On this page:
- Confidential Information: The term “confidential information” applies broadly to information for which unauthorized access or disclosure could result in an adverse effect. To address this risk, some degree of protection or access restriction may be warranted.
- Restricted Information or Data: "Restricted information" is UC's term for the most sensitive confidential information. Restricted information or data is any confidential or personal information that is protected by law or policy and that requires the highest level of access control and security protection, whether in storage or in transit.
Examples of Restricted Data
(definitions and reference information follow)
- Personal Identity Information (PII)
- Electronic protected health information (ePHI) protected by Federal HIPAA legislation
- Credit card data regulated by the Payment Card Industry (PCI)
- Passwords providing access to restricted data or resources
- Information relating to an ongoing criminal investigation
- Court-ordered settlement agreements requiring non-disclosure
- Information specifically identified by contract as restricted
- Other information for which the degree of adverse affect that may result from unauthorized access or disclosure is high
Individuals with access to restricted data should, and in some cases are required to, read and sign the UCSC Access to Information Statement (PDF). This Access to Information Statement outlines the rules governing access to protected information at UCSC. Return the signed form to the requester.
- Access to Information Statements required for access to campus systems go to the ITS Support Center (mailstop: ITS-Kerr).
- Forms required by a department should be filed according to departmental procedures.
- Personal identity information (PII) is the electronic manifestation of an individual's first name or first initial, and last name, in combination with one or more of the following*:
- Social Security Number (SSN)
- Driver's license number, or State-Issued ID card number
- Financial account number, credit** or debit card number in combination with any required security code, access code, or password
- Personal medical information
- Health insurance information
**Credit card information is also regulated by the Payment Card Industry (PCI) Data Security Standard. See below
Personal Identity Information (PII) is Protected by State Law and UC Policy
- State Law: California Civil Code (1798.29) requires us to notify people if their unencrypted PII is disclosed without authorization.
- UCSC Policy: UCSC PII Inventory and Security Breach Procedures
- UCSC PII Resources: http://its.ucsc.edu/security/pii.html
- PII training page: http://its.ucsc.edu/security/pii-training.html
- ITS Policy regarding storage and transmission of PII: http://its.ucsc.edu/policies/pii.html
- Patient health information which is computer based, e.g., created, received, stored, maintained, processed and/or transmitted in electronic media. Examples include:
- Medical record number, account number or SSN
- Patient demographic data, e.g., address, date of birth, date of death, sex, email / web address
- Dates of service, e.g., date of admission, discharge
- Medical records, reports, test results, appointment dates
- Special training is required for people who access ePHI. Contact your department for more information.
Electronic Protected Health Information (ePHI) is protected by State and Federal Laws and UC Policy
- State Laws: California Civil Code 1798.81.5: California Information Practices Act, Consumer Records, outlines the definition of and required protections for protected health information.
- Federal Laws: HIPAA Privacy & Security Laws mandate protection and safeguards for access, use and disclosure of PHI and/or ePHI with sanctions for violations.
- HIPAA Security Rule compliance at UCSC: http://its.ucsc.edu/policies/hipaa.html
- HIPAA Information at UCOP: http://www.universityofcalifornia.edu/hipaa/welcome.html
Credit card information is regulated by the Payment Card Industry (PCI) Data Security Standard (DSS).
Description of the PCI Standard
- The PCI DSS is a set of security requirements developed by credit card companies to ensure consistent data security measures for sensitive credit cardholder data. These requirements apply to anyone who stores, processes, transmits or otherwise has access to credit cardholder data. It also applies to all system components included in or connected to or the cardholder data environment.
- System components include network components, servers, workstations, and applications.
- Special training is required for people with access to credit cardholder data. For information see https://financial.ucsc.edu/Pages/Cash_Guide.aspx#PCI_Overview
(ITS employees, see http://its.ucsc.edu/security/training/its-staff.html#pci).
Payment Card Industry (PCI) Data Security Standard References
- PCI Compliance at UCSC: https://financial.ucsc.edu/Pages/Cash_Guide.aspx#PCI_CCGuide
- Payment Card Industry Data Security Standard: https://www.pcisecuritystandards.org/security_standards/index.php
- Payment Card Industry Self-Assessment Questionnaire: Questionnaire designed to determine compliance with the Payment Card Industry Data Security Standard: https://www.pcisecuritystandards.org/merchants/self_assessment_form.php
Most student records are not considered restricted data; they are considered confidential data. The disclosure of information from student records is governed by FERPA.
At UCSC, the Registrar is the authoritative office for FERPA. Refer to the Registrar's website for information about privacy requirements for student records, as well as related resources: http://registrar.ucsc.edu/records/privacy/
- Everyone with access to FERPA-protected information is responsible for protecting its privacy in accordance with FERPA. Employees are expected to review the above website and complete the Registrar's FERPA quiz (also at the above link).
Student records protected by FERPA are protected by both Federal and State laws
- Federal & State Laws: The disclosure of information from student records is governed by FERPA and, in part, by the State of California Education Code.
- Potential consequences include legal or civil action and withdrawal of funds under any program administered by the Secretary of Education.
- Home address or home telephone number
- Personal information protected by anti-discrimination and information privacy laws such as:
- Ethnicity or Gender
- Date of birth
- Marital Status
- Religion or Sexual orientation
- Certain types of student records
- Exams, answer keys, and grade books
- Applicant information in a pending recruitment
- Information subject to a non-disclosure agreement, including research data, intellectual property (IP), patent information and other proprietary data
- Academic evaluations and letters of recommendation
- Responses to a Request for Proposal (RFP) before a decision has been reached
- Some kinds of personnel actions
- "Pre-decisional" budget projections for a campus department (can also be marked "Draft" or "Not for Distribution")
- Practices for protecting electronic restricted data
- UC Business and Finance Bulletin IS-3, Electronic Information Security is a comprehensive Electronic Information Security policy and set of guidelines designed to reduce risks related to maintaining the integrity of electronic information resources. BFB IS-3 applies to all UC campuses and facilities, as well as to their vendors, contractors and business partners.
- IS-3 Assessment Template (Excel download)
- Protection Matrix: This protection matrix identifies protections for information according to its level of sensitivity. This tool identifies protections that should be in place according to law and policy. The purpose of this matrix is to help data owners assess whether current (or, for a new system, planned) protections are adequate or may require remediation or re-thinking.
Encryption can dramatically reduce the risks associated with stored restricted data, and especially PII. Encryption comes with tradeoffs, however. In general, if you lose or forget your encryption key/password, you will lose your encrypted data. Because of this, encryption is considered an at-your-own-risk option. Encrypting local, non-authoritative copies of restricted data that is also stored securely elsewhere is less risky. Work with ITS to determine if encryption is an appropriate option for you. Also see: http://its.ucsc.edu/security/encryption.html
If you are planning a contract that will provide a third party (e.g. contractors and consultants) with sensitive information, or access to UCSC systems or applications that contain sensitive information, be sure to inform Purchasing or Business Contracts so the appropriate data security contract language can be included in the agreement.
It is also strongly recommended that you ensure the vendor has read this contract language in their contractual terms and conditions to ensure they understand their obligations under it.
Rev. Sept 2015