Systems should not
include restricted information unless absolutely necessary. Restricted
data elements are defined in IS-3
Electronic Information Security. Examples of restricted data elements
include Social Security numbers, ethnicity, date of birth, and financial
information such as credit card number or bank account number.
Avoid storing restricted
data on portable devices. If restricted data must be transferred onto
portable devices, implement measures to safeguard the confidentiality
or integrity of the data in the event of theft or loss of the portable
device.
Provide staff access
to restricted data only as needed to perform assigned duties.
Maintain appropriate
physical security for computing devices with restricted data. Take
special care with a laptop that includes restricted data; in the event
of theft, not only will the laptop be lost, but also restricted data
will be compromised.
Delete personal information
when there is no longer a business need for its retention on computing
systems.
Remove all information
from your old computer when you replace it. Be aware that many types
of erased data can be recovered from your computer, unless you take
explicit measures to effectively remove it.
Avoid using restricted
data elements as the “key” to a database.
Avoid using actual data
when testing an application; rather, “mask” the restricted data, such
as Social Security number, with dummy information. If this is not
possible, ensure implementation of security measures appropriate to
the standard working environment.
When personally identifying
information is distributed to users, include notification that the
data is restricted and requires security protection. Include reference
to applicable policies and regulations. Delete personal information
not critical to the task when distributing full data sets.
When passing restricted
data to a third party agent of the University, ensure there is a written
contractual agreement (including terms and conditions) that provides,
at a minimum, for (a) disallowance of disclosure by the agent
or affiliate to other third parties including subcontractors, (b)
the requirement that all agents and affiliates must observe the laws
and policies required of the University of California for privacy
and security, including federal and state law, (c) a specific plan
by the agent or affiliate for the implementation of logical, physical,
and managerial security strategies, and (d) a specific plan for the
destruction of restricted data upon completion of the agent's or affiliate's
work for UCOP.
