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Institutional Encryption Requirements

This document outlines UCLA's encryption requirements, ensuring that data is reasonably encrypted to uphold confidentiality and integrity, even if the encryption key is lost or stolen. It addresses types of sensitive data that must be secured, including public records and research data subject to legal obligations. The guidelines emphasize the importance of availability as a legal requirement and highlight privacy concerns, native encryption methods, and key management practices necessary for securing institutional data while maintaining compliance with applicable laws.

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Institutional Encryption Requirements

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  1. Institutional Encryption Requirements When data is encrypted: It must be reasonably encrypted to ensure confidentiality and integrity It must beavailable even in the event the encryption key is lost, stolen or otherwise unavailable

  2. Confidentiality & Integrity “Standards” for encryption Defining due diligence for UCLA No rot-13!

  3. Availability Types of data of concern Things to consider How to approach

  4. Availability: Of what data? • Records subject to a California Public Records Act request, including emailnot falling under incidental personal use • Administrative book of record data required by applicable law and policy • Transient book of record data, e.g., original data created on a laptop that is book of record until it is transferred to a main database • Data with under a legal obligation, such as: • Non-book of record data (i.e., copies) that the University is under legal obligation to segregate, such as copies of data under a duty to preserve (e-discovery) • Research data subject to a contracts and grants requirement • Data whose unavailability will cause some other institutional impact (e.g., information relevant to a patent dispute)

  5. Availability: Things to consider 1 • Availability is not a new requirement! • It is driven by many legal obligations, including the California Public Records Act that speaks to transparency and accountability of public institutions.

  6. Availability: Things to consider 2 • Privacy and cultural concerns • Intertwining with non-consensual access protocol • Native encryption in applications / databases • Native encryption of laptops • Trend toward ubiquitous native hard disk encryption

  7. Availability: How to approach • Encryption key management

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