Identifying Confidential Electronic Data - IT Help Desk

Identifying Electronic Confidential Data

Data that are stored or transmitted electronically are considered confidential if their unauthorized release can result in harm to the institution or to individuals. Such harm may include identity theft, legal or financial liability, institutional or personal embarrassment, as well as other consequences. It is the responsibility of all employees of ��ջ� College and others who are empowered to act on behalf of the College to protect confidential data from unauthorized access and/or misuse.

The following guidelines are intended to help you identify data items that should be treated as confidential. However, the lists below are not exhaustive and there are confidential data items that fall outside of these guidelines. If you are uncertain about the confidentiality status of a particular data item, please consult with your supervisor or the Chief Technology Officer.

Identity Theft Material
Employee Information
Donor Information
Student Information
Other Information

Identity Theft Material

Identity theft is the fraudulent use of another's personal information for financial gain or to perpetrate other illicit activity. Unauthorized access to materials that can be used for identity theft can expose individuals to harm and, in certain cases, expose the institution to financial liability, public relations challenges, and other types of problems. This applies to all employees, students, alumni, donors, parents, board members, vendors, and others –– whether they are current, former, or prospective –– whose personal data is electronically stored or transmitted by the College. In conjunction with an individual's name, data related to identity theft include:

Date of birth
Social Security Number
Driver's license/passport/ID numbers
Credit card numbers, expiration dates, PINs
Account numbers (banks, brokerages, utilities, etc.)
Passwords for accounts, databases, and other resources

These items can be found in documents such as tax returns, admissions applications, credit, loan and other types of applications, housing agreements, employment records, student records, financial correspondence, etc.

For more information about ID theft see

Employee Information

In addition to material that can be used in identity theft, other personal data items that are to be treated as confidential include:

Compensation and promotion information
Benefits information
Performance reviews, disciplinary materials, and related documents
Worker's compensation, disability claims, or other medical information

Information on records marked confidentialDonor Information

Activities/events attended
Children/family information
Contact reports
Correspondence history
Gift/Pledge data

If you are authorized to handle donor information, see the College Relations Security Policy at /cris/CR_IS/Documentation/Policy_CRIS_RecordRelease200612.pdf.

Student Information

The Family Educational Rights and Privacy Act, FERPA, gives students four specific rights:

to see the records that the institution is keeping on the student;
to seek amendment to those records and in certain cases to append a statement to a record;
to consent to disclosure of his/her records;
to file a complaint with the FERPA Office in Washington.

For answers to some common questions about FERPA see .

For information about ��ջ�'s FERPA policies, see
/academic/gbook/comm_pol/disclosure.html

Under FERPA the following data items may be not be disclosed unless appropriately authorized:

Grades
Financial aid information
Credit Card Numbers
Bank Account Numbers
Wire Transfer information
Payment History
Student Tuition Bills

In addition, students have the right to restrict disclosure of the following items:

Name
Date of birth
Place of birth
Campus address and phone number
Campus mailbox number
Electronic mail address
Permanent mailing address
Permanent phone number
Secondary mailing address
Semesters of registration at ��ջ�
Full or part-time status
��ջ� major, degree(s) awarded and date(s)
Institution attended prior to ��ջ�
Honors awarded
Participation in ��ջ� College programs
ID card photographs

Under Health Insurance Portability and Accountability Act, HIPAA, the following data may be not be disclosed unless appropriately authorized:

Patient Name
Street address, city, county, zip codeBirth date (except year)
Location or dates of treatment
Contact information: phone, fax, email, etc.
Social security number
Account/Medical record numbers
Health plan beneficiary numbers
Certificate/license numbers
Vehicle ID's & serial numbers
Device ID's & serial numbers
Full face images
Any other unique identifying number, characteristic, or code
Payment guarantor's information

For answers to commonly asked questions about HIPPA see the HHS website:

Other Information

Other data items whose unauthorized use could directly or indirectly harm the institution or individuals include:

Class rosters
Academic records and notes
Human subject data
Materials related to internal or external investigations
Legal documents and records
Financial records, grants, and contracts
Campus security plans and procedures
Storage sites for confidential data
Email containing sensitive information
Meetings minutes, memos, notes, emails, and other materials related to sensitive topics such as personnel matters, student behavior, etc.