http://aclu.org/pizza UCLA CPO (& co) CSG — November 27, 2012 Kent Wada, Director, Strategic IT Policy and Chief Privacy Officer UCLA Office of Information Technology The UC Electronic Communications Policy (ECP) http://policy.ucop.edu/doc/7000470 The ECP Defenders of the faith … and proxy Adopted 2000, last major revision 2005 2010: ECP “quick fix” project and overarching review of privacy and information security Issues become more complicated and far more pervasive (tools like Google Analytics and Dropbox; HR issues; cultural expectations; …) UC Privacy and Information Security Initiative http://universityofcalifornia.edu/privacyinitiative/ Steering Committee Charge An overarching privacy framework that enables UC to meet statutory and regulatory obligations in a manner respectful of individual privacy; Governance, implementation and accountability structures across the University with respect to privacy and information security; A formal, ongoing process through which the University can examine and, where necessary, address through policy vehicles the technical and societal changes that have an impact on University policy and practice in the areas of privacy and information security; and Specific actions or phases needed to implement the proposed framework as University policy. What is Privacy? Privacy is about the individual The Perils of Privacy “Down the hall in the billing department, a clerk uses a lunch break to scan the Web for information on abuse victims. The information retrieved also flashes onto a screen in the boss’s office, revealing a secret the employee never told anyone.” The Perils of Privacy: PC World, December 28, 1999 pcworld.com/news/article/0,aid,14557,00.asp Implications, Activities and Status Aligning privacy and security IS-3 Convergence for strategic direction setting and risk/compliance Systemwide information security policy review and alignment project Report draft status A Campus Privacy Program http://privacy.ucla.edu (planned) A “Typical” Privacy Program Identifying and managing privacy risks Developing privacy policies and practices Maintaining integrity over campus practices and decisions that impact privacy Fostering privacy by design Properly handling privacy breaches Resolving conflicting privacy interests Not Your Father’s CPO Actually, your father didn’t have one (and most still don’t) Integration of both forms of privacy across the campus Not intended to replace existing authority for regulatory compliance Integrated coordination with Chief Compliance Officer, Health System/School of Medicine and campus ISO More a focus than a position (at present) Building a roadmap A first step: identifying campus privacy pieces UCLA Privacy and Data Protection Board http://privacyboard.ucla.edu/ Not Your Father’s “Privacy Board” Historical context UCLA Privacy Statement … basis for part of the UC initiative 2012: organizational revision Strategic direction setting for privacy and information security Compliance and risk The CPO and the Board Director, IT Security and Chief Compliance Officer, UCLA Health System and David Geffen School of Medicine Questions? Thoughts? Comments?