UC Santa CruzInformation Technology Services

Model for Social Security Number Scanning on Campus Systems

Printer-friendly format (PDF, 20K)

General Methodology for Performing Scans for Personal Identity Information (PII) Data, e.g. SSN

Users:

Users may scan their own systems for PII data.

Scan results may contain PII and must be protected and disposed of accordingly.

Service Providers and Unit/Departmental Managers:

Prior to performing a scan for PII data on any system, Service Providers or Unit/Departmental Managers must

  • Provide advance notification of the scan to all individuals, managers and system stewards whose data will be scanned
  • Provide an option for individuals to request an exemption from the scan, to remove or exclude personal or electronic communications files from the scan, and/or to choose to scan their own systems themselves
    • Advance notification must be sufficient to realistically allow individuals to exercise these options.

Service Providers and Unit/Departmental Managers must adhere to the following agreements with respect to scan results:

  • Assure a practice of least perusal and retention of scan results
  • Consult with user/data owner (if known) on scan results indicating potential PII
  • Proper protection and disposal of scan results

UCSC IT Security:

As part of UCSC’s standard IT incident response procedure, UCSC IT Security is authorized to scan for PII data on any system in response to a security breach or compromise. The system steward (or the data owner in the case of a non-shared system) shall be notified prior to performing the scan. IT Security must adhere to the above agreements with respect to scan results as applicable to a given security investigation.


Authorization for Performing Scans for PII Data

Individuals:

Individuals are authorized to scan their own systems for PII data.

Service Providers:

Service Providers are authorized to scan for and access PII data on systems for which they have administrator privileges, with the permission of the system steward or data owner.

  • Note: for departmental systems or servers with shared data, the system steward is the departmental manager.

Unit/Departmental Managers:

Unit/Departmental Managers are only authorized to scan departmental systems for which they are the system steward, and must comply with the terms outlined above for these scans. Unit/Departmental Managers are not authorized to scan other systems, including individual users’ systems, without the explicit consent of all parties whose data will be scanned.

UCSC IT Security:

UCSC IT Security is authorized to scan for PII data on any system in response to a security breach or compromise as part of UCSC’s standard IT incident response procedure.


Related UC Policy

University of California Electronic Communications Policy (ECP):

Rev. 4/13/06