Research & Economic Development Office of Grants and Contracts Administration Data Security Presented by Debbie Bolick September 24, 2015
Data Security Data security Means safeguarding data, from being lost, modified, or unauthorized access Monitoring That responsible parties are compliant with security plans Termination Disposition or Sanitization of Data
What type of Data is being protected? Defined personally identifiable information Information that can be used to distinguish or track an individual’s identity such as name, SSN, or biometric information Indirect identification using information in conjunction with other data elements to reasonably infer the identity of a respondent such as a combination of gender, race, date of birth, geographic indicators, or other descriptors Non-identifiable information Tracking purposes
CIPSEA Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA), Implemented June 15, 2007 Provides strong confidentiality protections for statistical information collections sponsored by or conducted by more than 70 Federal agencies Establishes uniform policy across Federal agencies Authorizes data sharing among specified agencies (Bureaus of Economic Analysis, Labor Statistics and Census) to include identifiable data CIPSEA data may only be used for statistical purposes
CIPSEA Penalties for non-compliance Class E felony with imprisonment of not more than five (5) years Fine of not more than $250,000
CIPSEA Implementation Guidance Harmonized principles and processes and set minimum standards Utilized best practices for handling Addressed intersection between CIPSEA and Privacy Act of 1974 for non-statistical uses
Authority Federal agencies empowered to make determination about the sensitivity of their information used for statistical purposes under a pledge of confidentiality Applies to local and state governments collecting data for federal agencies Special procedures required for use of laptop computers, PDAs, zip drives, floppy disks, CDROMs or any other IT devices
Minimum Standards All persons with access understand his/her responsibility related to maintaining confidentiality of information Monitoring procedures for collection and release Evaluating the reason for and controlling access Maintaining physical and information systems security Required Training Overview of protection procedures Limit access to those with a “need to know” Physical and information systems security procedures must be in place Penalties
Ensure Controls
311.9 Regulation Regarding Third Party Data Subject to Contractual Access Data Security at UNC Charlotte pursuant to Policy Implemented February 2011 Policy for handling and safeguarding electronic third part y data Received from third parties Subject to contractual access restrictions. Ensures that adequate precautions are implemented prior to receiving such data Maintain the security and confidentiality of covered data; and Protect against the unauthorized access or use of such records or information in ways that could violate the University’s agreements with third parties who supply such data.
Initiate Request for Data? Data Security Officer ) First Point of Contact Data Security Plan Checklist University Signatory Data Use Agreement Document Repository Submits to Agency Data Sponsor Agency releases Data to PI PI
Ongoing Monitoring College Data Security Officer Central IT Random audits Collaborative role PI (Lead Custodian) cannot be a student Authorizes Updates and monitor Students Research staff Signs Use Agreement System of Record Signatory Unit Responsible Party Information Security Internal Audit
DSO list Data Security Officers Effective April 2015 Charles Andrews......Metropolitan Studies and Extended Academic Programs William Ardern William States Lee College of Engineering Brian Bard Student Health Center Tim Carmichael Belk College of Business Alex Chapin College of Liberal Arts & Sciences Rose Diaz College of Arts + Architecture Dane Hughes College of Education Joe Matesich College of Computing and Informatics Michael Moore College of Health and Human Service
Resources College Data Security Officers IT Policies & Standards Security Awareness Training assurance/security-awareness-training Human Subjects (IRB) compliance-orc/human-subjectshttp://research.uncc.edu/departments/office-research- compliance-orc/human-subjects Checklist & Data Security Plan orc/human-subjects/3rd-party-data-requirements
QUESTIONS?