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Definitions of Confidential and Sensitive Information (CSI)
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Policy
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| Document Number: REDFLAG--102 |
Revision #: 1.0 |
| Document Owner: Executive VP |
Date Last Updated: 08/17/2012 |
| Primary Author: Executive VP |
Status: Approved |
Date Originally Created: 12/14/2011 |
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General Description
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Description:
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Information about confidential and sensitive information (CSI).
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Purpose:
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Delineation of policy and definitions.
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Scope:
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All faculty, staff, students, and administrators
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Responsibility:
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Administration
Executive VP
VP of Business and Finance
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Requirements
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Relevant Knowledge:
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In order to comply with this policy you should know:
Current University policy
Federal statutes
Standard company policies
Standards of good practice
State statutes
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Terms and Definitions:
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Additional training
Corrective Action
Fine
Loss of privilege, general
Termination
Staff members who knowingly and blatantly violate this policy may be terminated.
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Policy Provisions
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1.
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Definitions of Confidential and Sensitive Information (CSI)
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Confidential and Sensitive Information includes, but is not limited to, the following identifiers whether contained in hard copy or electronic format.
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1.1
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| 1. |
Social Security Number |
| 2. |
Social Insurance Number |
| 5. |
Drivers License Information |
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Professional License Information |
| 7. |
Paychecks, Pay stubs, Pay rates |
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1.2
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Credit Card Expiration Dates |
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Credit Card CCV Numbers |
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Bank/Credit Union Account Numbers |
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1.3
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| 2. |
Doctor Names and Claims |
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Health, Life, Disability Insurance Policy Information |
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Prescription Information |
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1.4
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| 2. |
Proprietary Information |
| 8. |
Access Numbers / Passwords |
| 9. |
Customer, Student, Patient Identifiers |
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2.
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An account is a body of information, or a record, or an individual, group, or entity that is kept for the purpose of transacting on an on-going basis with another individual, group, or entity. The terms accounts and records are used interchangeably because they share similar functions and characteristics. Both contain identifiable information on an individual,
group, or entity. They each allow for access to products or services, and keep a history of transaction activity.
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3.
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Both new and existing accounts where a continuing relationship exists between the University and an individual, group, or entity are considered covered accounts. There are two definitions.
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An account that the University offers or maintains, primarily for personal, family, or household purposes, that involve or is designated to permit multiple payments or transactions. Examples include a credit card account, tuition and fee payment, bookstore purchases, and/or other financial transactions of matriculated and non-matriculated students and of employees. |
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Any other account that the University offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety of the financial institution or creditor from identity theft, including financial, operational, compliance, reputation or mitigation risks. |
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4.
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Electronic or Soft Copy Format
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Electronic or Soft Copy Format refers to any Confidential and Sensitive Information that exists electronically on CDs, DVDs, phones, computers, networks, portable devices, etc.
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5.
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Hard Copy Format refers to any Confidential and Sensitive Information that exists physically on paper.
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6.
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A physical access zone is a clearly defined physical or implied boundary established to control and limit access to CSI areas.
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7.
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Red Flags are patterns, practices, or specific activities involving covered accounts that indicate the possible risk of identity theft.
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8.
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A service provider is any individual, group, or entity that directly provides a service to the University or on behalf of the University for its customers or clients.
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9.
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Spoken Word refers to the transfer of Confidential and Sensitive Information verbally or audibly through electronic media.
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Performance Evaluation
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Performance Metrics:
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Compliance with standard policy and procedure
Compliance with federal mandate
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Consequences:
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Further training
Job Termination
Loss of privileges
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Subject Experts
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The following may be consulted for additional information.
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Executive VP
VP of Business and Finance
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