Protected & Sensitive Data Á¿×Ó×ÊÔ´
Scope:
This policy covers all computers and electronic devices capable of storing or transmitting electronic data that are owned or leased by Á¿×Ó×ÊÔ´ University Chicago, consultants or agents of Á¿×Ó×ÊÔ´ University Chicago and any parties who are contractually bound to handle data produced by Á¿×Ó×ÊÔ´.
Purpose:
The purpose of this policy is to ensure that Á¿×Ó×ÊÔ´ Protected or Á¿×Ó×ÊÔ´ Sensitive data is not inappropriately stored on Á¿×Ó×ÊÔ´ computers and electronic devices through systematic electronic examination.
Á¿×Ó×ÊÔ´:
Frequency
All departments will perform a Personal Information Security Compliance (PISC) Review at least every 6 months. Departments are free to perform PISC Reviews more frequently if they see a need to do so. All departments must maintain a schedule for performing their PISC Reviews.
Covered Systems
During a PISC Review, departments are responsible for scanning workstations, laptops, portable devices, and any servers that are managed by the department. Portable devices that store electronic data should be attached to a computer during the PISC Review. ITS will perform PISC Reviews for all servers that they manage.
Collection Method & Methodology
Scan results shall be stored on each machine that is scanned. The primary data steward or the alternate data steward in each department will be responsible for examining each scan result to determine if the machine or device houses Á¿×Ó×ÊÔ´ Protected or Á¿×Ó×ÊÔ´ Sensitive data.
Measurement & Reporting
The primary data steward or the alternate data steward in each department will create and send a summary of their scan results to ITS. This summary of scan results will include the number of computers and electronic devices that contain either Á¿×Ó×ÊÔ´ Protected data or Á¿×Ó×ÊÔ´ Sensitive data, and the number that contain neither. Scan results will also include any machines which were believed to not contain Á¿×Ó×ÊÔ´ Protected data or Á¿×Ó×ÊÔ´ Sensitive data but were found to contain either data type. ITS will create and provide a summary report to the Information Technology Executive Steering Committee.
Follow-up & Training
Any users who regularly use a computer or electronic device identified by a scan as inappropriately containing Á¿×Ó×ÊÔ´ Protected data or Á¿×Ó×ÊÔ´ Sensitive data without proper authorization may be required to complete online training on the use and storage of Á¿×Ó×ÊÔ´ Protected data and Á¿×Ó×ÊÔ´ Sensitive data.
Software
ITS will install software that is capable of scanning for Á¿×Ó×ÊÔ´ Protected data and Á¿×Ó×ÊÔ´ Sensitive data on all Á¿×Ó×ÊÔ´ computers and electronic devices subject to this Á¿×Ó×ÊÔ´. Only software approved by ITS to scan for and identify Á¿×Ó×ÊÔ´ Protected data and Á¿×Ó×ÊÔ´ Sensitive data may be used during a PISC review.
Search Terms
The scanning software will search for the patterns that are specified in the Appendix. If additional patterns are identified that need to be identified, they will be added to the Appendix.
Questions about this policy:
If you have questions about this policy, please contact the Information Security team at DataSecurity@luc.edu .
Á¿×Ó×ÊÔ´ adherence:
Failure to follow this policy can result in disciplinary action as provided in the Staff Handbook, Student Worker Employment Guide, and Faculty Handbook. Disciplinary action for not following this policy may include termination, as provided in the applicable handbook or employment guide
Appendix:
Policies referenced
Definitions
Personal Information Security Compliance (PISC) Review – Occurs when a department follows the Personal Information Security Compliance Review Protocol.
Regular expression – A pattern, such as 9 consecutive digits or 3 consecutive digits then 2 consecutive characters. Any item which matches the regular expression will be flagged by the scanning software.
Search Terms
The following regular expressions will be flagged by the scanning software as possible matches for sensitive data:
- SSN9 – 9 consecutive digits
- SSN324 – 3 consecutive digits, a dash, 2 consecutive digits, a dash, and 4 consecutive digits
- AMEX – 4 consecutive digits, a dash, 6 consecutive digits, a dash, and 5 consecutive digits
- VMCD – 4 consecutive digits, a dash, 4 consecutive digits, a dash, 4 consecutive digits, a dash, and 4 consecutive digits
History:
- March 4, 2008: Initial Á¿×Ó×ÊÔ´
- June 19, 2015: Annual Review for PCI Compliance
- June 20, 2016: Annual Review for PCI Compliance
- June 21, 2017: Annual Review for PCI Compliance
- Sep 6, 2018: Annual Review for PCI Compliance
- Sep 24, 2019: Annual Review for PCI Compliance
- Aug 6, 2020: Annual Review for PCI Compliance