Electronic Data Integrity

Background and Reasons for the Policy: The University of Connecticut views University Data, in all its forms and throughout its life cycle, as an asset of the University. University Data must be protected to comply with the policies of the University and to meet requirements of Federal and State laws such as the:

• Family Rights and Privacy Act (FERPA)
• Health Insurance Portability and Accountability Act (HIPAA)
• Electronic Communications Privacy Act (ECPA)
• Gramm-Leach-Bliley Act (GLBA)
• Children's Online Privacy Protection Act (COPPA)
• Freedom of Information Action (FOIA)
• Connecticut Personal Data Act

Purpose of Policy: The purpose of this policy is to ensure that the University has implemented the safeguards needed to protect the integrity of electronic data that is accessed, stored, or transmitted using computing resources at the University.

Expected Institutional Outcome: This policy will improve the University community's ability to provide adequate protection for electronic data stored, used, or transmitted using the University's computing resources.

Definitions:

Data Steward: The entity/entities or office/offices that are delegated by the President and/or his designee(s) with the policy-level responsibility for establishing definitions of the data assigned to him/her (i.e. defined portions of University Data) and developing general procedures and guidelines for the management, security and access to those data sets, as appropriate.

University Data: Items of information that are collected, maintained, and utilized by the University for the purpose of carrying out institutional business subject to contractual or statutory regulations. University Data may be stored either electronically or on paper and may be of many forms (including but not limited to: text, graphics, images, sound, or video). Research data, scholarly work of faculty or students, and intellectual property that do not contain personally identifiable information or other data protected by law or University policy are not covered by this policy.

Applicability of Policy: This policy applies to any department within the University that stores, uses, or transmits University Data or electronic data that is subject to State or Federal regulations that require security protections for data covered by those regulations.  The policy is also recommended for all departments that have other data that should be protected from interrupted availability or damage.

Policy Statement: Each impacted department within the University will protect any data that may be electronically used, stored or transmitted using information technology resources (including the facility, equipment, software and data) that are under its control from unauthorized alteration or destruction. 

1. Integrity Controls. Each Data Steward will develop and implement process(es) that protect data under its management from unauthorized access or modification.  These protections include the use of mechanisms or tools that can be used to corroborate that data has not been altered or destroyed in an unauthorized manner.  Each department will adhere to the integrity controls.
2. Encryption: Each Data Steward will implement UITS-approved process(es) that support encryption of non-public data under its management when encryption is an appropriate protection for the data.  Each department will use the encryption process(es) when needed.   

Responsibilities:
University officials with delegated responsibilities for data as defined in the Policy on Roles and Responsibilities with Respect to University Data are responsible for the security of the information technology resources (including the facility, equipment, software and data) that are within their control and/or protection.  They are also responsible for ensuring that they remain knowledgeable about regulatory and University security requirements impacting their data.  They may delegate this security responsibility to administrators who they may appoint to manage data for them.

Departments and units must adhere to the Responsibilities of Individual Departments and Units policy when developing required processes.  The University's security policies set a minimum level of protection for information technology resources.  The processes and technologies instituted by departments must achieve that level of protection.  They may provide additional protections as needed when stricter requirements apply to the departments or operating units.  When designing or implementing security policies, procedures, or technical solutions that respond to unique departmental needs, the departments should ensure that they are in compliance with the Physical Network Access policy.

Enforcement and Review:
The Chief Information Officer has overall responsibility for this policy.

The Chief Information Officer will review this policy on a bi-annual basis and respond to formal complaints resulting from the implementation of this policy.

Any individual who suspects a violation of this policy may report it to the Compliance Office in the Office of Audit, Compliance and Ethics at (860) 486-4526, or anonymously through the Reportline (https://www.compliance-helpline.com/uconncares.jsp). Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and Bylaws, General Rules of Conduct for All University Employees, and applicable collective bargaining agreements.

Policy Implementation Guidelines: Departments required to implement these processes should also refer to http://itpolicy.uconn.edu/, where UITS maintains a set of documents for policies, procedures, guidelines, and standards that provide additional detail.

Last updated: August 2008