Evolution of Data Use and Stewardship Recent University-wide Data Stewardship Enhancements Integrated System Data Stewardship Shirley C. Payne, CISSP, CRISC UVa Assistant VP for Information Security, Policy, and Records July, 2012

etc. Data Dark Ages Centralized Stovepipe Data Stores

etc. Data Floodgates Opened In Early 90s I NFORMATION W AREHOUSE

Clarified data ownership: University is owner of all administrative data Organizational units may have stewardship responsibilities for portions of those data Set high level conditions of data use: Use only for University business Comply with confidentiality and privacy policies and laws Comply with reasonable protection and control procedures Present data accurately

Defined roles and responsibilities for (initially) : Data Stewards – data use planning/policy Data Custodians – data creators/updaters Data Users – data viewers ITC – technical underpinning New roles and responsibilities added over time and existing ones renamed and/or updated Last update was in 2001

Departmental Systems ERPs Escalating Security Threats Web Apps New Laws & Regulations Increasing Public Awareness & Concern Cloud Computing Mobile Computing

Highly sensitive data requested only when essential Highly sensitive data provided only when essential Highly sensitive data access authorized to least # of people Highly sensitive data stored only in well secured devices and file cabinets University Processes & Supporting Systems Data Minimization Initiative Clear data use policies and standards exist Responsibilities for data protection well communicated Compliance verification processes in place

Redefined Data Classifications

Highly Sensitive Moderately Sensitive Not Sensitive - Data that enables identity theft - Personally- identifiable medical data Everything In between Public Data such as: - University financial statements - Summary statistics, e.g. employees by gender

Redefined Data Classifications Protection and Use of SSNs Policy

Redefined Data Classifications Protection and Use of SSNs Policy Electronic Storage of Highly Sensitive Data Policy

Redefined Data Classifications Protection and Use of SSNs Policy Electronic Storage of Highly Sensitive Data Policy Institutional Data Protection Standards By Classification

Redefined Data Classifications Protection and Use of SSNs Policy Electronic Storage of Highly Sensitive Data Policy Institutional Data Protection Standards By Classification Revision of Administrative Data Access Policy

Current Policy Planned Revision Administrative Data Access Policy Addresses administrative electronic data shared across departments Roles and responsibilities do not reflect current practice; unclear how to fulfill Institutional Data Stewardship Policy Addresses all data owned by the institution wherever they are created and used and whatever the form Roles and responsibilities are updated and clearer Clear linkage made between data classifications and data protection standards

Data Domain Roles System-Specific Roles

Human Resources Data Procurement Data Payroll Data Accounts Receivables Data Development Data Student Records Data Other Data Domains

Human Resources Data Domain Integrated System Time and Leave System System Other Systems Benefits System

Integrated System Procurement Data Domain Accounts Receivables Data Domain Hunan Resources Data Domain Payroll Data Domain Other Data Domains Budget Data Domain

Senior university officials having planning and policy-level responsibilities for a large subset of the institutions data resource. They: Oversee the implementation of the Institutional Data Stewardship Policy for their data domains Determine the appropriate classification of institutional data within their domains in consultation with executive management and appropriate others Appoint Data Stewards for their data domains

University officials having responsibility for determining purposes and functions of data within their assigned data domains. They: Work to ensure accuracy, integrity, and (as appropriate) confidentiality of data Establish criteria for meeting the need to know requirement for data access. Have final sign-off authority for users seeking to access data for their respective data domains. May delegate final sign-off authority to Deputy Data Stewards they appoint, but retain accountability for results. Work to ensure users understand the data to which they have access

Authorize or reject access requests based upon approval criteria established by the Data Stewards who appoint them

Data Users – acknowledge acceptance that they are accountable for protecting and appropriately using data to which they are given access meet all prerequisite requirements, e.g. attend training on system use, before being granted approved access. Supervisors – confirm that their employees job duties require system access privileges assure system access privileges are removed when employees no longer need them. Data Access Approvers – develop in-depth understanding of various responsibilities established within a given system confirm that data access requests for a given system are completed correctly, e.g. that appropriate system responsibilities are selected for the stated purpose(s). Provisioners – central IT staff who implement the requested access authorizations.

Protection & Use of SSNs Policy Electronic Storage of Highly Sensitive Data Policy Institutional Data Protection Standards Administrative Data Access Policy (under revision) Additional IT Policies