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ITCC / IT Retreat. Data Access Procedure December 10, 2009 Karl F. Lutzen Information Security Officer. Summary of UM System AUP Changes. Electronic information is subject to examination, including (but not limited) to:

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Itcc it retreat

ITCC / IT Retreat

Data Access Procedure

December 10, 2009

Karl F. Lutzen

Information Security Officer


Summary of um system aup changes

Summary of UM System AUP Changes

  • Electronic information is subject to examination, including (but not limited) to:

    • It is necessary to maintain or improve the functioning of University computing resources;

    • There is a suspicion of misconduct under University policies, or suspicion of violation of Federal or State laws;

    • It is necessary to comply with or verify compliance with Federal or State law including e-discovery procedures; or

    • If it will serve a legitimate business need of the University.


Reasons

Reasons

  • AUP needed changes mostly due to

    • E-discovery requirements

    • Situations where information is required for mission continuity – ensuring that mission of the University and department are met


Process required for item 4

Process Required for Item 4

  • All campuses must have a defined process with minimums:

    • All requests must be documented and retained

    • Request must be approved by a minimum set of approvers:

      • If the request affects a faculty member, an approval by a faculty representative.

      • An approval by one of the following University administrators at the Chancellor, Vice Chancellor, Provost or Vice Provost level as follows:

        • Students including student employees –  Student Affairs

        • Staff – Administrative Services or Human Resources

        • Faculty – approval from the Chancellor or Provost or designee

    • Approval by the business unit Chief Information Officer (CIO) or designee


Preservation of data

Preservation of Data

  • There is a clause for preservation of electronically stored information.

    • A general officer or their direct reports in advance of an access request approval may authorize data retention


S t process

S&T Process

  • We have defined a process that includes these as well as additionally:

    • Requires keywords for searches (we do not give direct access to the account)

    • Areas must be defined as to where we search

    • Perform legal checks prior to search:

      • Grievance

      • Pending litigation:

        • UM Legal

        • Student Affairs


S t process cont

S&T Process (cont)

  • Searches are to be conducted by Information Security only.

  • Records are filed with the campus Information Security Officer

  • Information Security Personnel may NOT be one of the authorized signatures if CIO is not available. Another suitable delegate must be identified prior to search


It process preservation

IT Process - Preservation

  • Work in progress

  • Currently:

    • Any such request must be identified as in the request form

    • Data is secured, not analyzed, and if access request does not appear in a reasonable time, data copy will be destroyed.

    • Time needs better definition. Currently held no more than 12 months.


Statistics

Statistics

  • In addition, all campuses must annually disclose statistics on faculty accounts being accessed.

  • Action Items:

    • When should this report occur?

    • Who to send it to?

    • Format?


Faculty representative

Faculty Representative

  • Need to identify:

    • Campus faculty representative

    • Alternate/Delegate for all signers when primary representative is unavailable

  • Must be kept current

    • Need to determine online documentation

      (IT will work on this and report back)


Subsequent searches

Subsequent Searches

  • Currently, it is Information Security’s view that any additional keywords requires a new request be filed and approved prior to the new search.

  • Reason: Could be a “fishing” expedition.

  • This needs more discussion (breakout session)


Learning management data

Learning Management Data

  • Issue:

    • Instructor unavailable to teach current semester

    • Data does reside in Blackboard (or other official LMS IT has access to).

  • What process for providing course data to ensure mission continuity?

  • Should it be the same as regular request or is this published data different?


Breakout session

Breakout Session

  • Annual faculty data access report:

    • When? To Whom? What Format?

  • Faculty representative:

    • Identify primary representative and delegate(s).

  • Subsequent searches:

    • New request form or other?

  • Data Preservation time:

    • How long? <=12 months in current draft

  • Learning Management Data

    • What process for access?


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