Bloomberg Law Analysis

ANALYSIS: Washington Privacy Law Mends Loophole for Common PIN

March 25, 2020, 9:25 AM

Washington state failed to pass comprehensive privacy protections earlier this month, but it has stitched a few words to an existing law to address a commonly used (but often overlooked) PIN—the last four digits of a Social Security number.

SB 6187, signed by Gov. Jay Inslee on Mar. 18, amends the definition of personal information found in Wash. Rev. Code § 42.56.590, which is the breach notification statute applicable to government agencies. The amendment specifies that the last four digits of an individual’s Social Security number (SSN) may constitute a “data element” that—when combined with an individual’s name—would...

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