Really Right

Note: This charge concerns actions taken on Saturday of the Convention

Aaron and George Park, at the instruction of John Briscoe, conducted the elections for Senate District Directors. Aaron’s was one of ten Vice-Presidents and George was Membership Secretary. Here again were Bylaws violations, procedural violations and a big mess created by the Park brothers.

First, the convention has an Elections Committee for a reason. They should be involved when these elections were conducted, but they were not.

ARTICLE XIII – NOMINATION & ELECTION OF OFFICERS

Section 13.02. Elections Committee. The Elections Committee shall have general charge of the election and the distributing and the counting of the ballots.

Traditionally, the caucus for electing Directors and their Deputies, can be done any time from when ballots are distributed on Saturday until the final gavel of the convention on Sunday. The reason for this is that some delegated don’t arrive at the convention until the business meeting on Sunday morning. This allows the flexibility to have the most people present when the caucus is held. This was short circuited by John Briscoe. Briscoe required all caucus ballots to be turned in less than an hour after they were distributed.

Furthermore, the ballots should be tabulated by members of the Election Committee. These ballots are supposed to be compiled into a report and presented to the Convention. Those districts with three or less members fall under this bylaw provision.

ARTICLE XIII – NOMINATION & ELECTION OF OFFICERS

Section 13.08. Senate District Directors and Deputy Senate District Directors.

(b) If there are fewer than three Delegates from a Senate District present, the Senate District Director and the Deputy Senate District Director shall be appointed by the Board of Directors.

The appointment mentioned in this provision has always been at the Board of Directors meeting immediately following the Annual Convention. At least until this year. John Briscoe also failed to do this.

To compound this mess, only the Park brothers ever saw the ballots. The Elections Committee was not in charge of the ballots.

Even before the ballots were collected at the Convention, stories were circulated of Aaron and others giving conflicting instructions to people trying to vote.

Dallas Thiesen’s characterization fits well with my experience at the Convention.

It was apparent to everyone present that Vice President Park and Membership Secretary Park took control the Senate District Caucuses Saturday General Session of the 2015 CRA Convention. This was improper, the Senate district Caucuses should be administered by the Convention Election Committee, to ensure order and fairness.

However, the Membership Secretary Park and Vice President Park took over the administration of the Senate District Caucuses away from the Election Committee. As direct result the 2015 Senate Caucuses were disorderly, resulted in delegate confusion, and facilitated Vice President Park’s malfeasance described in above.

Furthermore, Membership Secretary Park failed to validate the results of the Caucuses transmit the final results to President Briscoe for reading at the Board of Directors Meeting on Sunday following the close of the convention.

Had the Convention Elections Committee not been improperly stripped of its duty to facility the Senate District Caucuses the process would have been orderly and any discrepancies in the Caucuses would have been discovered and dealt with during the convention, not months later when it benefits Vice President Park and Membership Secretary Park to raise the issue.

Like all the rest of the information that checks into the Park’s possession, it only sees the light of day after it has been massaged and cherry-picked to serve the will of Aaron and George.

The flaws and shortcomings of this sloppy caucus will be fixed at the May 30th Board meeting.

Had Aaron and George spent their time in February and March concentrating on organizing the Convention instead of playing circular firing squad with Credentials and Charter review, most of the problems we are faced with now would never had happened. Again, the records belong to the Board not George and Aaron.

In the current CRA dispute, the only complaint that Aaron raises that appears especially troubling is Santa Clarita member rolls listing a dead person and the couple that—per his blog—“have divorced and moved to Texas”.

I have talked with representatives of the Santa Clarita unit and they assure me that they have investigated each and every name which Aaron has put out publicly. Many outside their unit have implored them to engage publicly on this issue but they are doing their best George W Bush imitation by being silent. Typically, he who frames the issue wins the debate and right now they look rather stupid. Understandably however, they don’t wish this issue to become part of the blog wars which are currently raging so they will only release the information to the Investigative Committee created by the CRA Board of Directors.

This sounds great except for one small detail; George and Aaron won’t talk to the Investigative Committee.

Yes, same problem the rest of the Committee has had for months. George and Aaron refuse to provide the documents which they allege prove fraud. Since George and Aaron fired the first shot by screaming “fraud”, the Investigative Committee decided to let the Park brothers present the case for claims of fraud. Then, any units that have claims made against them will be given the opportunity to present any contrary or mitigating evidence. Then the Committee will look at all the evidence and present their findings to the Board once their report is complete. Translation, the report could never be ready by May 30th and George and Aaron are making certain that it won’t be.

So now that you know where things stand on the Investigative Committee, let’s take a look at this claim of divorce and departure. Is the email that Aaron posted April 17th correct ?

I have a friend that did a little digging on this allegedly divorced couple and this is what was discovered.

• Mr. and Mrs. X are proudly cohabitating in sunny southern California.

• Mr. and Mrs. X are both registered Republicans.

• Mr. and Mrs. X voted in the November 4, 2014 election.

• Mr. and Mrs. X cast their ballot at their polling place, not by mail.

• Furthermore, per the Los Angeles County Assessor’s Office, the property was last sold in 2004.

• Lastly, Mrs. X has “married” as her status on Facebook.

Translation: “Alive and well and living in L.A.”—Michael Omartian 1976

Aaron one of your key proofs of fraud just blew-up in your face.

In the future try tossing the grenade instead of the pin or be more charitable and hold your fire altogether.

The idea of electronic membership records was pushed as part of a modernization effort by George Park once he became CRA Membership Secretary. After the 2011 mess with Peggy Mew, the Board was almost unanimous in supporting this idea.

The record depository was to be a one stop storage site for everything CRA. Each local chapter was to have their own area for membership records, samples of Bylaws, guides for voter registration, candidate training and a host of other resources were supposed to be available. Senate District Directors and Vice-presidents would have more access so they could monitor the activity of clubs in their care. Committees were supposed to be able to communicate with each other and access records necessary for them to conduct their business. The standardized membership spreadsheets created by George were supposed to be an integral part of this data. Access was to be controlled via different user roles defined prior to populating the site with data.

It sounded like a great idea until George built the member database. Then he began to retreat from the goals stated above. He tried to scare people with the idea that electronic records were not really that secure. Some clubs with older members got lost in all the changes or lost confidence in the system we had supposedly adopted.

Look at the bald faced lies spewing forth on Aaron’s blog.

Both Jim and Tim were used by Alice as stooges to help her get her hands on all of the CRA’s records in an unsecured electronic format. The credentials committee kept ramping up their requests for more and more records from George until it hit a flashpoint a couple weeks before the convention.

… the same people that wanted and entire copy of the CRA’s Membership Records in an unsecured electronic format sent to the credentials committee!

Blog Post
Emphasis added

These statements are so stupid that only Apple users or people of my parent’s generation could possibly believe them. George didn’t want to give the records to Credentials so he could prevent them from doing their job. I have extensively demonstrated this elsewhere on my blog.
Blog Post

When the time of truth came for George to do what Peggy Mew had failed to do back in 2011, he failed. The Credentials Committee—which Park has chaired in the past—exists for the express purpose of examining membership records. The records belong to the Board not Mr. Park. Somehow George forgot who he works for.

ARTICLE VIII – BOARD OF DIRECTORS

Section 8.02.

(a) Powers and Limitations of Powers. The Board of Directors shall have the control and management of all CRA affairs, properties, and funds.

Here is much of the complaint filed by Jim Shoemaker. Shoemaker was also on the Credentials Committee.

George has worked very hard at trying to bring our records up to date. I applaud him for this and it was needed. But in his zeal to accomplish this task he has forgotten that we are a volunteer organization and we must be considerate and respectful of each other.

The Membership Secretary has no authority to withhold requested documents, including the complete membership list in electronic form, from any board member and especially Vice Presidents and our Credentials committee.

George has over stepped his authority by nit picking units that have had no history of being out of control or being a problem.

The membership secretary has overstepped his authority in the credentialing process and failed to provide the credentials committee with the necessary documents to perform their duties in determining appropriate delegates to the convention and their ability to provide candidates with the documents they have a right to have in advance of the convention in a timely manner.

Record security is not now nor ever been the issue. Record security means limiting access to authorized individuals. Board members using records in the course of their duties is allowed.

It is record control. Park didn’t want other on the Board to have copies of membership information.  He does believe knowledge is power, his power. That apparently is why he permitted his brother to post portions of it on the internet in an unsecure format for all the world to see less than a month after the convention and mere weeks after the email quoted below.

On March 10, 2015, George Park sent this campaign email to delegates to the CRA Convention. (Please note that the Convention began March 20th.) The bolded portion quoted below was that way in the original.

Protecting the privacy of your units’ membership records – many of you have expressed concern over your rosters being distributed in even a limited manner.

I have listened and have protected your records! I am willing to stake my reelection on protecting the privacy of your personal membership information.

If re-elected – I will continue to safeguard the confidentiality of your records.

Once again, Park violated the CRA Bylaws by withholding membership records from the Credentials Committee. He also violated his pledge to “stake my reelection on protecting the privacy of your personal membership information” while simultaneously violating State and Federal law.

On his blog, Aaron Park has made a multitude of admissions against interest on this subject. For the Parks, the hill that they have chosen to die on is this one. Nevada Republican Assembly cannot be allowed to exist in any form. It must be exterminated. George and Aaron are the Daleks running around the state screaming, “Exterminate”. Thus Tom McClintock (or Barry Pruett) is The Doctor.

Please also note that current CRA President Tom Hudson went nearly psycho when the CRA did not endorse McClintock in 2014. He sent emails to thousands of people and in my opinion, he fought to prop up the Nevada RA for the purpose of making sure the Placer RA could never block a McClintock endorsement again. In so doing, this was the ignition switch for the current state of affairs within CRA. The Nevada RA was the first time where Alice Khosravy, Carl Brickey and Tim Thiesen stopped going after by-law violations.

Blog Post

This quote needs some explanation for the purposes of context.

First, Aaron admits that this is all about Nevada RA, “this was the ignition switch for the current state of affairs within CRA.”

Now let’s talk about the infamous non-endorsement of Congressman McClintock.

Aaron and George Park organized the 2014 CRA Spring Convention held at Knott’s Berry Farm in Anaheim. Per Google Maps, that’s about 429 miles from their homebase in Roseville. To add a little more importance to the convention, Aaron tried to get all the northern California CRA chapters to hold their local endorsing conventions in Anaheim. My chapter, refused to participate in such a crazy idea. Which part of local does Aaron not understand? My club had several email exchanges with him before he took us off the list of participating chapters.

During the local endorsing votes, Tom Hudson handed the gavel to Aaron Park and left to attend to some other convention business. While Hudson was out of the room, Park presided over the vote. Please understand that what Park did next was a deliberate break from the practice of endorsing within CRA. Park started with a motion not to endorse McClintock. A majority voted in favor of the motion and thus Tom McClintock was denied an opportunity to be endorsed.

This slap at McClintock caused much grief for John Briscoe. At the next Board meeting, Briscoe passed a resolution thanking McClintock for being a great conservative leader. I was one of the few folks in the room that voted against the resolution. I thought it undermined the right of local chapters to endorse. It wasn’t until much later that I found that Park effectively pulled his version of the Kobayashi Maru at the endorsing convention.

Nevada RA is clearly a thorn in Park’s side. Does he really believe that the sole purpose of the chapter is “…making sure the Placer RA could never block a McClintock endorsement again”?

Last year, Aaron was singing a very different tune on this endorsement.

Third – I am neutral. The attacks have only hardened my resolve to sit this one out. At a time of my choosing, when it is convenient for me, I may engage on behalf of either one of them, which one it is depends on Tom McClintock. Right now, this is a no-win thanks to the actions of one CRA officer (who I won’t name) who has inflamed this situation causing Steve Frank to get John Briscoe’s email. Our club spoke and the CRA Spoke and the discussion should be on why we did not endorse versus the attacks.

Blog Post

Ok, Aaron are you neutral or wanting to insure you can block a McClintock endorsement? The preponderance of evidence points to the latter.

And now for the bald-faced lie.

The Nevada RA was the first time where Alice Khosravy, Carl Brickey and Tim Thiesen stopped going after by-law violations.

Here again is Aaron projecting his feeling to others. This is a lie, and the greatest mischaracterization of all. This distortion is the cornerstone of all the Park attacks. Charter Review followed the Bylaws. That is their job. They try to fix broken units not euthanize them. These Board members are the focus of Aaron’s vitriol in this situation because Aaron’s side lost the Board vote. And for that we have had a continuous tantrum for five months from George and Aaron.

Let’s go back to the January 2015 Board meeting. Here was my take on this at the time.

Next was the Nevada County RA.

Charter Review wanted to discipline the group since the Jeopardy Letter had not had the desired effect. They have been messing with this group for four years but Nevada RA will not follow the rules everyone else has to follow. The vote Charter Review scheduled was to suspend the group and put them in the care of the regional vice-president; in this instance Aaron Park who was not present at the meeting.

This portion of the meeting was again mishandled, this time by Charter Review Chairman, Tim Thiesen, and CRA President, John Briscoe. First, Thiesen failed to make a cogent case as to why Nevada RA was in trouble to start with. Thiesen did not lay out in a concise format what happened or when. We were given disjointed fragments of information. Had this been done via email with an executive summary and a request to vote, I think it would have been a slamdunk; however, done in real time it was a disaster.

To add to the confusion, a representative from Nevada RA appeared to speak in defense of his unit. A motion was made from the malcontent wing of the CRA to allow this man to speak for five minutes. This motion was made after Thiesen’s disjointed presentation was concluded. The motion was approved and the Nevada RA rep was granted five minutes to speak. In addition three speakers from each side were allowed two minutes each to speak. Briscoe made two critical mistakes at this juncture. First he allowed the three speakers on each side their two minutes speaches to occur first and then allowed the Nevada RA speakers five minutes at the end to wrap this up.

The old axiom of he who frames the issue wins the debate proved true here. Thiesen failed to prove why the chapter was in trouble so the Nevada RA guy muddied up the waters even more. President Briscoe did not defend his Charter Review Committee and declined to vote on the matter. This was the last straw. The vote which required a two-thirds vote could not break fifty percent. The malcontents prevailed again. Nevada RA begged to be given until the March Convention and this was granted. I don’t think the extra time will solve the issue.

Blog Post

Park wrote,

20 CRA Board members voted to suspend the charter of the Nevada RA. Tom Hudson’s arguments managed to get 20 to vote no, causing the motion to fail.

Blog Post

Tim Thiesen may not be Perry Mason, but John Briscoe seemed to do everything in his power to disrupt the presentation against Nevada RA. He ever stopped Tim in mid stride to allow Jim Brulte to speak to the Board and get endorsed for re-election. Tim had no opportunity to present a cogent argument.

Here are the pertinent Bylaw sections:

ARTICLE V – TERMINATION OF CHARTER AND MEMBERSHIP

Section 5.03. Membership. By January 31, the Membership Secretary shall notify each chartered Republican Assembly with fewer than fifteen dues-paying members that its charter is in jeopardy. The Board of Directors shall also be so notified by the Membership Secretary. If the membership has not increased to a minimum of fifteen members within six months after the notice was sent, then the chartered Republican Assembly may have its charter and membership revoked at the next Board meeting.

Section 5.04. Discipline. Any Republican Assembly that fails to conform to these Bylaws may have its charter and membership suspended or revoked, or may be otherwise disciplined, by a two-thirds vote of the Board of Directors. At least thirty days prior to any Board vote on such matter, written notice of the alleged offense and the Board meeting to discuss it shall be provided to the last reported President and Secretary of such Republican Assembly by the Membership Secretary, Recording Secretary, or Corresponding Secretary. Acceptance of a CRA charter constitutes agreement by each Republican Assembly that the state Board of Directors has full authority to discipline any Republican Assembly for violation of these Bylaws, including the power to suspend or revoke its charter. Officers, agents, and members of a Republican Assembly whose charter has been revoked shall turn over all money and property belonging to that Republican Assembly to a duly-authorized representative of the state Board of Directors at a time and place designated by that representative.

What really happened was that since the motion to suspend the chapter failed to get a 2/3 vote, that the Board chose to offer Nevada one last chance to reform prior to the Annual Convention. The convention was scheduled in March (two months later). At this point, the Board could evaluate their response and then Nevada RA could have their charter suspended.

Nevada RA viewed this vote as a wake-up call. They thought the warning letters were just toothless documents sent as retribution for their support of Tom McClintock. In fact, the Nevada President was advised by a previous President to ignore the letters.

Carl Brickey and the others on the Charter Review Committee took the Board instructions seriously and worked to get the Nevada RA back into compliance. Brickey—then a CRA Vice-President—made this issue his personal project. Park had jurisdiction of the Nevada RA but there was so much “bad blood” between the Parks and Nevada that Brickey felt only someone outside this divide could work with Nevada RA.

Prior to the convention, these was a meeting held which again Park mischaracterizes to advance his narrative.

The Nevada RA had a meeting at 8:30AM on a Monday in 2015, 4 days before the CRA Convention in a vain attempt to paper over some by-law violations – at the behest of Alice Khosravy who called Barry to tip him off after then President John Briscoe told her he’d be handling the situation himself. Alice needed the votes from the Nevada RA for the 2015 convention for her plan to take out George.

Blog Post

Alice Khosravy, Carl Brickey and Tim Thiesen were all on Charter Review. Charter Review’s job is to help units in distress to again become units in good standing; not terminate them. Brickey was in attendance at this meeting of Nevada RA just prior to the Convention. He personally verified that all members of the Nevada RA were notified of the meeting and approved of the actions that were taking place. Most chapter members were present at the meeting.

At its conclusion, Brickey was satisfied that Nevada RA had put their two months of grace to good use and had fully complied with the instructions of the Board. This is not to say that Nevada RA was off the hook but any thought of terminating their club at the March 2015 Annual Convention was over.

Clearly, the Parks will settle for nothing less than the eradication of the Nevada chapter. However, if Nevada comes up for another charter suspension vote and survives, then they will be granted de facto immunity from suspension. This possibility is untenable for the Parks. So what do they do? They must first discredit the Charter Review Committee members.

Another lie in Aaron’s narrative is that Alice came to the convention with a “plan to take out George”.  Park has repeated this claim many times. However, Alice had no candidate. I’m sure she wished that she did, but Rick Marshall was not her choice.

Prior to the election of officers, I spent time with Alice and others that Aaron is currently attacking on his blog and was never told not to vote for George nor asked to support Rick Marshall. Yes we grumbled about George and his recent conduct. As a matter of fact, I even told Alice that if she wanted, I would be willing to run against George. She was not interested. At the election, I reluctantly voted for George.

So what does all this have to do with the Bylaws? Clearly, the Parks are unwilling to abide by them when the vote does not go their way. Are we ruled by laws or men? As members of the Board, the Parks must abide by the decisions of the Board. Yes, they can still dissent and express their opinion but they cannot undermine the whole organization in some sort of cosmic temper tantrum. If the Board’s actions are so disharmonious with their views then they should resign.

…to be continued

In his blog, Aaron Park has repeatedly taunted the majority with claims that none of the complaints lodged against he and his brother are violations of the CRA Bylaws.

For example:

“Note – none of Barry Pruett’s allegations, even if true and absent several lies, would constitute a violation of any CRA By-Laws.” 05-03-2015

Concerning the complaint by Mark Gardner, Park writes that the complaint “…lacks a single violation of CRA By-Laws.” 05-05-2015

“Meantime – three complaints in, still no by-law violations.” 05-06-2015

“P.S. There are still no alleged violations of CRA By-Laws …” 05-07-2015

“He (Dallas Thiesen) also accuses George of violating CRA By-Laws that don’t exist…” 05-08-2015

I would like to respectfully disagree with Mr. Park. To that end, I humbly submit the following:

Being a Board member implies a legal, civil and ethical responsibility 
The California Republican Assembly is a corporation registered in the State of California. As such, it is expected that the actions of the corporation, including its Board of Directors, are in accord with both State and Federal law. This corporation has stated that it shall be governed by Robert’s Rules of Order Newly Revised and its Bylaws.

While these statements are reasonable to most folks, those with thicker skulls might need more proof so I would like to suggest at least the following:

All California based corporations are registered with the Secretary of State’s Office.
When a corporation is formed, it agrees to statements such as this: “The purpose of the corporation is to engage in any lawful act or activity…” Corporation filing form from http://www.sos.ca.gov

Furthermore, the CRA is governed by its Bylaws and Robert’s Rules of Order:

  ARTICLE XVIII – PARLIAMENTARY AUTHORITY

  Section 18.01. The most current version of Robert’s Rules of Order, Newly Revised, shall be the parliamentary authority for all matters of procedure not specifically addressed by these Bylaws.

When taken as a whole, I think it fair to say that CRA must abide by both state and federal law, its Bylaws, and Robert’s Rules of Order.

In addition—and I hope I don’t lose my target audience on this—the law and society in general have an expectation that corporations and their governing boards act in an ethical manner and within the rules they have established. Yeah, in essence, there is a moral component to the law. If they only taught Western Civilization in our schools…, but I digress.

So my contention is that CRA is governed by more than just its Bylaws, otherwise why require that our members be of “good moral character” ARTICLE IV – MEMBERSHIP Section 4.05.

The practical effect of this principle is that Board officers whose actions tarnish the image and reputation of the corporation can be removed. Those that violate state and/or federal law can be removed because failure of the board to act will be viewed as condoning the actions taken by the offending board members. Board officers are responsible for their actions and can be held accountable for them by the corporation, and civil authorities. In short, Corporations have a right to self-defense.

  ARTICLE V – TERMINATION OF CHARTER AND MEMBERSHIP

  Section 5.08. Termination and Discipline of Member

  (6) Otherwise violated the CRA Bylaws or brought discredit or disrepute upon the CRA, provided that at least thirty days before such disciplinary action, the member was notified in writing of the alleged offense and the Board hearing. CRA members shall be permitted to address the charges against them prior to the Board vote.

Thus removal of George and Aaron Park from the CRA Board for the violation of Personally Identifiable Information (PII) is well within the rights of the Board. In fact, I think that it is the duty of the Board to do so.

…to be continued

I went on the Internet and did a quick check. The data breach is actually worse than first reported.

This is what I found from the General Services Administration, a Federal Agency

Here are their definitions:
Personally Identifiable Information (PII) – information about a person that contains some unique identifier, including but not limited to name or Social Security Number, from which the identity of the person can be determined. OMB Memorandum M-10-23 (June 25, 2010), updated the term “PII”: “The definition of PII is not anchored to any single category of information or technology. Rather, it requires a case-by-case assessment of the specific risk that an individual can be identified. In performing this assessment, it is important for an agency to recognize that non-PII can become PII whenever additional information is made publicly available — in any medium and from any source — that, when combined with other available information, could be used to identify an individual.”

Data Breach – Includes the loss of control, compromise, unauthorized disclosure, unauthorized acquisition, unauthorized access, or any similar term referring to situations where persons other than authorized users with an authorized purpose have access or potential access to Personally Identifiable Information, whether physical or electronic. In the case of this policy, the term “breach” and “incident” mean the same.

The following list contains examples of information that may be considered PII.
• Name, such as full name, maiden name, mother‘s maiden name, or alias
• Personal identification number, such as social security number (SSN), passport number, driver‘s license number, taxpayer identification number, patient identification number, and financial account or credit card number
• Address information, such as street address or email address
• Asset information, such as Internet Protocol (IP) or Media Access Control (MAC) address or other host-specific persistent static identifier that consistently links to a particular person or small, well-defined group of people
• Telephone numbers, including mobile, business, and personal numbers
• Personal characteristics, including photographic image (especially of face or other distinguishing characteristic), x-rays, fingerprints, or other biometric image or template data (e.g., retina scan, voice signature, facial geometry)
• Information identifying personally owned property, such as vehicle registration number or title number and related information
• Information about an individual that is linked or linkable to one of the above (e.g., date of birth, place of birth, race, religion, weight, activities, geographical indicators, employment information, medical information, education information, financial information).
Guide to Protection the Confidentiality of PII

Organizations should develop an incident response plan to handle breaches involving PII.
Breaches involving PII are hazardous to both individuals and organizations. Harm to individuals and organizations can be contained and minimized through the development of effective incident response plans for breaches involving PII. Organizations should develop plans that include elements such as determining when and how individuals should be notified, how a breach should be reported, and whether to provide remedial services, such as credit monitoring, to affected individuals.
Guide to Protection the Confidentiality of PII

PII is in two types

Linked
Linked information is information about or related to an individual that is logically associated with other information about the individual.

Linkable
Linkable information is information about or related to an individual for which there is a possibility of logical association with other information about the individual.

For example, if two databases contain different PII elements, then someone with access to both databases may be able to link the information from the two databases and identify individuals, as well as access additional information about or relating to the individuals. If the secondary information source is present on the same system or a closely-related system and does not have security controls that effectively segregate the information sources, then the data is considered linked. If the secondary information source is maintained more remotely, such as in an unrelated system within the organization, available in public records, or otherwise readily obtainable (e.g., internet search engine), then the data is considered linkable.
Guide to Protection the Confidentiality of PII

The same document quoted above goes on to state, “Federal agencies are required to report all known or suspected breaches involving PII, in any format, to US-CERT within one hour. To meet this obligation, organizations should proactively plan their breach notification response. A breach involving PII may require notification to persons external to the organization, such as law enforcement, financial institutions, affected individuals, the media, and the public.”

CRA on the other hand thinks it is exempt from reporting any release of PII.

The PII article on Wikipedia.org is interesting; especially footnote #19. ”In 2011, the California State Supreme Court ruled that a person’s ZIP code is PII”
Wikipedia Personally Identifiable Information

Under this ruling, not only was the disclosure of bank routing and account numbers a disclosure of PII but also all the member spreadsheets and membership forms that were scanned and posted on the Internet.

Based on the above, the Park brothers appear to have a serious problem.