University of Connecticut ePolicy Policy Page

Policy on Roles and Responsibilities with Respect to University Data

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. As an asset, 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 establish the levels of responsibilities for the control, protection and release of University Data within the framework of the University's general organizational structure.

Expected Institutional Outcome: It is expected that this policy will improve the University community's understanding of the responsibilities delegated to various entities in the control, protection and release of University Data and help ensure that the University complies with Federal and State laws and regulations regarding the use and security of University Data while improving the appropriate access to University Data.

Definitions:

University Data: Items of information that are collected, maintained, and utilized by the University for the purpose of carrying out institutional business subject to or limited by any overriding 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 all users of University Data.

Policy Statement: The University itself is the owner of all University Data. In order to fulfill its responsibility for University Data and guard its proper usage, the President delegates responsibility to various University personnel for the purpose of managing and protecting the data.

Roles and Responsibilities as Delegated by the President:

The President and/or his designee(s): The entity/entities or office/offices with primary accountability for the collection, accuracy and security of data as the University's official record, ensuring that appropriate policies and compliance mechanisms are in place to meet legal, regulatory and University policy requirements.

Regulator: The entity/entities or office/offices that has delegated or statutory responsibility for defining data values, definitions, requirements, security, confidentiality and access. These may be internal as delegated by the Laws, Bylaws and Rules of the Board of Trustees or by the President and/or his designee(s), or external as mandated by statute, regulation or contract, etc. For example, the U.S. Department of Health and Human Services is the Regulator for personal health information, the U.S. Department of Education is the Regulator for information protected under FERPA, and the University Senate is the Regulator for course requirements for general education of all undergraduate schools and colleges.

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.

Defines the administrative data sets and develops policies for the management, security and access of those data sets based on the requirements proscribed by the Regulator or to carry out the goals and/or business decisions of the University.
Defines the requirements for safeguarding the confidentiality, integrity, and availability of data.
Ensures that security policies are implemented consistently across the University.
Handles requests for exceptions to policies.
Delegates operational responsibilities for data to appropriate personnel within their scope of responsibilities.
Ensures that responsibilities delegated to technical administrators, third-party vendors, or other custodians are met as specified by the Data Steward.

Council of Data Stewards: The Data Stewards, as a group, are responsible for recommending policies, and establishing procedures and guidelines for university-wide management of University Data and for ensuring consistency of policies, procedures and guidelines across all areas.

Data Custodian: The entity/entities or office/offices that is delegated with the day-to-day operational-level responsibility of performing management functions for a defined portion of University Data (i.e. specific administrative data sets) based on the definitions, procedures and guidelines developed by the Data Steward.

Oversees the capture and maintenance of and access to the data.
Responsible for the accuracy and consistency of the data collected.
Provides a secure and stable environment for the storage of the data relevant to its criticality and confidentiality.

Data User: An individual who is eligible/authorized to submit (input) and /or access University Data in the performance of assigned duties.

Responsible for determining the appropriate data values to be submitted (input) into University Data records, consistent with applicable data and institutional definitions and policies.
Responsible for using data and access to data only as required in the performance of legitimate University functions.
Responsible for adhering to applicable Federal and State laws and University policies and procedures concerning the storage, retention, use, release, transportation and destruction of data.

Data Administrator: The entity or office that is delegated with the responsibility of applying formal guidelines, tools, data definition documentation and record keeping on assigned data responsibilities to manage the University Data.

Deans, directors and department heads may function at various times and for different subsets of University Data in any of the roles defined (Data Steward, Data Custodian, Data Administrator, Data User). In addition, Data Stewards may delegate to deans, directors, department heads and/or other supervisors the responsibility for managing and protecting University Data assigned to their care. In this role, these administrators are responsible for:

ensuring that people who work within their departments are complying with all applicable policies, procedures, and guidelines for safeguarding the security of data and computing resources as defined by the Data Stewards;
ensuring that individuals to whom they give access to data that has been delegated to their care are conforming to all applicable policies, procedures, and guidelines for safeguarding the security of data and computing resources as defined by the Data Stewards;
ensuring that they maintain primary responsibility for such data even when that data and/or computing resources are physically located or assigned to University and/or 3^rd-party entities external to the administrator's department.

Enforcement and Review:

The President, and/or his designee(s), has overall responsibility for implementation and enforcement of this policy.

Review of this policy by the President and/or his designee(s) will occur on a bi-annual basis. Delegation of responsibilities will be reviewed on an annual basis.

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, applicable collective bargaining agreements, and the University of Connecticut Student Conduct Code.

Last updated: August 2008