Protocol For Receiving and Investigating
Complaints under the Identifying Information Law
- CB2M has created the email mailbox [email protected], which mailbox shall be used exclusively for the receipt of and response to complaints by any person under the Identifying Information Law (Administrative Code Sections 23-1201 through 23-1205) (referred to as the “IIL”) (referred to here as the “Complaint Mailbox”).
- CB2M has also created an online form (available here) which also shall be used exclusively for the receipt of and response to complaints by any person under the IIL (referred to here as the “Complaint Form”).
- CB2M designates the Agency Privacy Officer (“APO”) as the point of contact for receiving and investigating complaints under the IIL.
- The APO or the APO’s designee will monitor the Complaint Mailbox and the Folder for Complaint Forms at least once per day each day that the District Office is open.
- CB2M has created a link on the CB2M website home page that will connect to the Complaint Form, which form will contain substantially the same information as set forth below. The form will include a feature that provides instructions on how to submit the form to the APO using the Complaint Mailbox.
- The APO shall promptly:
- Acknowledge to the complaining person receipt of each Complaint;
- Collect from the complaining person all information reasonably necessary for the APO to understand and investigate the Complaint, such as:
- the complaining person’s contact information,
- the date the complaining person became aware of the circumstances on which the Complaint is based,
- a description of those circumstances,
- and any supporting documentation the complaining person wishes to provide;
- Notify the Manhattan Borough President’s General Counsel of the receipt of each Complaint;
- Notify the Chief Privacy Officer of each Complaint within 24 hours of the discovery of each Complaint;
- Investigate the allegations of each Complaint, including working with the MBPO General Counsel and the other City Offices recommended by the MBPO General Counsel, including without limitation the Law Department, Cyber Command, the Office of Technology & Innovation, the CB2M Staff, and other resources reasonably available to the APO, in connection with the investigation of such Complaint and, as appropriate, in formulating a response to the Complaint; and
- Respond to the complaining party with the results of the investigation.
Sample Agency Identifying Information Complaint Form
If you believe that Community Board 2 Manhattan (“CB2M”) or one of its contractors has collected, retained, or disclosed personal identifying information in violation of the Identifying Information Law (Administrative Code Sections 23-1201 through 23-1205) (referred to as the “IIL”), you may either
- Filling in the Complaint Form using THIS LINK and then clicking “submit,” or
- Writing an email that contains as much of the information specified below as possible and submitting it to the dedicated Complaint Mailbox address, which is: [email protected]
Please provide as much of the following information as possible. The information you provide will be used to investigate your Complaint and for no other purpose.
The information we need to investigate your Complaint includes the following:
- Your Name
- Your Email Address
- Your Phone Number
- The date you learned that CB2M collected, retained or disclosed your personally identifying information in a way that you believe violated the IIL. If you are not sure, please provide your best estimate of the month and year.
- Description of the circumstances – please provide as detailed a description as you can of the personally identifying information that you believe was collected, retained or disclosed in violation of the IIL, including all surrounding circumstances, including why you believe it violated the IIL.
Each Complaint will be received and investigated by the CB2M Agency Privacy Officer. In order to investigate and response to your Complaint, the Agency Privacy Officer will need to share your Complaint, including the information you provide, with other City Agencies.Filing a complaint about CB2’s collection or disclosure of your personally identifying information
Thank you for bringing your Complaint to CB2M’s attention.