Body
PRINT DISCLAIMER: Official version of this document is accessible in the online policy library at https://policyoffice.ku.edu/. Printed copies may not reflect the most recent updates.
DOCUMENT TYPE:
Policy
PURPOSE:
This Procedures Guide for the University community was created to help you effectively manage information in your daily mission-related activities. Determining how to protect & handle information depends on a consideration of the information’s type, importance, and usage. These procedures outline the minimum level of protection necessary when performing certain activities, based on the classification of the information being handled. Classification is necessary to understand which security practices should be used to protect different types of information. The more protected the information needs to be, the more practices are required.
Information is classified as Level I, II, or III as defined in the Data Classification and Handling Policy based on the need for confidentiality and critical nature of that information.
NOTE: If any part or subset of the data requires more stringent controls or protections due to statutory, regulatory, and/or contractual obligation, and the data is not severable, then the highest or most stringent protection required for the subset of the data impacted shall govern the entire data set.
Although this Procedures Guide attempts to cover most situations at the University, it is not all-inclusive, and is not intended to represent all protections that may be necessary for each situation.
APPLIES TO:
University employees (faculty, staff, student employees) and other covered individuals (e.g., affiliates, vendors, independent contractors, etc.) in their handling of University data, information and records in any form (paper, digital text, image, audio, video, microfilm, etc.) during the course of conducting University business (administrative, financial, education, research or service).
“Handling” information includes, but is not limited to, the following: creating, collecting, accessing, viewing, using, storing, transferring, mailing, managing, preserving, disposing, or destroying.
CAMPUS:
Lawrence
TABLE OF CONTENTS:
In order to safeguard information, these 9 procedures should be followed:
- Determine How Much Protection your Information Needs
- Collect Only What is Necessary
- Provide Minimum Necessary Access
- Disclose Only the Minimum Information Necessary
- Safeguard Information in Transit
- Secure Physical Equipment and Resources
- Safeguard Information in Storage
- Dispose of Information Securely When No Longer Needed
- Stay Informed About Information Risks
POLICY STATEMENT:
1. Determine How Much Protection your Information Needs
The amount/type of protection to be applied to your information depends on an assessment of the need for the Confidentiality and/or critical nature of that information. The table below summarizes this process. For more detail regarding what types of information require Level I, II, or III Protection, refer to the Data Classification and Handling Policy, and Appendix 1: Data Classification Levels I, II and III.
How would you describe your information?
Is it Confidential? |
Level I Protection |
STOP!
SPECIAL CARE IS REQUIRED |
Is there a high need for Integrity? |
Is there a high need for Availability? |
Is it Sensitive? |
Level II Protection |
BE VERY CAUTIOUS |
Is there a medium need for Integrity? |
Is there a medium need for Availability? |
Is it Public? |
Level III Protection |
PROCEED WITH AWARENESS |
Is there a low need for Integrity? |
Is there a low need for Availability? |
The rest of this Guide is organized so that you can see what protections are required or recommended for your information, based on the classification level you have determined.
2. Collect Only What is Necessary
|
Level I |
Level II |
Level III |
A. Collect only the minimum required amount of data to fulfill institutional responsibilities. |
Required |
Required |
Required |
B. Collect Social Security Numbers only as required to achieve necessary institutional purpose. |
Required |
Not Applicable |
Not Applicable |
C. Retain full credit card numbers (electronically or on paper), only if written approval has been obtained from Financial Services, the E-commerce committee, and the IT Security Office.
|
Required |
Not Applicable |
Not Applicable |
3. Provide Minimum Necessary Access
|
Level I |
Level II |
Level III |
A. Limit access to information to those with a legitimate interest (“need to know” or “need to do”) based on their institutional responsibilities. |
Required |
Required |
Required |
B. Access or attempt to access only information required to fulfill your institutional responsibilities. |
Required |
Required |
Required |
C. DO NOT log in for other people who are trying to access the computer system, e-mail system or other device. Never use anyone else’s login information. |
Required |
Required |
Required |
D. Grant access only to those authorized by the data owner. |
Required |
Required |
Recommended |
E. Use an authentication process to control access to non-public file systems.
- Authentication means individuals attempting to gain access must have been previously approved for access and must prove their identity for each requested access by entering their user name and password or using another approved method of identification.
|
Required |
Required |
Not Applicable |
F. Ensure all vendor access has been approved by the IT Security Office. |
Required |
Required |
Required |
G. Track and review who has gained access by recording ALL access in a system log. At a minimum, successful and failed login events, successful and failed account management events, and successful and failed policy and system events should be logged. (The logs should be stored in a way that precludes system administrators from altering/deleting them. The logs will be reviewed for anomalies monthly.) |
Required |
Recommended |
Recommended |
H. Information must be protected from unintended access by unauthorized users.
- Guard against unauthorized viewing of such information displayed on your computer screen, keyboard, or login screen.
- Do not leave information unattended and accessible.
- Do not leave keys or access badges for rooms or file cabinets containing information in areas accessible to unauthorized personnel.
- When printing, photocopying or faxing information, ensure that only authorized personnel will be able to see the output. If these machines retain the last document or several documents in memory, be sure to clear the memory after sensitive documents have been processed. Use a fax cover sheet with a confidentiality statement.
|
Required |
Required |
Recommended |
I. Respect the confidentiality and privacy of individuals whose records are accessed by observing ethical restrictions that apply to the information accessed and by abiding by all applicable laws and policies with respect to accessing, using, or disclosing information. At a minimum:
- Ensure Confidentiality Agreements are signed by staff with access to those systems storing and/or processing Sensitive Information.
- Use an approved login banner on services that support it in order to inform users of their rights and responsibilities.
|
Required |
Required |
Required |
J. Revoke or modify access rights and privileges to information for any individual with new or different responsibilities.
- This may include obtaining keys, deactivating user accounts, changing the level of network access, changing codes for key punch systems, or deactivating passwords used to obtain access.
- To revoke or modify access rights to electronic mail or shared electronic resources, see IT's Accounts page.
|
Required |
Required |
Not Applicable |
K. Establish a periodic review (at a minimum quarterly) of user accounts including the related access rights and privileges for employees in your unit and modify those rights when appropriate.
- Maintaining a current list of employees and their corresponding access rights is one way to facilitate the review process.
|
Required |
Required |
Not Applicable |
L. Restrict servers to a single primary function. |
Required |
Recommended |
Recommended |
M. Disable or remove unused services, applications, ports, and user accounts. |
Required |
Recommended |
Recommended |
N. Physically secure access to operating systems, servers, and network equipment by placing them in areas that allow access to be restricted. |
Required |
Required |
Recommended |
O. Secure portable devices and portable media devices when unattended (e.g., laptop, PDA, smartphone, etc., and CD’s, DVD’s, floppy disks, USB/Flash/Thumb drives, etc.). |
Required |
Required |
Recommended |
P. Secure backup media from unauthorized physical access. |
Required |
Required |
Recommended |
Q. Ensure system setup is done in an environment that is only accessible to authorized administrators. |
Required |
Required |
Recommended |
R. All systems shall use only the below KU-approved network and system login banner:
“Access to electronic resources at the University of Kansas is restricted to employees, students, or individuals authorized by the University or its affiliates. Use of this system is subject to all policies and procedures set forth by the University in the Policy Library. Unauthorized use is prohibited and may result in administrative or legal action. The University may monitor the use of this system for purposes related to security management, system operations, and intellectual property compliance.” |
Required |
Required |
Recommended |
4. Disclose Only the Minimum Necessary Information
|
Level I |
Level II |
Level III |
A. Do not discuss or display information in an environment where it may be viewed or overheard by unauthorized individuals. |
Required |
Required |
Recommended |
B. Limit a disclosure to the amount of information reasonably necessary to achieve the purpose of the disclosure. |
Required |
Required |
Required |
C. Disclose information only when necessary and only to the extent that such disclosure is consistent with University policy and permitted or required by law. |
Required |
Required |
Recommended |
D. Ensure the Office of the General Counsel reviews all subpoenas, search warrants, or other court orders prior to release of information. |
Required |
Required |
Required |
E. Refer requests for information from media representatives (i.e., reporters, TV news crews, etc.) to the Office of University Relations. |
Required |
Required |
Required |
F. Report immediately any potential or suspected breach or compromise of, or unauthorized / unexplained access to University information (electronic or paper) to the Information Technology Customer Service Center (785-864-8080).
- The Information Technology Customer Service Center will notify the KU Privacy Officer and/or the KU IT Security Officer as required by the particular incident.
|
Required |
Required |
Required |
5. Safeguard Information in Transit
|
Level I |
Level II |
Level III |
A. Use secure methods of transmission when sending any Private, Confidential, or Sensitive data.
- Secure methods include, but are not limited to:
- Encryption (i.e., at least Triple DES or AES; use AES-256 when possible),
- Virtual private network (VPN),
- Secure Shell (HTTPS),
- Secure FTP (SFTP),
- Encrypted and password protected CDs separated from passwords (phoned in) and/or the decryption keys (hand carried),
- Facsimile transmission to secure faxes, etc
|
Required |
Required |
Recommended |
B. Encrypt email when sending Private, Confidential, or Sensitive information, even to other authorized users. The encryption method and key storage method must be approved by IT Security.
- Examples of information that should not be sent by email (unless encrypted) include, but are not limited to:
- Student lists,
- Data subject to the Health Insurance Portability and Accountability Act (HIPAA),
- Data subject to the Gramm-Leach Bliley Act (GLBA), or
-
- Use a confidentiality statement at the beginning or end of e-mails to notify the recipient of confidential content.
|
Required |
Required |
Recommended |
C. Send faxes only when the intended recipient is present.
- Use a confidentiality statement at the beginning or end of e-mails to notify the recipient of confidential content.
- Verify fax numbers prior to transmission.
|
Required |
Required |
Recommended |
D. Ensure information (including device(s) containing information) is physically secure at all times when carrying or hand-delivering it to a new location. |
Required |
Required |
Recommended |
E. Remove information from secure locations only with prior approval. |
Required |
Required |
Recommended |
F. Access information remotely using only secure methods approved by the KU IT Security Office.
- For example, KU Anywhere is a virtual private network that can be used to access Private Information remotely.
|
Required |
Required |
Recommended |
G. Accessing or transferring Private Information (Confidential or Sensitive information) using on-campus wireless connections is NEVER appropriate, unless the wireless network is encrypted and it has been approved by the KU IT Security Office. |
Required |
Required |
Not Applicable |
H. Accessing and transporting Social Security Numbers via a portable device is NOT appropriate. |
Required |
Not Applicable |
Not Applicable |
6. Secure Physical Equipment and Resources
|
Level I |
Level II |
Level III |
A. Actively “lock” your workstation when you are away from your desk; do not just wait for the screen saver feature to self-activate. |
Required |
Strongly Recommended |
Strongly Recommended |
B. Use “strong” passwords that are not easily guessed. Ensure that computer monitors are situated in a manner that login screens cannot be observed by passersby. Any passwords written down should be securely stored. Detailed requirements in regards to password strength and password changes can be found in the KU Password Policy. |
Required |
Required |
Required |
C. Place devices that can be used to print information in secure locations. |
Required |
Required |
Recommended |
D. Use a variety of methods to help prevent information compromise.
- Use a properly configured and currently patched firewall.
- Actively monitor systems using Anti-virus software that is updated daily.
- Actively monitor systems using Anti-spyware that is updated daily.
- Obtain automatic security updates, and implement them expediently.
- Click “No” if your web browser offers to save passwords. Alternatively, turn off the password saving feature in the browser.
- Be aware of the risks to privacy of information when using desktop search features like Google Desktop Search.
|
Required |
Required |
Required |
E. Physical protection from theft, loss, or damage must be utilized for mobile devices that can be easily moved such as a PDA, thumb drive, or laptop.
- Select portable device models that provide security options to protect information stored on the drive.
- For example, Personal Data Assistants (PDAs) may be set to require a password when turned on or are inactive for a few minutes.
- Enable pass-codes and inactivity timers on mobile devices that support them.
- Employ whole disk encryption on mobile computers (where the encryption method and key strength level are approved by IT Security).
|
Required |
Required |
Recommended |
F. When evaluating new software or appliances, request a security review of the proposed items by the IT Security Office BEFORE purchasing or installing.
- The request to ITSO should be in writing, signed by the purchasing authority, prior to final selection of vendors or products.
|
Required |
Strongly Recommended |
Strongly Recommended |
G. When making a change to a service, system, or business process, consider whether any currently functioning security measures will be disrupted. All changes or modifications to the standard architecture shall be documented along with any justifications. |
Required |
Required |
Recommended |
H. Conduct regular system backups. Backups help ensure the availability of data necessary to fulfill University responsibilities in the case of device failure, disaster or theft.
- Restoration from backup should be regularly verified.
- Security logs in addition to primary data should be backed up.
- Backup files should be stored at a secure location sufficiently apart from the primary data source/storage so as not to be impacted by an event that might render the original data unusable.
|
Required |
Strongly Recommended |
Strongly Recommended |
I. Immediately contact the local area public safety department if there is a theft of any computer, electronic storage media, portable or personal device containing or that has been used to process University information.
- Also alert the department responsible for the device.
- If you suspect any Private Information was on the stolen device, contact the Information Technology Customer Service Center (785-864-8080). The Information Technology Customer Service Center will notify the KU Privacy Officer and/or the KU IT Security Officer as required by the particular incident.
|
Required |
Required |
Required |
7. Safeguard Information in Storage
|
Level I |
Level II |
Level III |
A. Employ physical protection for all devices (electronic and non-electronic) used to store data.
- Limit physical access, including the ability of the public to inadvertently view the data (i.e., as passersby).
- Filing cabinets & drawers, offices, labs, and suite doors containing data must be locked. Do not leave data on unattended desk tops or leave file drawers unattended and unlocked.
- When not in use, all easily transportable devices should be secured (e.g., in locked cabinets or drawers).
- Users of lap-top and other mobile computing devices need to be particularly vigilant and take appropriate steps to ensure the physical security of mobile devices at all times, but particularly when traveling or working away from the University.
- Electronic media used to store Confidential Information must be secured by password-protected encryption. The encryption method and key strength level must be approved by IT Security.
- Encrypt Confidential Information stored on any portable device (laptop, PDA, smartphone, etc.) or other portable media device (CD’s, DVD’s, floppy disks, USB/Flash/Thumb drives, etc.) and utilize available security features on the device. The encryption method and key strength level must be approved by IT Security.
|
Required |
Required |
Recommended |
B. Store Confidential or Sensitive Information in a separate location when possible. |
Required |
Required |
Not Applicable |
C. Always encrypt Confidential and Sensitive Information prior to storage. Encrypting data helps ensure that if an access control is bypassed, the information is still not readily available. A standard and published encryption standard should be used. The encryption method and key strength level must be approved by IT Security.
- Encrypt media stored off-site or have a documented process to prevent unauthorized access.
|
Required |
Required |
Recommended |
D. Securely store information.
- Limit custody/access to as few people as possible to enhance accountability.
- Document transfers of custody.
|
Required |
Required |
Recommended |
E. Store data on systems that support access control (as described in Section 3 of this policy). |
Required |
Required |
Recommended |
F. Retain Social Security numbers only when required (by a “business-related” purpose) and ONLY in an encrypted file or truncated to last 4 digits.
- The following identification mechanisms should also be handled and protected with care: 1. KU Student ID numbers, 2. KU Employee ID numbers, 3. State of Kansas Employee ID numbers, and 4. the KU Online ID.
|
Required |
Not Applicable |
Not Applicable |
G. Store credit card numbers (electronically or on paper) ONLY with written approval from Financial Services, the E-commerce committee, and the IT Security Office.
|
Required |
Not Applicable |
Not Applicable |
8. Dispose of Information Securely When No Longer Needed
|
Level I |
Level II |
Level III |
A. When retention requirements have been met, records must be either immediately destroyed or placed in secure locations as described in this section for controlled destruction.
- No records that are currently involved in, or have open investigations or audits, or records for which a litigation “hold” has been issued, shall be destroyed or otherwise discarded.
|
Required |
Required |
Required |
B. Review, purge and shred printed documents regularly (in accordance with published destruction schedules).
- Shred documents prior to disposal/recycling.
- Adequately secure any documents that must be stored temporarily prior to shredding so they are not accessible to anyone without authorization.
|
Required |
Required |
Not Applicable |
C. Ensure complete destruction of information on electronic storage media, computers, and portable devices prior to disposal/recycling. Refer to the Electronic Data Disposal Policy and Procedure and the Data Removal from KU-Owned Computers procedure from the KU IT Security Office.
- Securely erase media prior to transfer to another individual or department.
- Securely erase data used for testing once testing is complete.
|
Required |
Required |
Not Applicable |
9. Stay Informed About Information Risks
|
Level I |
Level II |
Level III |
A. Ensure attendance at information awareness training provided by the University.
- Course 1, Module 1 for any new employee BEFORE granting access to Confidential or Sensitive data.
- Refresher courses every year thereafter.
- Certain categories of staff may have additional training requirements.
- For more information, including upcoming scheduled courses, reference the Information Management Program.
|
Required |
Required |
Required |
EXCLUSIONS OR SPECIAL CIRCUMSTANCES:
Exceptions to this Procedure shall only be allowed if previously approved by the KU Information Technology Security Office and this approval is documented and verified by the Vice Provost for Information Technology. Exceptions to this Procedure shall only be allowed if previously approved by the KU Information Technology Security Office and this approval is documented and verified by the Vice Provost for Information Technology.
CONSEQUENCES:
Faculty, staff, and student employees who violate this University policy may be subject to disciplinary action for misconduct and/or performance based on the administrative process appropriate to their employment.
Students who violate this University policy may be subject to proceedings for non-academic misconduct based on their student status.
Faculty, staff, student employees, and students may also be subject to the discontinuance of specified information technology services based on the policy violation.
CONTACT:
Office of the Chief Information Officer
1001 Sunnyside Avenue
Lawrence, KS 66045
785-864-4999
kucio@ku.edu
APPROVED BY:
Provost and Executive Vice Chancellor
APPROVED ON:
2009-01-15
EFFECTIVE ON:
2009-01-15
REVIEW CYCLE:
Annual (As Needed)
RELATED STATUTES, REGULATIONS, AND/OR POLICIES:
KU General Privacy Policy
Data Classification and Handling Policy
Student Records Policy
Information Technology Security Policy
Electronic Data Disposal Policy
Electronic Data Disposal Procedure
Data Removal from KU-Owned Computers
Internet-Based Credit Card Processing Policy
Password Policy
Acceptable Use of Electronic Information Resources
Procedures for Investigative Contact by Law Enforcement
Electronic Mail (Email) Policy
Gramm-Leach-Bliley Student Financial Information Security Program
Clinic Policies and Procedures Regarding Privacy & Security of Patient Information
KU General Records Retention Schedule
Telecommunications Wiring Policy
Wireless Local Area Network Systems Policy & Guest Access to Wireless Network
Virtual Private Network Policy
Access to Financial System
Access to HR System
Access to Student System
RELATED OTHER:
Laws:
Family Educational Rights and Privacy Act (FERPA), 20 USC 1232g
Health Insurance Portability and Accountability Act (HIPAA), P.L.104-191 (1996)
Gramm-Leach-Bliley Financial Services Modernization Act (GLB) P.L. 106-102, 113 Stat. 1338 (1999)
Electronic Communications Privacy Act of 1986 (ECPA), 18 USC 119
USA Patriot Act, P.L. 107-56 (2001)
Computer Fraud & Abuse Act, 18 U.S.C. §1030
Kansas Open Records Act, K.S.A. 45-215 et seq.
DEFINITIONS:
Whole disk encryption: for encrypting all data stored on a computer disk volume or partition.
Private Information: an overarching term used to indicate all Confidential and Sensitive information as defined below. Private Information includes all information protected by state and/or federal law or that the University is contractually obligated to protect. Private Information also includes information designated by the University as Private (Confidential or Sensitive) through the creation of standards, procedures and guidelines. Access to these data must be tightly monitored.
Confidential Information: a subset of Private Information that includes information protected by state and/or federal law and information that the university is contractually obligated to protect. \The mishandling of Confidential Information may impact the University through financial and legal sanctions, loss of public confidence, and damage to the University’s reputation. Examples of Confidential Information include Social Security numbers, bank account information, BPC account numbers, healthcare records, educational records, and risk assessments that highlight potential weaknesses in the University’s utility/service infrastructure.
Sensitive Information: a subset of Private Information that includes non-public information (other than Confidential Information) that may cause harm to the University or to individuals if inappropriately used or disclosed. This category includes, for example, research data with commercial or societal value, and individual works of intellectual property.
Public Information: includes information developed for public access. If this information is disclosed, there is no risk of damage to the University’s reputation.Some examples include:
- Publicly accessible web pages
- Campus maps
- University application forms and brochures
CHANGE HISTORY:
03/26/2025: Migration to TeamDynamix from Drupal.
01/26/2022: Updated contact section.
04/16/2021: Updated references from Comptroller to Financial Services.
06/02/2017: Fixed broken link.
11/04/2014: Policy formatting cleanup (e.g., bolding, spacing).
06/11/2009: Updated to reflect Legislative Post Audit requirements.