records by federal agencies. One of the primary focuses of the Health Insurance Portability and Accountability Act (HIPAA), is to protect a patient's Protected Health Information (PHI), which is similar to PII. The U.S. Senate proposed the Privacy Act of 2005, which attempted to strictly limit the display, purchase, or sale of PII without the person's consent. Similarly, the (proposed) Anti-Phishing Act of 2005 attempted to prevent the acquiring of PII through phishing. U.S. lawmakers have paid special attention to the social security number because it can be easily used to commit identity theft. The (proposed) Social Security Number Protection Act of 2005 and (proposed) Identity Theft Prevention Act of 2005 each sought to limit the distribution of an individual's social security number. Additional U.S. specific personally identifiable information includes, but is not limited to, I-94 Records, Medicaid ID Numbers, Internal Revenue Services (I.R.S.) documentation. Exclusivity of personally identifiable information affiliated with the U.S. highlights national data security concerns and the influence of personally identifiable information in U.S. federal data management systems. State laws and significant court rulings California The California state constitution declares privacy an inalienable right in Article 1, Section 1. California Online Privacy Protection Act (OPPA) of 2003 SB 1386 requires organizations to notify individuals when PII (in combination with one or more additional, specific data elements) is known or believed to be acquired by an unauthorized person. In 2011, the California State Supreme Court ruled that a person's ZIP code is PII. Nevada Nevada Revised Statutes 603A-Security of Personal Information Massachusetts 201 CMR 17.00: Standards for The Protection of Personal Information of Residents of the Commonwealth In 2013, the Massachusetts Supreme Court ruled that ZIP codes are PII. Federal law Title 18 of the United States Code, section 1028d(7) The Privacy Act of 1974, codified at 5 U.S.C. § 552a et seq. US "Privacy Shield" Rules (EU Harmonisation) NIST definition The National Institute of Standards and Technology (NIST) is a physical sciences laboratory, and a non-regulatory agency of the United States Department of Commerce. Its mission is to promote innovation and industrial competitiveness. The following data, often used for the express purpose of distinguishing individual identity, clearly classify as personally identifiable information under the definition used by the NIST (described in detail below): National identification number (e.g., Social Security number in the U.S.) Bank account numbers Passport number Driver's license number Debit/Credit card numbers The following