Loyola University Chicago

- Navigation -

Loyola University Chicago

Information Technology Services

Cloud Computing Policy

Scope:

This policy applies to all persons accessing and using 3rd party services capable of storing or transmitting protected or sensitive electronic data that are owned or leased by Loyola University Chicago, all consultants or agents of Loyola University Chicago and any parties who are contractually bound to handle data produced by Loyola, and in accordance with University contractual agreements and obligations.

Purpose:

The purpose of this policy is to ensure that Loyola Protected or Loyola Sensitive data is not inappropriately stored or shared using public cloud computing and/or file sharing services. Cloud computing and file sharing, for this purpose, is defined as the utilization of servers or information technology hosting of any type that is not controlled by, or associated with, Loyola University Chicago for services such as, but not limited to, social networking applications (i.e. blogs and wikis), file storage (drop box), and content hosting (publishers text book add-ons).  A list of acceptable and unacceptable cloud services are listed in the appendix at the end of this policy.

Reason for Policy:

This policy endorses the use of cloud services for file storing and sharing 1) with vendors who can provide appropriate levels of protection and recovery for University information, and 2) with explicit restrictions on storage of University Protected Information.  While cloud storage of files can expedite collaboration and sharing of information anytime, anywhere, and with anyone, there are some guidelines that should be in place for the kind and type of university information that is appropriate for storing and sharing using these services.  Even with personal use, one should be aware of the level of protection available for your data using such a cloud service.

Federal and State laws and regulations place a premium on institutions’ ability to understand the risks of IT services and systems and make appropriate determinations about risk tolerance.  Some cloud providers, for instance, might mine data for marketing purposes.Covered laws and regulations are listed in the Loyola University Data Classification Policy.

There are a number of information security and data privacy concerns about use of cloud computing services at the University. They include:  

Policy:

The following table outlines the data classification and proper handling of Loyola data.

Data Classification

Cloud Storage

(See appendix for approved services)

Network Drive

(LUC ID and Password Required)

Local Storage

Loyola Protected

Not Allowed

Allowed

No special requirements, subject to any applicable laws

Not Allowed

Loyola Sensitive

Allowed But Not Advised

Requires Dept. Manager approval

Allowed

No special requirements, subject to any applicable laws

Allowed But Not Advised

Requires Dept. Manager approval

Loyola Public

Allowed

No special requirements

Allowed

No special requirements

Allowed

No special requirements

Use of central and departmental servers, where LUID authentication is required, is the best place to store all categories of Loyola data, particularly Loyola Protected data. It is never acceptable to store Loyola Protected data on any cloud service.  This includes data such as grades, social security numbers, private correspondence, classified research, etc. 

Definitions:

Loyola Protected Data - Any data that contains personally identifiable information concerning any individual and is regulated by local, state, or Federal privacy regulations.

Loyola Sensitive Data - Any data that is not classified as Loyola Protected Data, but which is information that Loyola would not distribute to the general public.

Loyola Public Data - Any data that Loyola is comfortable distributing to the general public.

General Data Protection Terms:

The University must specify particular data protection terms in a contract with a cloud-computing vendor. In this way, the University creates a minimum level of security for University data. A minimum level of security ensures that the University data is kept confidential, is not changed inappropriately, and is available to the University as needed.

The University should consider the following contract terms to ensure a minimum level of information security protection: 

Compliance with Legal and Regulatory Requirements:

The University has many federal laws that it must follow, these include the Family Educational Rights and Privacy Act of 1974 (FERPA), the Health Insurance Portability and Accountability Act (HIPAA), and the Gramm-Leach-Bliley Act (GLBA).   

State laws may also affect a relationship with a cloud-computing vendor. For instance, the Illinois Personal Information Protection Act (IPIPA) requires that the University must follow rules about disclosing Social Security Numbers as well as specific security breach notification procedures. 

NOTE: A relationship with a cloud-computing vendor may also be impacted by private industry regulations. For example, departments at the University that accept credit cards also must follow the Payment Card Industry (PCI) Data Security Standard (DSS) issued by the major credit card companies. 

Finally, cloud-computing services that use, store, or process University data must also follow applicable University policies.  Such policies may include Information Technology Services policies and the University's data handling requirements.

Exit Strategy:

Cloud services should not be engaged without developing an exit strategy for disengaging from the vendor or service and integrating the service into business continuity and disaster recovery plans.  The University must determine how data would be recovered from the vendor.

Policy Adherence:

Failure to follow this policy can result in disciplinary action as provided in the Staff Handbook, Student Worker Employment Guide, and Faculty Handbook. Disciplinary action for not following this policy may include termination, as provided in the applicable handbook or employment guide.

Related Documents:

Acceptable Use Policy for Electronic University Resources

Ownership and Use of Data

Data Classification Policy

Electronic Security of Loyola Protected & Sensitive Data Policy

 

Appendix:

Listing of Cloud Services

This listing is meant to serve only as a partial list of cloud services.

Services Approved

for University Use

Services Not Approved

for University Use

Box – Using UVID only

Dropbox

 

iCloud

 

Amazon Cloud Drive

 

Google Drive

 

Microsoft OneDrive

Individuals who use enterprise Box accounts for university work are responsible for ensuring that Loyola Sensitive information is not placed or stored in unapproved or inappropriate locations. When using Box for institutional information, use it only for institutional information classified as Loyola Public or Loyola Sensitive. Pay special attention to access levels when sharing files and folders with other collaborators to ensure that data is not inappropriately shared.  You should not use your enterprise Box account to collect, process, or store data covered by laws such as HIPAA, FERPA, FISMA, and GLBA.

Contractual Expectations

The University will seek and endorse vendors who deliver solutions that meet the following requirements.

Both the University and cloud-computing vendor must declare the type of data that they might transfer back and forth because of their relationship. A contract must have clear terms that define the data owned by each party. The parties also must clearly define data that must be protected.

The contract must specifically state what data the University owns. It must also classify the type of data shared in the contract according to the University’s classification schema: Public, Sensitive, or Protected. Departments must exercise caution when sharing University-classified sensitive or protected data within a cloud computing service.

The contract must specify how the cloud-computing vendor can use University data. Vendors cannot use University data in any way that violates the law or University policies.

References:

This policy is a production of individual thought and a collaboration of multiple public works including portions of policies and guidelines from: Western Michigan University, EDUCAUSE, and Internet2 Consortium.

Questions about this policy:

If you have questions about this policy, please contact the University Information Security Office at DataSecurity@luc.edu.

History:

August 31, 2012: Initial Policy Created
September 13, 2012: Policy Approved
July 7, 2013: Annual review for PCI Compliance
June 4, 2014: Annual review for PCI Compliance

Loyola

Information Technology Services
1032 W. Sheridan Ave. · Chicago, IL 60660 · 773.508-4ITS

InfoServices@luc.edu

Notice of Non-discriminatory Policy