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Addressing Unauthorized Release of Personal Information at UC Davis. August 12, 2003. California Civil Code, Section 1798. State’s response to an estimated 160,000 cases of identity theft in 2002
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Addressing Unauthorized Release of Personal Information at UC Davis August 12, 2003
California Civil Code, Section 1798 • State’s response to an estimated 160,000 cases of identity theft in 2002 • Requires organizations, including institutions of higher learning, to notify state residents when unauthorized individuals have obtained personal information via a computer security breach • Effective as of July 1, 2003
UC Guidelines • Electronic Information Security (BFB IS-3) • Defines personal information as first name or first initial and last name in combination with one or more of the following: • Social Security Number • Driver’s license or California ID number • Account or credit card number and security code, access code or password
UC Guidelines (cont.) • Defines security breach as when a California resident’s unencrypted personal information is believed to have been acquired by an unauthorized person. • Calls for system-wide notification procedures and the development of local guidelines.
UC Davis Implementation • Chancellor Vanderhoef • Appointed UC Davis Information Technology Security Coordinator, Bob Ono, as lead in coordinating the campus’ compliance efforts • Via May 28, 2003 memo, notified Vice Chancellors, Vice Provosts and Deans of the need to take a proactive approach by identifying ways in which security risks can be minimized
UC Davis Implementation (cont.) • IT Security Coordinator, Bob Ono • Developed draft implementation plan that identifies key roles, responsibilities and procedures for: • Minimizing risks of security breach • Reporting incidents • Notifying individuals whose personal information may have been obtained by a non-authorized person
Roles and Responsibilities • CODVC Members • Oversee preventative measures to secure data • Communicate with appropriate staff about Section 1798, identity theft, and the campus implementation plan
Roles and Responsibilities (cont.) • Campus Units • Inform users of their responsibilities to secure personal information • Assess risks and implement security safeguards for systems housing personal information • Develop and maintain control records and establish monitoring procedures • Report suspected incidents
Roles and Responsibilities (cont.) • Campus Misuse Committee • Investigate reported incidents • Assess need for and authorize notifications • Authorize case closure
Roles and Responsibilities (cont.) • IT Security Coordinator, Bob Ono • Communicate components of implementation plan to responsible parties • Ensure response process is followed • Ensure system-wide and campus notification procedures are followed • Coordinate incident reporting with department personnel, Campus Misuse Committee, and UCOP
Resources • Identity Theft Prevention Web Site • http://security.ucdavis.edu/identity_theft.cfm • Information Practices Act of 1977 – California Civil Code Section 1798 • http://www.privacy.ca.gov/code/ipa.htm • Information Security Policy, Business and Finance Bulletin IS-3 • http://www.ucop.edu/ucophome/policies/bfb/is3.pdf • Misuse of University Resources, UC Davis Policy and Procedures Manual, Section 330-95 • http://manuals.ucdavis.edu/ppm/330/330-95.htm