黑料视频

Purpose

The University will provide timely and appropriate action in response to suspected or confirmed breaches of university data. This standard outlines procedures for reporting, investigating, and notifying affected individuals in accordance with state and federal laws, contractual obligations, and industry best practices. Prompt and coordinated response minimizes risk, ensures legal compliance, and supports individuals whose personal information may have been compromised.

Scope

This standard applies to all 黑料视频 faculty and staff members that have a responsibility to respond to a data breach.

Standard

Where a breach of university data is suspected, University employees and students, or other individuals, must report incidents to the Office of Information Technology (OIT) Information Security Office (ISO), via the ISO website鈥檚 Report Information Security Incidents.

Upon report of an incident, the ISO will begin investigating the incident in accordance with the Information Security Incident Response Standard and report the results of the investigation to the Chief Information Security Officer.

The CISO, in consultation with the University Privacy Officer, and the Office of Legal Affairs is responsible for determining:

1. Whether a breach of information security or sensitive university data has occurred and

2. Whether notification to affected individuals is required, based upon state and federal laws.

The CISO may also seek advice from other key administrators responsible for security and privacy at the University and consult with responsible administrators in the affected campus, area, or unit.

The CISO and the ISO will work with the responsible departments to facilitate the required notifications in accordance with . All notifications must be reviewed and approved by the University Privacy Officer prior to the distribution or recordation of the notification.

Responsibilities

All Individuals. Report concerns regarding suspected security breaches of sensitive data to University Information Security at security@ohio.edu or via the ISO website鈥檚 Report Information Security Incidents.

Chief Information Officer (CIO). Delegate to the Chief Information Security Officer (CISO) the authority and responsibility for the suspected information security incident and data breach investigation, including but not limited to, the oversight of the notification process, and breach determination, where appropriate.

Chief Information Security Officer (CISO)

• Oversee the information security office staff in their investigation of reported incidents.
• As a result of investigative findings, ensure that appropriate and timely action is taken on suspected information security or data breach.
• Accountable for making determinations, in consultation with the University Privacy Officer and the Office of Legal Affairs as to whether a breach of information security or sensitive data has occurred and whether notification is required.
• Delegate the authority and responsibilities for investigation of the suspected information security and data breach.
• Inform the appropriate University leadership of suspected data breaches.
• Oversee and direct the departments responsible in complying with notification obligations. 

College/Unit Administrators. Provide timely and effective notification to individuals as directed by the Privacy Officer when there has been a security breach of sensitive data in their area. 

University Privacy Officer

• Notify external entities in accordance with the respective privacy law or contract (e.g., Federal Department of Health and Human Services for PHI, or Department of Education for FERPA data).
• Provide privacy advice to the Office of Information Technology and other University staff and decision makers to ensure compliance with breach determination and notification obligations under the privacy law or contract they are responsible for. 

Legal Affairs. Provide legal advice to the Office of Information Technology, University Privacy Officer, and other University staff and decision makers to ensure compliance with breach determination and notification obligations under the law. 

Definitions

Business Associate: An individual (other than an employee or member of the workforce of the Covered Entity) or organization who (i) on behalf of a Covered Entity, creates, receives, maintains or transmits PHI, or (ii) provides legal, actuarial, accounting, consulting, data aggregation, management, administrative, accreditation, or financial services to a Covered Entity and where the provision of the service involves the use or disclosure of PHI. 

Covered Entity: A Health Care Provider, Health Plan, or health care clearinghouse. A Covered Entity also includes those units or components designated as a Hybrid Entity. 

Data Breach: For purposes of this standard this means unauthorized access to, acquisition, use, or disclosure of data maintained by the University, which compromises the security and privacy of the data. 鈥淏reach鈥� does not include (1) good faith acquisition, access, or use of sensitive data by an employee, contractor, or agent of the University, if the data is not provided to an unauthorized person; (2) incidents involving data that have been rendered unusable, unreadable, or indecipherable (e.g., through valid encryption) to unauthorized individuals; or (3) incidents involving data that has been deidentified in compliance with applicable legal requirements.

Information: Data collected, stored, transferred or reported for any purpose, whether in electronic, paper, oral, or other media. 

Private data: University data protected by federal or state law (e.g., FERPA, HIPAA, Ohio Breach Notification Law), regulation, or contract (e.g. PCI DSS for credit cards, some research contracts). 

Protected health information ("PHI"): Information transmitted or maintained in any form or medium (electronic, paper, oral or other) that (i) is created or received by a Covered Entity, (ii) relates to the past, present or future physical or mental health or condition of an individual, the provision of health care to an individual, or the past, present or future payment for the provision of health care to an individual, and (iii) is identifiable to an individual or there is reasonable basis to believe can be used to identify an individual. PHI specifically excludes information of individuals who have been deceased for more than 50 years.

The following records are exempted from the definition of PHI as defined by HIPAA:

• Education records maintained by an educational institution;
• Treatment records about a post-secondary students meeting the requirements of 20 U.S.C. 1232g (4)(B)(iv); and
• Employment records held by a covered entity in its role as employer. 

Unauthorized acquisition: For the purposes of this policy, this means that a person has obtained University private data without statutory authority, authorization from an appropriate University official, or authorization of the individual who is the subject of the data, or with the intent to use the data for unauthorized or non-University purposes. 

References

• Administrative Procedure: Notification of a Data Breach
• Security Incident Response Standard
• Report Information Security Incidents
• University HIPAA Privacy Officer
• HIPAA Standard for HIPAA Compliance Coordinators
• /oit/security/consulting/defining-sensitive-data
• Academic Policy: Managing Student Records
• General Policy: Protected Health Information
• Administrative Policy: Accepting Revenue via Payment Cards
• IT Policy: Acceptable Usage
• Family Educational Rights and Privacy Act (FERPA)
• Payment Card Industry Data Security Standard (PCI DSS)

Exceptions

All exceptions to this standard must be formally documented with the ISO prior to approval by the Information Security Governance Committee (ISGC). Standard exceptions will be reviewed and renewed on a periodic basis by the ISO. 

Request an exception

Complete Exception request form.

Governance

This standard will be reviewed and approved by the university Information Security Governance Committee as deemed appropriate based on fluctuations in the technology landscape, and/or changes to established regulatory requirement mandates.