Data Classified as Critical or Confidential
A privacy review for data classified as confidential or critical is a significant step in ensuring the security and protection of sensitive information. Below is a general process you can follow, but please keep in mind that specific requirements may vary depending on your function and goals, location, and applicable regulations. Always consult legal and privacy experts for advice tailored to your specific situation.
These is a privacy checklist. There may be other security and compliance requirements that may also need to be addressed when evaluating the use of new services or technology.
- Data Classification and Inventory:
- Identify all data classified as critical and/or confidential. This may include personal information, financial records, trade secrets, proprietary algorithms, etc.
- Maintain a comprehensive inventory of this data, including its location, access permissions, and usage.
- Risk Assessment:
- Conduct a thorough risk assessment to identify potential vulnerabilities and threats to the confidentiality of the data.
- Consider factors like the nature of the data, origination and ownership of the data, physical location of data and equipment, potential impact of a breach, and likelihood of a breach occurring.
- Legal and Regulatory Compliance:
- Ensure that the processing and storage of confidential data complies with relevant laws, regulations, and Texas A&M policies and procedures (e.g., GDPR, HIPAA, CCPA, etc.).
- Access Controls:
- Implement strict access controls. Only individuals who require access to perform their job functions should have it, and their access should be regularly reviewed and updated.
- Encryption:
- Ensure that confidential data is encrypted both in transit and at rest. This includes using technologies like SSL/TLS for communication and encryption protocols for stored data.
- Secure Storage:
- Store confidential data in secure environments, such as encrypted databases or secure file systems. Implement strong physical and logical security measures.
- Data Retention and Disposal:
- Refer to Texas A&M Security and Records Management controls for information on data retention and secure disposal of data. If controls don’t currently exist for the type of data involved, establish policies for how long confidential data should be retained. Develop procedures for secure disposal or anonymization of data once it is no longer needed.
- Monitoring and Auditing:
- Implement monitoring tools and procedures to track access to confidential data. Regularly audit and review logs for suspicious activities.
- Employee Training and Awareness:
- Provide comprehensive training to all employees who have access to confidential data. Make them aware of their responsibilities and the potential consequences of mishandling it.
- Vendor and Third-Party Management:
- If applicable, ensure that any third parties or vendors who have access to confidential data adhere to similar privacy and security standards, and that appropriate contractual obligations are in place.
- Incident Response Plan:
- Develop a clear and well-documented incident response plan for handling data breaches or unauthorized access incidents. This should be done in conjunction with IT Security.
- Testing and Validation:
- Regularly test and validate the security measures in place. This may involve penetration testing, vulnerability assessments, and security audits. This should be done in conjunction with IT Security.
- Documentation and Record Keeping:
- Keep thorough records of the privacy review process, including policies, procedures, risk assessments, and any incidents or breaches that occur. Work with the TAMU Privacy Officer.
- Continuous Improvement:
- Regularly review and update your privacy policies and procedures to adapt to new threats, technologies, and regulatory changes. Work with the TAMU Privacy Officer.
- Compliance/Privacy/Security Review:
- Have your privacy practices and policies periodically reviewed by the TAMU Privacy Officer to ensure ongoing compliance.