All tenant records will reflect the high quality of management and professional standards. The verification reports from the EIV system will be retained in the tenant file and disposed of based on the Federal Trade Commission (FTC) and HUD requirements according to the following schedule:
A. O/As must retain:
1. The social security benefit reports and the new hires (W-4), wage and unemployment income reports obtained from EIV that are used as third party verification for the term of tenancy plus three years after tenancy is terminated.
2. Any tenant provided documentation, or other third party verification of income, received to supplement the SSA or NDNH data for the term of tenancy plus three years after tenancy is terminated.
Once the retention period has expired, O/As must dispose of the data in a manner that will prevent any unauthorized access to personal information, e.g., burn, pulverize, shred, etc.
Disposal of Information
In accordance with the FTC “Disposal of Consumer Report Information and Record”, any applicant or resident files that are purged based on the Records and Retention Policy will be disposed properly. A "proper" disposal of this information must be one that is reasonable and appropriate to prevent any unauthorized access to person information such as the items listed above.
Approved disposal methods include:
Burn, pulverize, or shred papers containing consumer report information so that the information cannot be read or reconstructed;
Destroy or erase electronic files or media containing consumer report information so that the information cannot be read or reconstructed;
Conduct due diligence and hire a document destruction contractor to dispose of material specifically identified as consumer report information consistent with the Rule.
Attachments;
History______________________________________________________________
Gabrielle Harris composed this Policy/Procedure on 02/09/2011 03:12:45 PM.