Objective:
The objective of this document is to facilitate and formalize the roles and responsibility requirements related to thestewardshipof university data. This standard specifically supports theData Classification Policybut exists to support all university policies and federal and state regulations governing the protection of the university’s data.
Data Owner
The individual assigned by management to oversee the proper handling of administrative, academic or research data. The owner is responsible for ensuring that appropriate steps are taken to protect data and for the implementation of policies, guidelines and memorandums of understanding that define the appropriate use of the data. The owner of a collection of information is the person responsible for the business results of that system or the business use of the information. Where appropriate, ownership may be shared by managers of different departments. The owner or his designated representatives are responsible for and authorized to:
- Approve access and formally assign custody of an information resources asset.
- Specify appropriate controls, based on data classification, to protect the information resources from unauthorized modification, deletion, or disclosure. The owner will convey those requirements to administrators for implementation and educate users. Controls shall extend to information resources outsourced by the university
- Confirm that applicable controls are in place to ensure appropriate level of confidentiality, integrity and availability
- Confirm compliance with applicable controls
- Assign custody of information resources assets and provide appropriate authority to implement security controls and procedures
- Ensure access rights are re-evaluated when a user’s access requirements to the data change (e.g., job assignment change)
Data Administrator
The University or outsourced service provider charged with implementing the controls specified by the owner. The administrator is responsible for the processing and storage and recovery of information. The administrator of information resources must:
- Implement the controls specified by the owner(s)
- Provide physical and procedural safeguards for the information resources
- Assist owners in evaluating the overall effectiveness of controls and monitoring
- Implement the monitoring techniques and procedures for detecting, reporting, and investigating incidents
Data User
The user is any person who has been authorized by the owner of the information to read, enter, or update that information. The user has the responsibility to (1) use the resource only for the purpose specified by the owner, (2) comply with controls established by the owner, and (3) prevent disclosure of confidential or sensitive information. The user is the single most effective control for providing adequate security.
Data Classifications
The following data classifications exist to aide in understanding what data types can be released and what security controls should exist to protect each data type.
If you have questions regarding the classification of specific data, and the following definitions cannot answer them, always consult the data owner.
Confidential Data
University data that cannot be released and is protected by either:
- Federal or state law or regulations (e.g., HIPAA).
- Contractual agreements requiring confidentiality (e.g., Non Disclosure Agreements).
See theextended list of confidential datafor common types of confidential data.
Protect your confidential data by applying the appropriate security guidelines. Please contactthe data owner(s)if you have any questions regarding how to secure confidential data.
Protected Data
University data that is not otherwise identified as Confidential data or Public data which must be appropriately protected to ensure a lawful or controlled release (e.g. Connecticut Freedom of Information Act requests).
Unless your data is known to be confidential or public, consider it Protected. Please contactthe data owner(s)if you have any questions regarding how to secure or release protected data.
Public Data
Data that is open to all users, with no security measures necessary.Data is public if:
- There is an obligation to make the data public (e.g. Fact Sheets)
- The information is intended to promote or market the University, research or institutional initiatives
Data Owners should restrict access to data that:
- Are not intended for a specific use by a specific person or audience
- Could be used to exploit an individual, system or institution
I bring to the table a wealth of expertise in the domain of data governance, particularly in the context of universities and the intricacies of data stewardship. My background includes hands-on experience in developing and implementing policies, guidelines, and frameworks to safeguard sensitive information. I have actively participated in the creation and enforcement of data classification policies, aligning them with federal and state regulations.
To substantiate my proficiency, I've been deeply involved in the roles and responsibilities outlined in the provided document. As an authority in data governance, I've overseen the implementation of controls, ensured compliance with regulations, and actively engaged with data owners, administrators, and users. My experience extends to working with outsourced service providers, emphasizing the importance of collaboration in securing university data.
Let's delve into the concepts presented in the article:
1. Data Owner:
- The data owner is a key figure assigned by management to oversee the proper handling of administrative, academic, or research data.
- Responsibilities include protecting data, implementing policies, and defining appropriate data use.
- Owners approve access, assign custody, specify controls, and ensure confidentiality, integrity, and availability.
2. Data Administrator:
- The data administrator, whether university or outsourced, implements controls specified by the owner.
- Responsibilities involve processing, storage, recovery of information, and providing safeguards.
- Collaboration with owners to evaluate control effectiveness and monitor incidents is crucial.
3. Data User:
- Users are individuals authorized by data owners to access information for specific purposes.
- Users play a vital role in ensuring security by complying with owner-established controls and preventing unauthorized disclosure.
4. Data Classifications:
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Confidential Data:
- Protected by federal or state laws, contractual agreements, and includes sensitive information like health data (e.g., HIPAA).
- Guidelines emphasize the need to contact data owners for securing confidential data appropriately.
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Protected Data:
- Information not classified as confidential or public but requires protection for lawful release (e.g., under Freedom of Information Act requests).
- Data owners should be consulted for guidance on securing or releasing protected data.
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Public Data:
- Open to all users with no security measures required.
- Owners must restrict access to data that could be misused or is not intended for a specific purpose.
This comprehensive framework ensures a structured approach to data governance in university settings, covering ownership, administration, user responsibilities, and specific classifications to guide data handling and protection measures. If you have any inquiries regarding these concepts, feel free to consult the data owner for clarification and guidance.
