TechTown is dedicated to protecting the personal security and privacy of all team members and customers.

In the ordinary course of its business, and for legitimate business reasons, TechTown may collect and store

personal information about its team members and customers, including all or any part of a team member's

or customer's social security number (“SSN”), in hard copy or digital storage. For purposes of this policy,

“SSN” means more than four sequential digits of a team member's or customer's social security number.

TechTown takes measures to prevent the unauthorized disclosure of a SSN, including without limitation:

• Ensuring the confidentiality of SSNs

• Prohibiting unlawful or unauthorized disclosure of SSNs

• Limiting the number of people with access to SSNs- and the circumstances under which

SSNs may be accessed

• Ensuring the proper disposal of documents (hard copy or digital) that contain SSNs

• Disciplining, up to and including termination, any team member who violates this policy

TechTown, and all team members who may have access to SSNs, will maintain the security and

confidentiality of every document containing the SSN. This means, at a minimum, that TechTown will

securely maintain documents containing SSNs and that any access to digital files containing all of an SSN

will be password protected.

Furthermore, no team member shall display or disclose an SSN without the express written consent of the

individual to whom the SSN is assigned. TechTown will not mail any document containing an SSN that is

visible on, or from, the outside of the mailed article. Nor will TechTown use the SSN as an identifying

number for its team members, or visibly print it on identification tags, badges, passes, cards, or licenses.

TechTown will not require team members to use or transmit their SSN over the internet, or any organization

intranet, computer system or network unless the connection is secure, or the transmission is encrypted.

TechTown restricts access to any document displaying an SSN to those with a legitimate business need to

access those documents. Access to these documents by anyone other than those individuals with a

legitimate business need must be specifically authorized, in writing by the Human Resources Director or by

the individual to whom the SSN is assigned. Documents containing an SSN will be disposed of in

accordance with TechTown's document retention policy and procedures in such a manner so that they

cannot be read or reconstructed in order to preserve the confidential nature of such documents.

Nothing in this policy is intended to modify a team member's right to access their own personnel file, as

permitted by applicable law. Nor does this policy prohibit the use of a SSN where the use is authorized by

state or federal statute, rule, regulation, court order, or pursuant to legal discovery or process.

Violations of this policy will result in disciplinary action up to and including termination of employment.

Violators may also be subject to civil and criminal penalties authorized by applicable state or federal law.