Information Technology Services

In today's universe, protecting confidential data is crucial. NDSU is a custodian of personal information belonging to students, staff, faculty, researchers, and tose who use its outreach services. As custodian of that information, NDSU is responsible for protecting and securing personal, student-related, financial, health information, and intellectual property from misuse, theft, compromise, and unauthorized disclosure. As an employee of NDSU it is your responsibilty to

• Follow all applicable laws, and NDSU policy and procedure
• Use due diligence when working with confidential and senstive data
• Incorporate and use mandated and recommended standards and guidelines for protection of confidential and sensitive data

When working with confidential and private data, these best practices must be followed

• All data must be classified.
• All data access must be authorized under the principle of least privilege and based on minimal need.
• All access to confidential data must be authenticated and logged.
• When an individual has been granted special access changes responsibilities or leaves employment, all thier access rights must be reevaluated and any unneeded access removed.
• When necessary, data transmission and storage should be encrypted.

Federal and state laws that protect personal data

• FERPA (Family Education Rights and Privacy Act), 1974. This law protects student information such as name, SSN, demographic information, grades and information related to their education.
• GLBA (Graham Leech Bliley Act), 2000. A finacial law designed to protect personal financial information such as financial aid, banking, credit , and investment information.

• HIPAA (Health Insurance Portability Accountability Act), 1996. A federal law that protects personal health information.

State Laws and Other Standards that protect personal data

• ND Privacy Law, 2006, Protects personal data. NDSU is required to report to the owner of the data if a breach has occured and if information has become compromised or stolen.
• North Dakota Public Records Statute. Defines what is and isn't a public record or what data can be made availabe for public view.
• PCI - DSS (Payment Industry Data Security Standard). Standards created for online credit card transactions by the four major credit card payment companies. Requires those entities that accept online credit card payments to follow strict standards.

NDUS and NDSU Policies and Procedures

• North Dakota University System Computer Use Policy and Procedure 1901.2
  • http://www.ndus.nodak.edu/policies_procedures/ndus_policies
• NDSU 710: Computer and Electronic Communication Facilities
  • http://www.ndsu.nodak.edu/policy/710.htm
• NDSU 158: Acceptable Use of Electronic Communication Devices
  • http://www.ndsu.nodak.edu/policy/158.htm
• NDSU 718 Public/Open Records
• • http://www.ndsu.edu/policy/718.htm
• NDSU Policy Manual
  • http://www.ndsu.nodak.edu/policy/

North Dakota University System Data Classification Standard

The North Dakota University System Data Classification Standard was developed to identify and clarify the definition of data types within a university. Any data asset of the NDUS or the Institution shall be classified as Public, Private, or Confidential.

Public data is defined as data that any entity either internal or external to the ND University System can access. The Open Records law of North Dakota may apply. Public data elements include

Private data includes information that the NDUS or institution is under legal or contractual obligation to protect. Private information may be copied and distributed with the NDUS only to authorized users. Private information disclosed to authorized external users must be done so under a non-disclosure agreement. Private data elements include

Confidential data is information that is not to be publically disclosed. The disclosure, use, or destruction of confidential data can have adverse effects on the ND University System or the institution and possibly carry significant civil, fiscal, or criminal liability. This designation is used for highly sensitive information whose access is restricted to selected, authorized employees. The recipients of confidential information have an obligation not to reveal the contents to another individual unless that person has a valid "need to know" for the information. Confidential information must not be copied without authorization from the owner. Confidential data elements include

The owner of the data is the one whom the data belongs to. For example, a person owns his/her social security number, date of birth, and address.

The custodians of such data are employees, departments, colleges, research centers, and extension offices responsible for the integrity, confidentiality and availability of the data. It shall be the responsibility of the owner/custodian of the data to classify the data. However, all individuals accessing data are responsible for the protection of the data at the level determined by the owner/custodian of the data as mandated by law. Any data not yet classified by the owner/custodian shall be deemed Confidential. Accerss to data items may be further restricted by law, beyond the classification systems of the NDUS or NDSU.

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Quick Reference Guide for NDSU Data Classification

Confidential	Private	Public
Legal investigations conducted by the institutions	Employee ID number	Employee Information	Student Directory Information*
Sealed bids	Birth date	Name	Name
Trade secrets or intellectual property such as research activities	Location of assets	Salary	Address
Social Security Number	Donors	Expense reimbursements	Telephone number
Gross pension	Gender	Job titles	Electronic (e-mail) address
Value and nature of fringe benefits	Ethnicity	Job descriptions	Dates of enrollment
Health records	Citizenship	Education and training	Enrollment status (full/part-time, not enrolled)
Passwords	Citizen visa code	Previous work experience	Major
Credit/debit card information	Veteran and disabled status	First and last employment	Advisor
	Non-Directory Student Information*	Existence and status of complaints	College
	Grades	Terms of buy-out agreements	Class
	Courses taken	Final disposition of disciplinary action	Academic awards and honors
	Schedule	Work location	Degree recieved
	Test scores	Work phone number
	Advising records	Work electronic (e-mail) address
	Educational services recieved	Honors and awards recieved
	Disciplinary actions	Payroll time sheets
	Student ID	Home address*
		Home telephone number*
		Other
		Financial data on public sponsored projects
		Course offerings
		Invoices and purchase orders
		Budgets

Non-Directory Student Information* - May not be released except under certain perscribed conditions.

Student Directory Information* - This information is public unless the student has requested non-disclosure (suppress).

Home Address* - Considered public information unless employee has requested non-disclosure (suppress).

Home Telephone Number* - Considered public information unless employee has requested non-discosure (suppress).

Social Security Numbers

Do not use SSNs as a key field or as an identifier for files, spread sheets, data bases, and correspondence. If possible, it is recommended to avoid including the SSN in any type of file or document. An alternative would be to use the EmplID or Student ID.

If there is a business need to use the SSN in files and documents, the data must be secured and available only to those who have a need to know.

If you use a laptop and travel, it is recommended the hard drive of the laptop's hard drive be encrypted.

Never attach documents containing SSN's or other personally identifiable information to email. It is possible the transmission may not be secure.

Credit Card Information

Credit card information is protected under the Payment Card Industry Data Security Standards and by various federal and state laws. When accepting, using, and storing credit card information, these guidelines must be followed.

• Do not store the full credit card number. If there is a business to store credit card information, only the last four digits can be stored electronically or in hard copy.
• Do not store the CVV2 (Credit card validation value - the three digites located on the back of the credit card).
• Do not store the expiration date
• Credit card reciepts must only show the last four digits of the card. The CVV2 and/or the expiration data must not be printed on the reciept.
• Do not accept credit card information over e-mail.
• If credit card information is recieved over voice mail, delete immediately.
• Within the office/college, there must be separation of duties for accepting and processing credit cards.

NDSU uses a secure third party vendor, TouchNet, to accept credit cards. Please contact NDSU Customer Account Services, Karin Hegstad or Carrie Peterson for more information on how to use this service. If it is desired to implement another vendor or method of collection for payment using credit cards, please read NDSU policy 509, Electronic Financial Transactions.