Not all data theft is high-tech. PLS Financial Services, PLS Group and the Payday Loan Store of Illinois in November 2012 settled a Federal Trade Commission (FTC) case alleging the company disposed of documents containing consumer personal information, including names, Social Security numbers, and wage and bank account information, in trash containers near several locations of the payday loan and check-cashing operation. The trash containers were unsecured and accessible to the public.

Although the FTC did not claim the information had fallen into the wrong hands, such disposal practices violate federal rules protecting consumer information against trash-diving identity thieves.

“The FTC relied primarily upon the Gramm-Leach-Bliley Act's Safeguards and Privacy Rules and the FTC Disposal Rule, but also invoked the FTC Act generally, and other federal laws in the PLS case,” says Michael Pennington, a partner at Bradley Arant Boult Cummings.