October 30, 2006
Topic: Topic
Given the latest Pentagon problems with data, employers should heed certain privacy requirements. Employers can take the following steps to limit unlawful disclosure of private employee data:
In addition to legislatively imposed confidentiality requirements, employers also have court imposed obligations not to invade their employees' privacy. Most states recognize common law invasion of privacy tort claims. Iowa recognizes the following four theories of invasion of privacy: "Intrusion upon plaintiff's seclusion or solitude, or into his private affairs[;] [p]ublic disclosure of embarrassing facts about the plaintiff[;] [p]ublicity which places plaintiff in a false light in the public eye[; and] [a]ppropriation, for defendant's advantage, of the plaintiff's name or likeness." Yoder v. Smith, 253 Iowa 505, 112 N.W.2d 862, 863-64 (Iowa 1962) (quoting PROSSER, LAW OF TORT 637-39 (2d ed.1955)).
In the context of employee data, such claims historically have fallen under one of two theories: "publication of private facts" (unreasonable publicity given to a person's private life in a manner that is highly offensive to a reasonable person and involving a disclosure or subject that is not of legitimate public concern) or "misappropriation" (misappropriating the name or likeness of another for one's own benefit, such as using an employee's photograph without the employee's permission). Plaintiff employees frequently prevail on invasion of privacy lawsuits where their employers have inappropriately disclosed medical information to others. Oftentimes, the outcome in such cases will depend upon whether the publication was made to more than just a single person or a small group of persons. However, an exception to this rule was created in a case handled by LaMarca & Landry P.C., in Peggy A. Hill v. MCI Worldcom Communications Inc., 141 F.Supp.2d 1205 (S.D. Iowa 2001), No. 4-00-CV-70496, "… under Iowa law disclosure of private facts about a plaintiff to a third party may state a claim for invasion of privacy under the theory of public disclosure of embarrassing facts if there is a confidential relationship between the plaintiff and the third party." Id. at 1213.
Increasingly, privacy has become a hot button issue. Employers must recognize the importance of focusing on the need for a thorough and consistent approach to protection of customer, personnel, and benefit data as a risk management and compliance matter, as well as a public relations issue. As employers focus on confidentiality and privacy both internally and externally, all parts of the organization should be called to demonstrate what they are doing to protect private information.
October 30, 2006
What Employers Should Do to Insure Privacy of Employee Data.
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