As individual custodians of the university's sensitive data, faculty, staff, and U-M workforce members are responsible for complying with
- Applicable laws, statutes, and regulations (see Sensitive Data Policies & Regulatory Compliance)
- U-M information security and institutional data management policies and procedures
These policies apply to university owned and managed computers as well as to personally owned devices used to access sensitive university data. You are responsible for the following areas:
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Access Only the Data You are Authorized to Access
Don't request access unless you truly need it.
Before requesting access to systems that maintain sensitive institutional data, U-M faculty, staff, and Michigan Medicine workforce members are asked to:
- Complete an online course, Access and Compliance 101: Handling Sensitive Institutional Data at U-M. (U-M login required)
- After completing the course, they must agree to and submit online the Institutional Data Access and Compliance Agreement.
- Once these two steps are completed, they can submit an access request.
Remove access when no longer appropriate.
When people no longer have any affiliation to the university, they lose access to U-M standard computing services after a grace period. Departments and units are expected to initiate removal of administrative, elevated, and departmental access as part of the university's off-boarding process, whether the person leaves the university entirely or just leaves a role or job within it. For details, see
Work With Data Responsibly
Specific types of data may have special rules and/or laws for handling.
If you use personal devices with sensitive data, you will have extra responsibilities.
If you work with sensitive institutional data from your own devices or from self-managed devices (for example, devices purchased for research purposes with grant money that are not managed by your department's IT staff), you are expected to secure and properly manage them to protect that data. For details, see: Your Responsibilities for Protecting Sensitive Data When Using Your Own Devices.
Never use personal accounts to maintain or share the university's sensitive data.
Personal accounts are those you sign up for yourself for your own use. These are different from accounts that the university makes available to you and for which it has a contract with the vendor, such as Box or Google.
See Use of Personal Accounts and Data Security for more information.
Store Data in the Appropriate Places
Learn where specific types of data can be safely stored.
The Sensitive Data Guide is an interactive tool to assist faculty, staff, and researchers in making informed decisions about where to safely store and share sensitive data using IT services available on the UM-Ann Arbor campus. It is particularly important to be careful with cloud computing resources; see also Safely Use the Cloud.
If you use Box at U-M, learn how to use it securely.
Properly Manage Devices Used with Sensitive Data
Follow device security rules.
Be sure the equipment you are using to interact with sensitive data is being properly secured to work with it. See Manage Your Workstation.
If you are interacting with sensitive data on a personal device, you will also need to review:
Securely dispose of media that has ever held, stored, or transmitted sensitive data.
When you are done with computers, other devices, hard drives, DVS, scanners, etc. that have interacted with sensitive data, you must take special care to dispose of them properly, since that data may still be recoverable. See Securely Dispose of Media for instructions.
Report a Breach or Compromise of Sensitive Data
Don't wait to gather evidence or resolve it yourself; report immediately if you suspect a breach.
Immediate reporting of a suspected breach:
- gives security staff the best chance to mitigate any possible negative outcomes
- is a U-M policy: Information Security Incident Reporting (SPG 601.25)
See Report an IT Security Incident for details.
Get Help from these U-M Offices If Needed
Human Resource Records and Information Services
Human Resource Records and Information Services (HRISS) is the data steward of employment data for the university. It is responsible for developing and maintaining the university's human resource information system, maintaining faculty and staff records, providing information services to the university community and external agencies, and delivering customer support for benefits and other HR-related items. The HRRIS team is available for individual consultations with business and academic units.
Michigan Medicine Compliance Office
The Michigan Medicine Compliance Office promotes compliance with all laws/regulations governing health care billing, coding, Medicare and Medicaid, patient privacy and information security, relationships and conflict of interest, and governmental investigations.