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Keep It Safe - Enterprise Information Stewardship - Michigan State ...

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<strong>Keep</strong><br />

<strong>It</strong> <strong>Safe</strong><br />

A guide to securing institutional<br />

data for MSU employees<br />

1


Securing Institutional Data<br />

Effective January 1, 2011, a new Policy for protecting the<br />

security and integrity of <strong>Michigan</strong> <strong>State</strong> University’s<br />

Institutional Data was released. While many units and<br />

individuals have been supportive of the managing sensitive<br />

data initiative rolled out to the campus in 2005, the new<br />

Institutional Data Policy establishes minimum requirements<br />

for the appropriate stewardship of the University’s<br />

Institutional Data.<br />

The Policy on Institutional Data applies to all University<br />

business and academic units and all MSU employees. Unit<br />

administrators and supervisors will be implementing training<br />

and procedures in support of this Policy. The Institutional<br />

Data Policy calls for:<br />

• Members of the University community to access and use<br />

Institutional Data only for University purposes.<br />

• Institutional data to be used, stored, transferred,<br />

disseminated, and disposed of in ways that minimize the<br />

potential for their improper disclosure or misuse.<br />

• Members of the University community to be individually<br />

responsible for the security and integrity of Institutional<br />

Data in their possession or control, including their<br />

proper storage and disposal.<br />

Mitigating the risk of unauthorized exposure and protecting<br />

the University’s information assets is the responsibility of<br />

every member of the MSU community. You can help protect<br />

yourself, our network, and University resources by following<br />

the practices outlined on this guide.<br />

1


2<br />

Confidential Institutional Data<br />

MSU’s Institutional Data Policy sets minimum expectations<br />

for members of the MSU community for the stewardship of<br />

institutional data, especially Confidential Data. Faculty, staff,<br />

and students have individual responsibilities for protecting<br />

the security and integrity of institutional data.<br />

What are institutional Data?<br />

Institutional data are all of the data held by MSU, in any<br />

form or medium, for normal business operations.<br />

What Data are Confidential?<br />

• Institutional data that can be used for identity theft or<br />

related crimes, e.g., Social Security numbers, account<br />

numbers, date of birth, and mother’s maiden name<br />

• Institutional data whose public disclosure is restricted<br />

by law, contract, university policy, professional practice,<br />

e.g., student records, medical records and donor records<br />

• <strong>Information</strong> concerning MSU’s plans, procedures and<br />

methods for securing data, e.g., passwords, decryption<br />

keys, data access controls, and threat assessments<br />

• Institutional data whose value would be lost or reduced<br />

by unauthorized disclosure or whose unauthorized<br />

disclosure would otherwise adversely affect the<br />

university financially, e.g., research data, technical<br />

information and property appraisals<br />

The policy, including purpose, applicability, definition of<br />

terms, responsible use requirements, authorized release of<br />

data, implementation, violations, and additional examples<br />

and resources are available at eis.msu.edu/sid.<br />

If you are uncertain if particular data are considered<br />

confidential, err on the side of caution and treat the data as<br />

confidential. Ask your supervisor or unit administrator.


What’s at Stake?<br />

• Your privacy and the privacy of others—Protecting<br />

personally identifiable confidential information helps<br />

keep it private, safe from identity thieves, avoids possible<br />

criminal and civil legal action and penalties, and helps the<br />

university comply with federal and state regulations, e.g.,<br />

Family Educational Rights and Privacy Act (FERPA).<br />

• Computer and network performance—<strong>Keep</strong>ing your<br />

computer secure with anti-virus software; active firewalls;<br />

application patches; and up-to-date operating systems<br />

helps to keep the university network secure and stable.<br />

• MSU’s reputation—Securing Confidential Data from<br />

unauthorized access helps ensure compliance with<br />

federal law (e.g., HIPAA), state law (e.g., <strong>Michigan</strong><br />

Social Security Number Privacy Act) and contracts (e.g.,<br />

PCI/DSS) that protect privacy. <strong>Keep</strong>ing Confidential<br />

Data secure avoids adverse publicity, and protects the<br />

university’s reputation and public trust.<br />

• Your reputation—Members of the university<br />

community may be held individually responsible for the<br />

appropriate collection, creation, usage, storage, transfer,<br />

dissemination, and disposal of institutional data to which<br />

they have access. Confidential data should be handled in<br />

ways that comply with university policy and professional<br />

practice that protects privacy.<br />

3


Your Role<br />

<strong>Michigan</strong> <strong>State</strong> University (MSU) employees need to<br />

protect the security of MSU’s institutional data as well as<br />

the associated computer systems and networks that handle<br />

the data. We have both a legal and an ethical responsibility<br />

to work responsibly with and safeguard the privacy of<br />

confidential information. We need to comply with state and<br />

federal legislation, funded research program requirements,<br />

and associated university policies and guidelines that address<br />

protecting the security and confidentiality of institutional<br />

data.<br />

We all have roles to play in managing institutional data:<br />

unit administrators and administrative staff, IT staff and<br />

end users — anyone who collects, creates, stores, maintains,<br />

distributes, uses, archives, deletes, destroys, or handles<br />

institutional data in any way.<br />

Recognize and remember your position of trust:<br />

• Institutional data should only be made available and<br />

used on a “need-to-know” basis for university purposes,<br />

the fulfillment of employment responsibilities, and<br />

participation in university governance processes.<br />

• We are each responsible for the appropriate use, release<br />

and disposal of institutional data.<br />

• We are each responsible for the security and integrity<br />

of institutional data.<br />

• Treat all Confidential Data as a highly valuable asset.<br />

• Minimize the chance of its release to an unauthorized user.<br />

• Do not share Confidential Data with unauthorized<br />

individuals or store on shared websites or file servers.<br />

4


Know Your Personal Responsibilities<br />

<br />

<br />

<br />

<br />

<br />

<br />

<br />

Provide information on a need-to-know basis only.<br />

Do not store, transmit, or use Confidential Data unless<br />

needed to perform your assigned duties and responsibilities.<br />

Carefully weigh the need for storing, transmitting,<br />

and using the data against the risk of exposure and the<br />

administrative responsibilities for protecting it.<br />

Properly secure Confidential Data you do need<br />

<strong>Keep</strong> Confidential Data you do need only for as long as<br />

necessary to do your job.<br />

Dispose of Confidential Data as soon as it is no longer<br />

needed.<br />

Exercise caution when using cloud computing computing<br />

services such as Google Apps, Gmail and Microsoft Office<br />

Live. Guidelines for working “in the cloud” are available<br />

through the Featured Links at eis.msu.edu/sid/keepitsafe.<br />

5


6<br />

<strong>Keep</strong> Confidential Data Secure<br />

Practice Smart Habits<br />

• Store Confidential Data on a secured server. Avoid<br />

storing copies of Confidential Data on laptops, desktops,<br />

smartphones, or portable devices, e.g., USB drives.<br />

• If you need to access Confidential Data connect to a<br />

secured MSU server.<br />

• Don’t leave Confidential Data or portable media<br />

unattended. Physically secure data when not in use.<br />

• Do not open unexpected attachments or attachments<br />

from unknown sources. Be skeptical and use caution<br />

when downloading anything—know the person or<br />

entity who sent it before downloading.<br />

• Avoid sending Confidential Data electronically. When<br />

necessary, send the data over a secured communication<br />

method (or make sure the data are encrypted). Contact<br />

your local technical staff for details.<br />

• Ensure that your<br />

screen saver is set to<br />

require a password before the<br />

desktop can be reactivated.<br />

• Turn your computer<br />

off when not in<br />

use. Lock it when<br />

you step away from<br />

your desk.


Protect Your Computer<br />

A computer should be secured before it connects to the<br />

network, e.g., virus protection and firewall. An unprotected<br />

computer can be taken over in minutes and often without<br />

any outward signs. Take steps to help ensure your system is<br />

secure. See your local technical staff for details.<br />

Password Protection Tips<br />

Best practices for passwords include:<br />

• Try to memorize your password.<br />

• Make them hard to guess. Use strong passwords.<br />

• Change passwords often.<br />

• Do not share them with others.<br />

• Use different passwords for different accounts.<br />

• If you must write it down, keep it in a secure, locked<br />

place or as a strongly encrypted file.<br />

• Contact your security administrator and change your<br />

password immediately if you suspect a problem.<br />

Strong password tip...<br />

Password requirements typically enforce length and use of<br />

certain types of characters. An MSU NetID is required to<br />

have a password at least eight characters long and contain<br />

three of the four character types (upper case letters, lower<br />

case letters, numeric characters, symbols). A great way to<br />

create a secure password is by using an easy-to-remember<br />

sentence. For example: “I typically ate pizza three times per<br />

week” when used as a base, can become “<strong>It</strong>8p3xpwk.”<br />

Limit Data Exposure<br />

• Do not use Social Security numbers as an identifier.<br />

• Educate yourself about the most common tactics<br />

imposters use to gain access to confidential information.<br />

• See your technical staff to learn how to protect data on<br />

the server.<br />

7


Action Plan for Units and Individuals<br />

1. Inventory your data — What Confidential Data do you<br />

have? Where is it? How is it used? Who has access to it?<br />

2. Assess the impact of exposure — What laws and/or<br />

policies apply? What are the consequences of exposure?<br />

3. Reduce the risk of exposure — Be aware of good<br />

security habits and practices, keep your inventory current,<br />

physically and digitally secure the data<br />

• Unapproved and unsecured wireless networks, e-mail, and<br />

public computers are particularly vulnerable to breaches.<br />

• Reputable organizations will never ask you to share<br />

confidential information, especially passwords.<br />

8<br />

Remember:<br />

• You may need to exchange or use Confidential Data daily.<br />

Examples include credit/debit card numbers, driver’s<br />

license numbers, Social Security numbers, personal<br />

identification numbers, digital keys and passcodes. These<br />

are Confidential Data that could be used for identity theft,<br />

fraud, or other crimes.<br />

• Confidential data are more easily stolen when shared<br />

between users, so take note of the type of connection used.


Report a Data Security Breach Immediately<br />

A reportable incident occurs when:<br />

• An unauthorized person is believed to have gained the<br />

ability to access institutional data that are stored on a<br />

university data system, or<br />

• A person who is authorized to access the information<br />

misuses that data.<br />

Examples of reportable incidents include:<br />

• The theft or physical loss of computer equipment<br />

(including personal equipment) known to hold files<br />

containing Social Security numbers or other Confidential<br />

Data.<br />

• An unencrypted list of university donors with gift<br />

amounts is e-mailed to an unauthorized recipient.<br />

• A computer known to hold Confidential Data is accessed<br />

or otherwise compromised by an unauthorized party.<br />

• Materials with personally-identifiable information, such<br />

as printed copies of grades or applications, are discovered<br />

in a publicly-accessible location.<br />

Aware of suspicious activity?<br />

Any known or suspected compromise of institutional<br />

data should be reported immediately to:<br />

MSU’s ATS Help Desk: (517) 432-6200<br />

Detailed information on what a reportable incident is,<br />

how to report it, and procedures regarding notification<br />

to affected persons is available at eis.msu.edu/sid in the<br />

document entitled Guidelines for Internal and External<br />

Reporting of Data System Security Breaches.<br />

9


Destroy What Isn’t Needed<br />

• When you no longer need Confidential Data, it is best<br />

to destroy it. Shred papers with Confidential Data and<br />

sanitize hard drives when disposing or transferring<br />

computers.<br />

• The <strong>Michigan</strong> Identity Theft Protection Act requires<br />

destruction of data containing personally-identifiable<br />

information when the data are “removed from the<br />

database” and not retained for a permitted use.<br />

• Follow the Best Practices in Disposal of Computers and Electronic<br />

Storage Media listed in the Featured Links section at<br />

eis.msu.edu/sid/keepitsafe.<br />

• Sanitize data by following information contained in<br />

Learn How to Sanitize Data for Disposal and Day-to-day Security<br />

available in the Featured Links section at eis.msu.edu/<br />

sid/keepitsafe.<br />

10


How Do I <strong>Keep</strong> Data Confidential?<br />

• Know what data are confidential<br />

• Know your responsibilities<br />

• Access and use ONLY as needed to do your job<br />

• <strong>Keep</strong> data secure<br />

• <strong>Keep</strong> ONLY as long as needed<br />

• Destroy when no longer needed<br />

Libraries, Computing and Technology<br />

400 Computer Center<br />

East Lansing MI 48824-1042<br />

(517) 353-0722<br />

vplct@msu.edu<br />

11

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