Data Classification and Usage Policy
Approved by the IT Governance Committee 12/13/2016
Information technology and data constitute valuable Saint Peter’s University assets. In order to protect the security, confidentiality and integrity of Saint Peter’s University data from unauthorized access, modification, disclosure, transmission or destruction, as well as to comply with applicable state and federal laws and regulations, all Saint Peter’s University data are now classified within security levels, with regulations on the usage of data at different levels.
The policy applies to all employees, student employees and contractors that access Saint Peter’s University information.
The following definitions and rules for usage delineate types of data and provide instructions for usage of that data.
Level 1: Highly Confidential, Requires Notification: This includes data that is highly confidential and requires notification to subjects and various state and federal entities if breached. Level 1 data includes: A person’s first and last name, or first initial and last name in combination with any one or more of the following data elements relating to that person:
- Social Security Number;
- Driver’s License Number or state-issued identification card number, including passports and visa numbers;
- Financial account number (bank, investment, 403B), or credit or debit card number;
- Health care information, including patient billing or medical records, information about physical or psychological state of health, counseling records, disease, medical history, medical treatment, drugs, therapies, genetic test results, family health or morbidity history;
- Biometric data including fingerprints, voice prints, retina image, iris image, or other unique physical representation, with the exception of the fingerprints associated with individual fingerprint readers used for securing laptop or desktop computers.
- Information security data, including passwords, and other data associated with security-related incidents occurring at the University.
Rules for Usage of Level 1 Data:
Highly confidential data shall be stored on institutionally supported applications . Level 1 data can also reside in approved third party hosted applications, but those applications must be approved by the CFO and CIO. Hard copy data shall be stored in locked receptacles and rooms. Access to this electronic data shall only be gained through authenticated access on the Saint Peter’s University network or approved VPN access. Hard copy data shall only be accessed when business requires such use and all storage receptacles and rooms shall be appropriately designed to allow for authorized access only.
To this end, employees shall not store or copy this data to laptop or desktop computers (whether institutionally-owned or personally owned), smart phones, USB devices or other portable media. In addition, this data shall not be transmitted via e-mail, instant message, chat or other social media technologies, with the exception of approved third party vendors with appropriate encryption in place. If data is transmitted on a recurring basis to external vendors, it shall be sent via a secure transmission, such as secure FTP (SFTP).
Electronic and hardcopy data shall be destroyed in accordance with Saint Peter’s University’s Data Retention and Destruction Policy, and shall be rendered unreadable in paper or electronic form. All departments shall have policies in place and periodically review electronic storage areas and their hard copy storage areas to insure that data is being destroyed in a timely and effective manner.
Level 2: Confidential: This includes data protected by state or federal law, contractual agreements and proprietary information against unauthorized use, disclosure, modification and destruction. Confidential data includes, without limitation, the following:
- Student records, including date of birth, place of birth, mother’s maiden name, official grades recorded on a student’s permanent record, academic information, race, judicial information and other information relative to a student’s permanent record (i.e. official grades, judicial records, etc.).
- Human Resources data including employment records, salary, benefits, personnel evaluations, date of birth, place of birth, mother’s maiden name, race and other records pertaining to personnel files (i.e. payroll reports, yearly merit increase data, etc.).
- Academic Affairs information relating to non-public research and promotion and tenure files (i.e. notes relating to tenure decisions).
- Alumni or donor information, including date of birth, place of birth, mother’s maiden name, donation amount and assets (i.e. Daily Giving Reports, Donor Profiles, etc.).
- Corporate records including Board of Trustee minutes, Board of Trustee votes and other confidential information dispersed at Board meetings and/or shared with Board members.
- Sensitive Personal Information including credit checks, criminal background checks, visa numbers, sexual behavior and criminal convictions (i.e. CORI/SORI reports).
- Research data involving human subjects that are subject to the Common Rule (Federal Policy for the Protection of Human Subjects, 46 CFR 101 et seq).
Rules for Usage of Level 2 Data:
Confidential data shall be stored in institutionally supported applications, institutionally supported shared drives, or approved third party hosted applications. Third Party hosted applications that store Level 2 data must meet Saint Peter’s University’s Third Party Assurance standard. Confidential data can be stored on University-owned laptop or desktop computers, but shall not be copied to non-University computers, USB devices or other portable media. Hard copy data shall be maintained in as few receptacles and rooms as business dictates. Copies of this data shall not generally be made unless business requires it.
To this end, employees are permitted to store data on institutionally-owned laptop or desktop computers and shared drives; however, the dissemination of this data shall be done securely. Data shall not be transferred via e-mail unless encrypted. If data is transmitted on a recurring basis to external vendors, it is preferable to send this data through secure transmissions such as secure FTP (SFTP).
Electronic data shall be destroyed in accordance with Saint Peter’s University’s Data Retention Policy, and shall be rendered unreadable in paper or electronic form. All departments shall have policies in place and periodically review electronic storage areas and their hard copy storage areas to insure that data is being destroyed in a timely and effective manner.
Level 3: Internal Use Only: This includes information that requires protection from unauthorized use, disclosure, modification, or destruction, but is not subject to any of the items listed in the Level 1 or 2 definitions above. Internal Use Only data includes:
- Data related to Saint Peter’s University operations, finances, legal matters, audits, or other activities that are not public in nature, but not classified as Level 1 or 2.
- Faculty grade worksheets (i.e. Excel files used to track student grading prior to submitting to the Registrar’s Office, Blackboard grades. comments, paper markups, submissions, postings.)
- Personal white page, business white page or professional employment information for students, alumni or donors. This includes name, business name, business address, home address, e-mail, cell phone numbers, business phone numbers, home phone numbers, occupations and titles, but not classified as Level 1 or 2.
- Personal white page information for faculty and staff. This includes home address, cell phone, home phone, home fax and personal e-mail, but not classified as Level 1 or 2.
- Personal characteristics such as gender, height, weight, marital status, nationality, personal interests, photographs and names of children and other demographic information that is not classified as Level 1 or 2.
- Saint Peter’s University Network Diagrams which display IP Addresses.
- Internal Saint Peter’s University data, the distribution of which is limited by intention of the author, owner, or administrator, but not classified as Level 1 or 2.
Rules for Usage of Level 3 Data:
Internal Use data can be stored in institutionally supported applications located in the Saint Peter’s University Server Rooms, institutionally supported shared drives, third party hosted applications and laptop or desktop computers (both Saint Peter’s University issued and personally owned). This data can be copied to smartphones, USB devices or other portable media. Hard copy data shall be maintained in as few receptacles and rooms as business dictates. Copies of this data shall not generally be made unless business requires it.
To this end, employees are permitted to transmit this data via unencrypted e-mail. Electronic data can be destroyed using traditional application delete functionality. Hard copy information can be destroyed in accordance with an employee’s personal or departmental policy.
Level 4: Unrestricted: This includes data that can be disclosed to any individual or entity inside or outside of Saint Peter’s University. Security measures may or may not be needed to control the dissemination of this type of data. Level 4 data includes:
- Content and images on Saint Peter’s University’s public web sites (i.e. www.saintpeters.edu)
- Publically released press statements
- Course catalog
- Business White Page information for faculty and staff, unless otherwise restricted. This includes name, title, department, office location, office phone and Saint Peter’s University e-mail.
Rules for Usage of Level 4 Data:
All information, whether in paper or electronic form, can reside in the public domain and is available to all students, faculty and staff; but, it is subject to Saint Peter’s University’s Acceptable Usage Policy and federal copyright laws.
If there are any documented processes related to this policy, links to the process documentation should be listed here.
As described in Saint Peter’s University’s Acceptable Usage Policy, anyone found to have violated this policy may be subject to disciplinary action, up to and including immediate termination.