Appendix A: Data Classification

This appendix attempts to identify the individual elements of data categorized as either personally identifying or business sensitive.

I. Directory Information

The specific data elements that the University considers directory information is maintained in the definitions section of UD’s Policy on Disclosure of Student Records ("FERPA" Policy) at http://www.udayton.edu/policies/enrollment/ferpa/ferpa_policy_page.php.  The University is allowed, but not obligated, to divulge this information without student consent unless the student specifically opts out.

II. Personally Identifying Information

The following data elements fall into the category of personally identifying and are further categorized by applicable regulation:

HIPAA: Protected Health Information (http://www.hhs.gov/ocr/hipaa/)

Federal law protects the health records and privacy of individuals. The Privacy Rule establishes minimum standards for protecting the privacy of individually identifiable health information. Individually identifiable health information, somewhat confusingly, includes elements such as name that would normally be considered directory information. The following 18 elements (http://privacyruleandresearch.nih.gov/pr_08.asp#8a) could be used to identify the individual or the individual's relatives, employers, or household members.

• Names
• All geographic subdivisions smaller than a state, including street address, city, county, precinct and ZIP Code, and their equivalent geographical codes, except for the initial three digits of a ZIP Code if, according to the current publicly available data from the Bureau of the Census:
• The geographic unit formed by combining all ZIP Codes with the same three initial digits contains more than 20,000 people
• The initial three digits of a ZIP Code for all such geographic units containing 20,000 or fewer people are changed to 000
• All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older
• Telephone numbers
• Facsimile numbers
• Electronic mail addresses
• Social security numbers
• Medical record numbers
• Health plan beneficiary numbers
• Account numbers
• Certificate/license numbers
• Vehicle identifiers and serial numbers, including license plate numbers
• Device identifiers and serial numbers
• Web universal resource locators (URLs)
• Internet protocol (IP) address numbers
• Biometric identifiers, including fingerprints and voiceprints
• Full-face photographic images and any comparable images
• Any other unique identifying number, characteristic, or code, unless otherwise permitted by the Privacy Rule for re-identification

Exceptions to the HIPAA regulations by “educational agencies” are defined at http://www4.law.cornell.edu/uscode/20/1232g.html.

FERPA: Student Records (http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html)

Federal law protects the privacy of student education records. Schools must list what they consider to be directory information. UD assumes all elements of the student record, except for those items listed at the beginning of this appendix, to be confidential. Examples of confidential information include:

• Grades/Transcripts
• Class lists or enrollment information
• Student Financial Services information
• Athletics or department recruiting information
• Credit Card Numbers
• Bank Account Numbers
• Wire Transfer information
• Payment History
• Financial Aid/Grant information/Loans
• Student Tuition Bills

Credit and Debit Cards (https://www.pcisecuritystandards.org/)

Security standards compiled by members of the Payment Card Industry (PCI) Security Council.

• Cardholder Data
• Credit Card Number
• Cardholder Name *
• Service Code*
• Expiration Date*
• Sensitive Authentication Data
• Full Magnetic Stripe**
• CVC2/CVV2/CID**
• PIN/PIN Block** 

* Elements must be protected if stored in conjunction with the credit card number

** Storage is not permitted

III. Business Sensitive

The categories of data listed below, while not necessarily regulated, are considered valuable to the University of Dayton. Loss of this information might lead to embarrassment, risk to safety, competition, etc.

• Donor Information
• Employee information
• Financial Information
• Infrastructure Information
• Management Information
• Research Information

This document is not comprehensive and should be revisited regularly to clearly identify sensitive data elements to all members of the University community. In the case of a breach of any of the elements listed in this appendix, incident response and handling procedures should be initiated through UDit and the IT Risk Management Officer. Questions can be addressed to the responsible office listed in this policy.