The University of Memphis
Data Security Policy
In the course of its operations, the University of Memphis collects
and maintains restricted data about students, employees, donors,
vendors, and others. This policy governs the use, control,
and access to restricted data defined by statute, regulation,
contract, license, or definitions within this policy.
Classification document differentiates the types of University
The Chief Information Officer (CIO) is responsible for implementing
appropriate data security policies, procedures, and technology
standards (i.e. hardware and software) for the University.
Department heads, in cooperation with Local Support Providers and ITS, are responsible for ensuring their employees have adequate technical support to understand and implement security standards and procedures. This responsibility extends to data regardless of the storage medium or originating point of access including, but not limited to, University-owned equipment, personally-owned equipment, and cloud-based services. Each unit of the University instructs employees about the designated and storage space for saved University data. In the event of an audit, each unit of the University would be responsible for providing the location of the unit's designated and approved storage.
Employees, in cooperation with their LSP, are responsible for protecting restricted University data to which they have access. In areas not supported by a LSP, ITS will provide assistance to employees.
Employees are responsible for ensuring that appropriate security
controls, in accordance with published University standards, are in
place to protect restricted University data. This responsibility
extends to data regardless of storage media or originating point of
access including, but not limited to, University-owned equipment,
personally-owned equipment, and cloud-based services.
Personal passwords are established and secured by employees. In accordance with UM1535 Acceptable Use of Information Technology Resources policy, passwords are not to be disclosed or shared.
The ITS Security web page should be reviewed at the beginning of each academic semester by all users.
| ||The University of Memphis is committed to maintaining the confidentiality of all restricted University data. The purpose of this policy is to establish classifications for University data and a framework to preserve the integrity of all University data, regardless of the hardware, systems, etc. where the data may reside or from which it is accessed.|
A vendor-provided service including, but not limited to, storage, analytics, business intelligence, reporting, or other processing, that is not typically located within the University's physical premises.
|Data Steward||University officials and agents of the University who have designated duties for collection, input, and maintenance responsibilities for data within their functional area.|
|Enterprise Information System||
Any centralized data storage or distribution system on campus. Enterprise Information Systems are managed by ITS.
|Internal/Limited Access University Data||Data that would not expose the University to loss if disclosed, but should be protected. Internal/Limited access University data includes, but is not limited to, operational data likely to be distributed across organizational units within the University.|
|Network||Any number of computers and portable devices joined together by a physical or wireless communications link that allows information to be passed between computers, irrespective of where those computers are located. Networks provide the pathways for information traffic and allow employees to access databases and share applications residing on servers.|
|Personally Identifiable Information (PII)||Data that can be used to uniquely identify an individual.|
|Portable Devices or Media||
Portable devices include laptops, Personal Digital Assistants (PDA), cell phones, tablets, or any other portable technology hardware. Media includes technology storage mediums such as CDs, DVDs, magnetic tapes, floppy disks, external hard drives, flash drives, and universal serial bus (USB) drives, or any other portable storage media.
|Public University Data||Data available within the University community and to the general public.|
|Restricted University Data||Data protected by federal or state law or regulations, or by contract. Restricted University data includes, but is not limited to, data that is protected by the Family Educational Rights and Privacy Act (FERPA), the Health Insurance Portability and Accountability Act (HIPAA), or the Gramm-Leach Bliley Act (GLBA).|
|Server||An application or hardware that performs services for connected clients as part of a client server architecture.|
In coordination with the Office of Legal Counsel and the Department of Internal Audit, ITS will develop appropriate specific procedures for compliance with this policy and provide education to the University community on the implementation of this policy and such procedures. Procedures, technology standards, and best practices can be found at the ITS Security web page.
University data must be saved to an appropriate location defined by data storage guidelines based on the data classification except for rare exceptions approved by the Information Security Advisory Committee (ISAC). Data Stewards may request to store unencrypted restricted data through the CIO office, and the request will be forwarded to ISAC for approval. The request acceptance or denial will be noted in the minutes of the ISAC meeting following the request.
If ISAC grants permission for University data to be saved and
stored on University-owner equipment, personally-owned equipment,
or cloud-based services, faculty and staff are personally
responsible for encrypting the data with the current ITS standard
and for remembering the encryption keys or passwords. Access to
saved and stored University data while on campus must be through
the University network.
All University computers must have recommended operating system patches and updates installed, updated firmware, updated antivirus and antispyware tools installed, and firewalls turned on. Other devices connected to the University's network must utilize appropriate security protections to the extent possible, including updated firmware.
Remote access to restricted University data is available only to authorized employees. Employees must be authenticated to access restricted University data remotely. Data must be encrypted during transit.
Access from off-campus must be via VPN.
Home computers that are used to access, store, or transmit restricted University data should use current security patches, updated antivirus and antispyware software, and encryption. In instances where standard security precautions are not free, the employee will incur all costs for security of their home computer.Employees are responsible for deleting all restricted University data from their computer upon termination of employment.
|Portable Devices, Media and Cloud-Based Services||
Each user in the possession of restricted University data is
responsible for protecting the data, regardless of the media or
location where the data resides.
University-owned computers, portable devices and media must have university data securely erased prior to its transfer out of University control, and/or destroyed, using current best practices.
|Failure to Comply with this Policy||
Failure to comply with this policy may result in limiting or
denying access to University data resources. If, upon
investigation by the appropriate University officials, the lack of
compliance appears to have been willful and deliberate or if there
is repeated lack of compliance, disciplinary action may be taken.
|Data Classification Document||
|Data Storage Guidelines|
|Family Educational Rights and Privacy Act (FERPA)||www.ed.gov/policy/gen/guid/fpco/ferpa/index.html|
|Health Insurance Portability and Accountability Act (HIPAA)||www.hhs.gov/ocr/hipaa/|
|Gramm-Leach Bliley Act (GLB)||www.ftc.gov/privacy/privacyinitiatives/glbact.html|
|State of Tennessee Data Security Law|
|Tennessee Board of Regents Policy on Information Technology|
|UoM Policy - Acceptable Use of Information Technology Resources||policies.memphis.edu/UM1535.htm|
|UoM Policy - Security and Protection of Electronic Information Resources||policies.memphis.edu/UM1566.htm|
|UoM Policy - Data Access||policies.memphis.edu/UM1337.htm|
|UoM - TigerLAN Lab Guidelines||umtech.memphis.edu/TigerLAN_Guidelines.htm|
|UoM - ITS Security Procedures and Best Practices|
|Red Flag Policy|
| ||UM1691 -- revised October 7, 2016
UM1691 -- revised October 9, 2014
UM1691 -- revised April 26, 2014
UM1691 -- revised April 17, 2013
UM1691 -- revised November 10, 2009
UM1691 -- issued November 5, 2008 - supercedes policy number 1:2A:03:05
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