Sensitive Data Storage Best Practices

As an employee of SDSU, you are responsible for all university data that is sent, stored, or shared on all personal or university-owned devices that you use. Part of this responsibility includes choosing appropriate technology to manage and store the data, some of which may be confidential or restricted.

We have multiple options for data storage — from University servers to cloud-based services — but not all options are appropriate for all types of data. To help you choose the proper solutions for your university data, we've developed a matrix that outlines what can be stored where.

Sensitive Data Storage Classification

Information in the matrix below applies only to SDSU enterprise versions of the services. SDSU Data must never be stored in a consumer personal Gmail account e.g., [email protected]

The CSU Information Security Data Classification standard provides three levels of data classification regarding the level of security placed on the particular types of information assets.

This list below is not exhaustive and should only be used as a reference for purposes of data protection. Data protection is the implementation of administrative, technical, or physical measures to guard against unauthorized access to data.

Protected Level 1 (PL-1 Confidential)

  • HIPAA: ePHI, Personal Health Records, Health Insurance Data
  • Personally Identifiable Information (PII): Name with Personally Identifiable Information SSN, Passport, Visa, etc.
  • Gramm-Leach-Bliley Act (GLBA): Name with Financial Information, Bank Accounts, Tax Returns, etc.
  • Payment Card Industry Data Security Standard (PCI-DSS): Payment card information, Credit Card Numbers, Bank Account and Routing Numbers.
  • Law Enforcement Records: Name with Driver’s License, Criminal Background.
  • Campus Access Credentials: Passwords or credentials that grant access to level 1 and level 2 data.

Protected Level 2 (PL-2 Internal Use)

  • FERPA: Student Information: Educational Records not defined as directory” information, typically: Grades, Courses taken, Schedule, Test Scores, Advising records, Educational services received, Disciplinary actions, Student photo.
  • Campus Financials.
  • Campus Attorney-client communication.
  • Employee Information: Name with: Home Address, Home Phone, Personal Email, Marital Status, Gender, Evaluation, Personnel Actions.

Protected Level 3 (PL-3 General)

  • Information publically available Publications Web: The information which may be designated as publically available and/or intended to be provided to the public.

Sensitive Data Storage Matrix

How to interpret the Matrix

Use Permitted There are no technical, policy or contractual issues that prohibit the storing and sharing of this data type with appropriate intended users using this service. If you have questions about who you can share data with, contact the data owner.

Use Restricted Use of this service with the regulated data type is restricted and special approval and additional controls are needed. Please contact the IT Security Office at [email protected] for more information.

Use Prohibited Use of this service with the regulated data type is prohibited. Do not use this service to send, store or share the regulated data type.

IT Tools and Services to Store or Share CSU Protected Data
Storage Location Description Protected level 1 (PL-1) Protected level 2 (PL-2) Protected level 3 (PL-3)
Google Drive An enterprise solution that allows faculty/staff users to store, share and edit files as part of Google G Suite. Temporarily*
OneDrive for Business An enterprise service that allows students, faculty, and staff to store, share and edit files within online Office apps as part of Microsoft Office 365.
SharePoint An online collaboration space that is part of Office 365.
IT Network File Shares Network drives only accessible on the SDSU network and managed by SDSU IT Staff. **
University-owned devices Local Workstation or Laptop managed by SDSU.
Non-University-owned devices Personal Computers or devices not owned or managed by SDSU.
Portable Storage Thumb drives, portable hard drives or any other portable device that is capable of storing files.
Azure Files / Azure File Sync Cache Azure file shares on Windows Servers with Azure File Sync for local access performance.
* The Campus has put in additional safeguards for the temporary use of Google Drive during our response to COVID19. Please, review the following guide, "Security Guidance for Storing and Sharing Protected Data," to keep secure the files stored in Google Drive.
** With the review and approval of the Security office. Please contact the Security office at [email protected] for more information.

Notes

  • The Regulated Data Storage Matrix does not necessarily apply to data associated with faculty research. Research data that involves regulated data should have a Data Management Plan and should fulfill the security requirements of the granting agency as well as the policies and standards of SDSU.
  • The Regulated Data Storage Matrix only indicates if appropriate technical safeguards and contractual protections are in place for storing or sharing regulated or confidential data using a particular technology.