Physical Access Control for Computing Resources and Equipment

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 controls needed to limit physical access to computing resources to only those people who are authorized to use the resources.

Expected Institutional Outcome: This policy will improve the University's ability to protect its computing resources and data from intrusion, theft, or damage that may result from unauthorized physical access to those resources.

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 unauthorized disclosure, interrupted availability, or damage.

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.

Policy Statement: Each impacted department within the University will implement controls that limit physical access to University-owned information technology resources (including the facility, equipment, software and data) under its control.  These controls will be consistent with the sensitivity and criticality of the resources as described in the Policy on Data Classification.  At a minimum, these controls will include:

1. Physical Safeguards. Safeguards to limit physical access to computing equipment and sensitive electronic data to only the individuals that are authorized to use or handle the resources.  This may include restricting access to individual computing devices or to the areas where they are kept. 
2. Control and Validation Procedure:  Procedures that limit the access to computing equipment and sensitive data to those people who are properly authorized to use the data or to complete testing or maintenance activities for computing equipment, programs, or data stores. 
3. Maintenance Documentation:  Documentation of the maintenance history for computing resources that support storage, presentation, or transmission of data. 
4. Emergency Access to Data: Procedures for providing authorized individuals with access to computing equipment and data during emergency situations.   

Responsibilities: University officials with delegated responsibilities for University 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 the access control processes for those resources to the system administrators who they may appoint to manage the processes 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, applicable collective bargaining agreements, and the University of Connecticut Student Conduct Code.

Policy Implementation Guidelines: Departments required to implement these security management 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: November 18, 2008