Personally Identifiable Information (PII) is information that can be used to distinguish or trace an individual's identity, either alone or when combined with other information. Because there are many different types of information that can be used to distinguish or trace an individual's identity, the term PII is necessarily broad. The definition of PII is not anchored to any single category of information or technology. Rather, it requires a case-by-case assessment of the specific risk that an individual can be identified using information that is linked or linkable to said individual. In performing this assessment, it is important to recognize that information that is not PII can become PII whenever additional information is made publicly available — in any medium and from any source — that, when combined with other information to identify a specific individual, could be used to identify an individual (e.g. SSNs, name, DOB, home address, home email).
A breach is an unauthorized disclosure, unauthorized acquisition, unauthorized access, and/or any similar occurrence where a person other than an authorized user accesses PII or an authorized user accesses PII for other than an authorized purpose.
Essent protects the information entrusted to it. Essent representatives undergo security and privacy training prior to obtaining access to information and annually to ensure individuals are up-to-date on the proper handling of PII. Failure to complete required training results in denial of access to information.
Users and Systems are tested annually to determine their incident response capability and incident response effectiveness. Essent meets annually for a tabletop exercise, designed to test the breach response procedure and to help ensure members of the Response Team are familiar with the plan and understand their specific roles.
Essent employees and contractors with access to data and information systems must report all concerns, suspected breeches, or confirmed breaches. Core event information must be collected and reported: date of the incident, location of the incident, breached data, nature of the breach (loss of control, compromise, unauthorized access or use, other), and the suspected number of impacted individuals, if known.
A breach involving personally identifiable information (PII) in electronic or physical form must be reported to the Executive Vice President within one hour of discovering the incident, who in turn must report it to the President. In terms of reporting, there should be no distinction between suspected and confirmed PII breach incidents.
A Response Team will be formed to determine the level of risk to the impacted individuals with the appropriate remedy and form a Breach Response Plan.
The Response Team will respond to all breaches and will perform an initial assessment of the risk of harm to individuals potentially affected.
This team will analyze reported breaches to determine whether a breach occurred, the scope of the information breached, the potential impact the breached information may have on individuals and on Essent.
This team consists of the manager of the area experiencing or responsible for the breach, the head of development, the head of systems, and the Executive Vice President.
Within the confines of the law, notification may be delayed if a notification would potentially cause harm, including further breaches. Notification to affected parties may not occur or may be delayed if a national security or law enforcement agency determines that the notification will impede a criminal investigation.
The Response Team will determine whether notification is necessary for all breaches under their purview. To determine whether notification of a breach is necessary, the respective team will determine the scope of the breach, to include the types of information exposed, the number of people impacted, and whether the information could potentially be used for identity theft. The team will also assess the likely risk of harm caused by the breach. Finally, the team will assess the level of risk and consider a wide range of harms that include harm to reputation and potential risk of harassment, especially when personal records such as health or financial records are involved.
In the event the decision to notify is made, every effort will be made to notify impacted parties as soon as possible unless otherwise precluded above. Notification shall contain details about the breach, including what information was compromised and whether credit monitoring will be offered. Initial notification shall be completed without undue delay from the time the incident was determined to be a breach.
At the end of each fiscal year, Essent will review reports, if any, from the Response Team detailing the status of each breach reported during the fiscal year and consider whether it is necessary to take any action, which may include but is not limited to:
We may update this Data Breach Notification Policy. We will post any changes to our Policy so that you are always aware of the information within it.
Essent is the leading provider of fully-integrated business management software solutions and services for process-intensive industries and the largest trading network for the promotional products industry. The Essent family of fully-integrated products and services combines best practices, business processes, software automation, and network communications to deliver unparalleled, unified business management solutions. Since 1980, Essent has offered the systems, service, software, and support critical to success in today's highly-competitive marketplace.