Resources Department to turn over all copies of the information in whatever form.

For more information about whether and under what circumstances employees may have access to this information, employees may review their job description or contact the Human Resources Department.