Data Protection Plan Requirements This document describes the required contents of the Data Protection Plan that must be submitted as part of an application for access to Floodwatch data. It describes the basic information that all Data Protection Plans should contain, including requirements for data access, storage, security, and dissemination, and the disclosure rules for presenting and publishing results on Floodwatch data. Floodwatch data is defined as any database records or server metadata provided to the Recipient in connection with OCR’s Floodwatch project. The Data Protection Plan must describe the following: 1. Data Protection Plan Description​
: A. List and describe all locations where the original and any copies of the data will be kept, including but limited to building name, street address, and room numbers); B. List names and include CVs of all individuals who have access to the data; C. Data Protections for Each Data Work Environment Describe each data work environment that will have access to Floodwatch data and how you will protect that data in that environment (including all network, system, and file security, encryption, etc.)., including: ­ Computing platform (e.g., personal computer, workstation, mainframe) and operating system, including any security used, such as encryption or firewalls; ­ Number and types of computers on which data will be stored or analyzed; ­ Confirm that PCs used in the research project will be stand­alone. ­ Physical environment and address in which computer and data are kept (e.g., in room with public access, in room locked when not in use by research staff); ­ A list and description of all devices on which data will be stored (e.g., mainframe computer storage device, PC hard drive, removable storage device such as CD, floppy drive, or zip drive); ­ Methods of data storage when data are not being used; ­ Methods of transmitting the data and results between research team members (if applicable); ­ Methods of storage of computer output both in electronic form and in hard copy (on paper or other media); ­ Instruction in data protection policies that will be provided to each staff member before they receive access to the data as well as recurrent instruction that will be conducted at least annually. Copies of these policies should be provided to OCR for review. At a minimum, if you plan to use any of the environments below or their equivalents, you must address each of them separately: ­ Standalone, non­networked PC or authorized data enclave ­ Office work environment ­ Removable data storage devices (e.g., CDs, diskettes, zip drive disks, etc.) ­ Detailed printouts derived from data analysis 2. Commitments to Data Protection By accepting receipt of Floodwatch data, you promise and agree to do the following: ­ Require that data use must be in office environment described in Data Protection Plan and not at home or any other off­site location ­ Prohibit any use of the data on laptop computers ­ Prohibit any automated backup copying of the data ­ Password­protect access to all computers storing the data ­ Return or destroy all files containing Floodwatch data at the end of the project ­ Automatically enable activation of password­protection after five minutes of inactivity on any computer which accesses or stores Floodwatch data. ­ Keep all detailed printouts derived from data analysis in a locked compartment or room when not in use ­ Shred all detailed listings and printouts that are no longer needed ­ Prepare and maintain a log of all data files acquired, accessed, storage, or disseminated. Record dates that data and paperwork are received and returned or destroyed. ­ Limit access to Floodwatch data to individuals with authorization for data use, that have also signed the confidentiality agreement ­ Encrypt with password protection all files containing data ­ Promptly report any and all violations of the Data Protection Plan to OCR, the Primary Investigator (i.e. the head researcher), and the home­institution IRB. ­ Prevent transmittal of data or detailed tabulations with cell sizes of less than 11 (as cell sizes less than this may lead to the ability to de­anonymize data) via any network communication, including but not limited to e­mail or e­mail attachment or FTP (either over the Internet, an Intranet system, or within a local area network). ­ Brief all research staff that have access to Floodwatch data about the Data Protection Plan, appropriate data use, and penalties for inappropriate use. The Primary Investigator must regularly monitor procedures for use of the data by all project staff and collaborators. Clear rules about Floodwatch data use should be posted in a location that is readily visible to staff. ­ At the conclusion of the Research Project, destroy or return all Floodwatch data files and destroy all unpublished printouts of Floodwatch data. 3. Disclosure Rules The Data Protection Plan must carefully describe how researchers and staff members will avoid inadvertent disclosure of individuals’ geographic locations and/or personally identifiable information in all working papers, publications, and presentations. Personally identifiable information includes any information which could reasonably be used to associate any Floodwatch data with the individual who recorded the Floodwatch data while browsing. At minimum, researchers must agree to exclude from any type of publication or presentation the following information: ­ Listing of individual users; ­ Description of individual users; ­ Summary statistics or tabulations that have cell sizes under 11 observations.