In today's universe, protecting confidential data is crucial. VCSU is a custodian of personal information belonging to students, staff, faculty, researchers, and those who use its outreach services. As custodian of that information, VCSU is responsible for protecting and securing personal, student-related, financial, health information, and intellectual property from misuse, theft, compromise, and unauthorized disclosure. As an employee of VCSU it is your responsibility to:
When working with confidential and private data, these best practices must be followed:
Federal and state laws that protect personal data:
State Laws and Other Standards that protect personal data:
NDUS and VCSU Policies and Procedures:
North Dakota University System Data Classification Standard
The North Dakota University System Data Classification Standard was developed to identify and clarify the definition of data types within a university. Any data asset of the NDUS or the Institution shall be classified as Public, Private, or Confidential.
Public data is defined as data that any entity either internal or external to the ND University System can access. The Open Records law of North Dakota may apply. Public data elements include:
Student Directory Information*
Student Directory Information* - This information is public unless the student has requested non-disclosure (suppress).
Home Address* - Considered public information unless employee has requested non-disclosure (suppress).
Home Telephone Number* - Considered public information unless employee has requested non-disclosure (suppress).
Private data includes information that the NDUS or institution is under legal or contractual obligation to protect. Private information may be copied and distributed with the NDUS only to authorized users. Private information disclosed to external authorized users must be done so under a non-disclosure agreement. Private data elements include:
Non-Directory Student Information*
Non-directory Student Information* - May not be released except under certain prescribed conditions
Confidential data is information that is not to be publically disclosed. The disclosure, use, or destruction of confidential data can have adverse effects on the ND University System or the institution and possibly carry significant civil, fiscal, or criminal liability. This designation is used for highly sensitive information whose access is restricted to selected, authorized employees. The recipients of confidential information have an obligation not to reveal the contents to another individual unless that person has a valid "need to know" for the information. Confidential information must not be copied without authorization from the owner. Confidential data elements include:
The owner of the data is the one whom the data belongs to. For example, a person owns his/her social security number, date of birth, and address.
The custodians of such data are employees, departments, colleges, research centers, and extension offices responsible for the integrity, confidentiality and availability of the data. It shall be the responsibility of the owner/custodian of the data to classify the data. However, all individuals accessing data are responsible for the protection of the data at the level determined by the owner/custodian of the data as mandated by law. Any data not yet classified by the owner/custodian shall be deemed Confidential. Access to data items may be further restricted by law, beyond the classification systems of the NDUS or VCSU.
Social Security Numbers
Do not use SSNs as a key field or as an identifier for files, spread sheets, data bases, and correspondence. If possible, it is recommended to avoid including the SSN in any type of file or document. An alternative would be to use the EmplID or Student ID.
If there is a business need to use the SSN in files and documents, the data must be secured and available only to those who have a need to know.
If you use a laptop and travel, it is recommended the hard drive of the laptop's hard drive be encrypted.
Never attach documents containing SSN's or other personally identifiable information to email. It is possible the transmission may not be secure.
Credit Card Information
Credit card information is protected under the Payment Card Industry Data Security Standards and by various federal and state laws. When accepting, using, and storing credit card information, these guidelines must be followed.
VCSU uses a secure third party service provider, TouchNet, to accept credit cards payments. Please contact the Director of Business & Financial Services for more information on how to use this service.
Sponsor: Vice President for Business Affairs
Effective: May 1, 2009