PROTECTING YOUR RESIDENT PAPER INFORMATION

 

Identity theft occurs when someone uses another individual’s personal identifying information, such as name, Social Security number, or credit card number, without that individual’s permission, to commit fraud or other crimes.

 

Public awareness on this issue is high. When you ask your applicants to complete the rental application, you should be prepared to answer some basic questions:

 

1. Why do you need this information? Is the answer that you need it to run the credit and criminal background checks and to contact prior managers the whole answer? Do you use the information for anything else? Statistical analysis of your resident profile? Marketing? Do you need all the information? Many applications ask for more information than is truly needed. Review your application.

 

2. Who will use this information? You give this information to your background service. Do you or your staff run any background checks (sexual predator website) or contact the prior manager? Do you do follow-up criminal checks periodically during the lease? At time of renewal?

 

3. How will you protect this information? Be careful here. The temptation is to overpromise with broad, reassuring statements like, “We keep everything under lock and key with tight security.” Yet in reality you give all your staff access to the resident files. People may legally rely on your statements. When those statements are false, they may be entitled to compensation for their damages.

 

4. Is there an alternative to giving you this information? Some people are trying to hide their disqualifying past. Others are concerned about the widespread abuse of private information.

 

Personal information is everywhere in your office. The obvious places are the file cabinets, the computers, and the mail. However, what about the less obvious places like the pad with the name, apartment and credit card number of the resident who called because he has to extend his vacation to deal with a family emergency? The half completed application in the trash can?

 

Dispose of all trash properly. Your leasing office trash is a gold mine for identity thieves. Paperwork bagged and placed in the dumpster doesn’t protect against dumpster diving. There’s no excuse for not having a paper shredder. The shredder is worthless without a shredding policy. The policy is worthless without enforcement.

 

Protect your paper files. Are they kept in a secure filing cabinet? Who has keys? Access to keys? A secure cabinet is not much protection for the files left on your desk overnight or for the week because you’re busy or have given keys to staff for follow-up who keep them in their unlocked desk drawers.

 

Protect your mail. Does it sit in an “Outgoing” box accessible to anyone coming into the leasing office? Is the incoming mail left on an unoccupied desk until you can get to it?

 

Protect you resident payments. How secure is your drop box? How hard is it to reach the payments inside? We get calls from managers who have drop box break-ins. If the manager permitted payments through a drop box, then the loss is on the manager. Why do you think bank night payment drops are so secure? In a drop box break-in situation it is impossible to disprove the claims of the many residents who allege deposit of cash payments into the drop box. Your drop box should have a prominent notice stating that its use is at the risk of the payer.  Protecting the resident’s payments includes protecting the information on any payments that you are returning. For instance, the resident makes a partial payment of rent by check in the drop box. You don’t permit partial payments. How do you return the check? Never post it on his door, even if it is in an envelope. Void the check and return it to him in a letter to protect the privacy of his bank information. Post a copy of the letter in an envelope on his door, so he will know immediately that his payment was refused.

Insist that an information release accompany any rental verification request. Best practice is to confirm with the resident before answering any such requests.