Third-Party Data Transfer Policy
Version 1.6
For Students, Faculty, Staff, Guests, Alumni
Purpose
The purpose of this policy is to ensure that the data transmitted or transferred between University IT Resources and a third party is secure and documented for audits.
Scope
This IT policy, and all policies referenced herein, shall apply to all members of the University community, including faculty, students, administrators, staff, alumni, authorized guests, delegates, and independent contractors (the “User(s)” or “you”) who use, access, or otherwise employ, locally or remotely, the University’s IT Resources, whether individually controlled, shared, stand-alone, or networked.
Policy Statement
- Users must submit a service request to initiate a third-party data transfer per the Third-Party Data Transfer Procedure.
- Data transmission to or from the University to a third party must be reviewed and approved by Information Security and Assurance (ISA).
- Any third-party vendor that stores the University’s data must have a signed contract with the University.
- A secure transmission method must be used as specified in the Data in Transit Policy.
- ISA has final approval on the requested protocols as reflected in the Data in Transit Policy.
Definitions
IT Resources include computing, networking, communications, application, telecommunications systems, infrastructure, hardware, software, data, databases, personnel, procedures, physical facilities, cloud-based vendors, Software as a Service (SaaS) vendors, and related materials and services.
Related Policies and Procedures
- Data Classification Policy
- Data Classification Guidelines
- Data in Transit Policy
- Third-Party Data Transfer Procedure
Implementation History
| Review Frequency | Triennial |
|---|---|
| Responsible Person | Senior Director, IT Security Operations and Assurance |
| Approved By | CISO |
| Approval Date | October 1, 2018 |
| Version | Date | Description |
|---|---|---|
| 1.2 | 01/15/2016 | Supersedes September 1, 2009 version |
| 1.3 | 01/01/2018 | Supersedes the January 15, 2016, version |
| 1.4 | 01/16/2020 | Updated policy statement |
| 1.5 | 02/22/2021 | Updated purpose and policy statements |
| 1.6 | 03/04/2024 | Updated purpose, scope, policy statement, and disclaimer |
Policy Disclaimer Statement
Deviations from policies, procedures, or guidelines published and approved by Information Security and Assurance (ISA) will only be considered cooperatively between ISA and the requesting entity with sufficient notice to allow for conducting appropriate risk analysis, documentation, review, and notification to authorized University representatives where necessary. Failure to adhere to ISA written policies may be met with University sanctions up to and including dismissal.