Information Security Framework Information Classification and Handling Procedure 1. Why is this important? The University uses large volumes and diversity of information to support its activities and to achieve its strategic aims. Information that the University manages shall be appropriately secured to protect against consequences of breaches of confidentiality, failures of integrity, interruption to availability and failure to comply with legal requirements. In order to protect information consistently, it is necessary to define a University-wide scheme for classifying (describing) information and how it should be handled according to its requirements for confidentiality, integrity and availability. We should classify information so that it is clear to everyone with access to know how best to protect it. Everyone should use the University Information Classification and Handling Procedure. 2. What is the Information Classification and Handling Procedure? The procedure describes how information and systems should be classified and marked, according to their confidentiality, criticality or value. Decisions around the appropriate protection and use of the information in each classification are based on the consequences of the loss or disclosure of the information. The procedure relates to all types of information and formats and applies in particular to staff but also covers students and third parties wherever appropriate. The procedure is a mandatory part of the University Information Security Framework and is overseen by the Institutional Governance Team. The University recognises that there may be legitimate circumstances where it is not possible to adhere to this procedure. In these cases, you must seek advice from the Institutional Governance Team (www.warwick.ac.uk/gov/informationsecurity). 3. What do I need to do? You should assess the sensitivity of the information you create and receive using the table in Annex A; and take proportionate measures to ensure that information is used securely – the key controls for protecting information are available in Annexes B and C. Where information classified as Protected, Restricted or Reserved is shared with others for a valid University business reason, everyone should ensure that the recipient is aware of the information’s classification and their obligation to protect it. Access to information in these classifications by a third party requires a data sharing or confidentiality agreement in place, signed on behalf of the University and the other party. The Legal Services team can help you with this (www.warwick.ac.uk/legalservices). Information Classification and Handling Procedure v1.2.1 Approved 4. What should I do if something goes wrong? The University is expected to inform the Information Commissioner’s Office of any significant information security breach relating to personal data as per the Data Protection Act 1998 and has an obligation to report any significant breaches pertaining to other types of ‘sensitive’ information to the data owner and other relevant parties. The University recognises that failure to adhere to its legislative, regulatory and contractual obligations may result in significant financial and legal penalties and reputational damage. 1 It is therefore vital that everyone reports any observed or suspected security incidents where a breach of the University’s security policies has occurred, any security weaknesses in, or threats to, systems or services. You should immediately report any actual or suspected information security breaches by emailing Informationsecurity@warwick.ac.uk and informing your line manager/Head of Department. Document History 13 May 2013 J. Findlay 31 2 Jul Sep 2013 2013 J.Findlay J.Findlay 16 Apr 2014 J.Findlay Created document with comments from Dr Duncan Hine (WMG, Cyber Security specialist), Verification Group members and Head of Service Development (ITS), Senior Assistant Registrar (Governance, Risk and Continuity) and Head of Institutional Governance Services (v1) Revised classification labels and examples (v1.1) Labels finalised as Public/Protected/Restricted/Reserved. Approved for release by Head of Institutional Governance Services (v1.2) Minor - ID number reclassified as Protected from Restricted due to use of ID number as usercode from March 2014. Inclusion of One Drive for Business in Annex B. Approved for release by Head of Institutional Governance Services (v1.2.1) The official version of this document will be maintained online. Before referring to any printed copies please ensure they are up to date Next Review Summer 2014 1 The Information Commissioner’s Office can issue a monetary penalty up to £500, 000 if it were determined that the University did not take reasonable steps to secure personal information or acted in such a way as to knowingly put information security at risk. Information Classification and Handling Procedure v1.2.1 Approved Annex A – Classifying Information Classification Public Protected Restricted Reserved Risk None confidentiality is of no particular significance to this information Low inappropriate disclosure would have minimum significance Medium - inappropriate disclosure could adversely affect the University's reputation or operations, substantial distress to individuals or breach statutory restrictions on disclosure of information; likely financial or legal penalties High - inappropriate disclosure could cause significant damage to the University's reputation or operations, great distress to individuals, pose a danger to personal safety or to life or impede the investigation or facilitate the commission of serious crime; substantial financial or legal penalties Access May be viewed by anyone, anywhere in the world Available to all University of Warwick members (e.g. secured behind a login screen) Available only to specified authorised University of Warwick members (e.g. secured behind a login screen, requires authorisation to gain access) Access is controlled and restricted to a small number of authorised University of Warwick members (e.g. secured behind a login screen, requires authorisation to gain access) PERSONAL Information Anonymised 2 information Student Names and Email addresses Individual’s home addresses, contact details and passport or NI number Financial information relating to individuals e.g. banking information, salary details, indebtedness (student fees) Staff Work Contact Details (incl job titles) Individual’s name, home addresses, contact details and age Staff Details shared publically by the University Examples (nonexhaustive) As defined by the Data Protection Act 1998 Information on individuals made public with their consent including on social media sites or departmental websites Academic Staff Qualifications and Publication Details List of student or staff names and ID number Individual’s image (incl CCTV footage) Student registration and attendance details Exam scripts/marks/comments on student’s performance Prospective Students’ contact details Information on individual’s, racial or ethnic origin, political option, religious or other beliefs, physical or mental health or criminal record Student academic progression details including details of disciplinary proceedings Provisional degree classification prior to formal approval and any publication Staff appointment, promotion or details of personal affairs (see University Data Protection Policy) References for staff or students UCAS forms Dates of birth (DoB) Individual’s name plus DoB or national insurance 4 number(NI) 3 Individual’s name plus DoB or NI number, passport details, home address and 4 telephone number Hundreds of individuals’ names plus date of birth or NI number 2 For these purposes anonymised information is information which cannot identify an individual either in isolation or when combined with other information (Section 1 (1) of the DPA 1998). Anonymised data may also carry other handling requirements – please see below. 3 Content dependent e.g. information relating to health, criminal record or disciplinary matters would make the reference or form Reserved 4 Adding additional combinations of data can change the overall classification (sensitivity) of the information. Increasing the volume can also increase the classification level. Information Classification and Handling Procedure v1.2.1 Approved Page 3 of 6 Classification Public Protected Restricted 5 NONPERSONAL Information Examples (nonexhaustive) Research proposals prior to award Information relating to supply or procurement of goods/services prior to approved publication. Anything subject to disclosure under the Freedom of Information Act HR Policies and Guidance 'Trade' secrets, intellectual property intended for commercialisation Department and Course details Marketing or Press Information Factual and general organisational for public dissemination incl annual reports or accounts 5 Reserved Research data which is security-sensitive or has been similarly classified by an external body (e.g. Government, commercial partner with a confidentiality agreement) Legal advice or other information relating to legal action against or by the University Content dependent e.g. information relating to industry collaborators or world leading new ideas may lead to this being Restricted Information Classification and Handling Procedure v1.2.1 Approved Page 4 of 6 Annex B – Handling Electronic Information Activity Creation University Information Classifications Protected Restricted Public N/A Reserved N/A Visibly marked ‘CONFIDENTIAL’ Visibly marked ‘STRICTLY CONFIDENTIAL’; To be created (and stored) only in a secure environment and copies be limited and recorded Only as encrypted/password 8 protected attachment (take care to check address of recipient(s)) Can Email Yes Yes Only to @warwick addresses or other internal domains e.g. wbs.ac.uk or jobs.ac.uk (take care to check address of recipient(s)) Need to Password Protect file in transit N/A N/A Password to meet University standard Can access remotely Using myfiles or VPN Can share via Teambuilder/Files.Warwick (www.warwick.ac.uk/its) Yes 7 Using myfiles or VPN 7 Yes Can share via One Drive for Business Yes Yes Can keep on University laptops or other portable media Yes Only on temporary basis, taking care to avoid loss or theft Can keep on personally owned devices Yes No Store on University servers Preferably in backed up personal or shared network spaces Only in backed up personal or shared network spaces with access restricted to only those with a valid right to access the information (either by adding a password to the document, encrypting it or apply permissions to a folder) Using myfiles or VPN Password to meet University standard, consider using PGP 6 encryption 7 Using myfiles or VPN Consider encrypting/password protecting files also for extra 8 security Yes Only to @warwick addresses or other internal domains e.g. wbs.ac.uk or jobs.ac.uk (take care to check address of recipient(s)) Only on temporary basis and if encrypted/ password protected, taking care to avoid loss or theft Only on temporary basis and if encrypted/password protected, taking care to avoid loss or theft No No Only in backed up personal or shared network spaces with access restricted to only those with a valid right to access the information (either by adding a password to the document, encrypting it or apply permissions to a folder) Only in backed up personal or shared network spaces with access restricted to only those with a valid right to access the information (either by adding a password to the document, encrypting it or apply permissions to a folder) Only as encrypted/password 8 protected attachment (take care to check address of recipient(s)) 6 Available via the IT Services Helpdesk (ext 73737 or http://www2.warwick.ac.uk/services/its/) http://www2.warwick.ac.uk/services/its/servicessupport/networkservices/vpn/ 8 Passwords to be communicated via mechanism separate to sharing the link to the files with colleagues. 7 Information Classification and Handling Procedure v1.2.1 Approved 7 Page 5 of 6 Annex C – Handling Paper or other media Activity Public University Information Classifications Protected Restricted Reserved Visibly marked ‘STRICTLY CONFIDENTIAL’ Creation N/A Visibly marked ‘CONFIDENTIAL’ Locked filing cabinet or equivalent Locked filing cabinet or equivalent in office which is locked or attended at all times Storage in University N/A Can take off or around site Yes Can Fax Ensure fax number is correct and entered correctly Can Post Yes Yes Disposal Recycling Recycling (shredding if available) Information Classification and Handling Procedure v1.2.1 Approved To be created (and stored) only in a secure environment and copies be limited, numbered and recorded. N/A For shortest time possible and documents to be kept securely and with person Ensure fax number is correct and entered correctly For shortest time possible documents to be kept securely and with person Ensure fax number is correct and entered correctly Double envelope with inner envelope marked as stated above, hand delivered, recorded or courier delivery Shredding, Confidential Waste Copies delivered by hand. Locked filing cabinet or equivalent in office which is locked or attended at all times Only exceptionally and with authorisation from line manager; documents to be kept securely and with person No (unless to ‘safe haven machine’) Double envelope with inner envelope marked as stated above, hand delivered, recorded or courier delivery Shredding, Confidential Waste Page 6 of 6