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Guidelines for Using Campus IT Services with Regulated Data

Refer to the Regulated Data Chart for guidance to help you choose appropriate technology tools for sending, storing and sharing institutional information.

As a custodian of institutional information, you are responsible for the Cornell data sent, stored or shared on all information technology devices -- personal or university-owned -- that you use. This responsibility includes choosing appropriate information technology (IT) to manage data.

What is the Regulated Data Chart?

The Regulated Data Chart provides guidance to help you choose appropriate technology tools for sending, storing and sharing institutional information.

The chart lists both cloud and on-premise services that you are likely to use as part of your daily Cornell work routine. Use the chart, as directed below.

How to use the Regulated Data Chart

Before choosing a tool to send, store or share institutional information, ask two questions:

  • Question 1: Does the Regulated Data Chart permit use of this IT service with the data type I am interested in working with?
  • Question 2: Do my department/unit policies and my data steward permit use of this IT service with the data type I am working with? If you don't know, check with your supervisor. The offices of the data stewards (see chart below) also can help.

If the answer to both questions is yes, you may use the IT tool to send and store the university data in question.  

Important notes for chart users:

  • Information in the chart applies to Cornell's enterprise versions of the services listed and these should not be confused with consumer versions of these services or third party applications associated with these services that take institutional information outside of the protected technical environment that Cornell's contract with the vendor requires. Enterprise versions of cloud services are very similar to consumer versions in terms of features and capabilities. However, for enterprise versions, Cornell
    • negotiates institution-wide terms and prices.
    • vets the service with its legal, policy, supply management, audit, and security specialists.
    • integrates the service into the Cornell environment (so that you can use your NetID and password to log on, for example).
  • The Regulated Data Chart does not apply to data associated with faculty research unless that research falls under a regulation or contract.
  • At this time, the Regulated Data Chart indicates only if appropriate technical safeguards and contractual protections are in place through Cornell (for on-premise services) or through vendors (for cloud services) for sending, storing, or sharing regulated or confidential data using a particular technology.¬†Always check both the Regulated Data Chart and your local guidelines before deciding. Example:

    Cornell's contract with (fictional) Vendor B requires that the company retain Cornell's education records, such as a student's academic work, in a technical environment that protects against inadvertent disclosure and that the company implement privacy practices that meet FERPA standards. Because Vendor B is obligated to provide this level of protection, it is possible from a strictly contractual perspective, to send, store or share FERPA records using Vendor B's service. This contractual provision is the minimum, necessary requirement but is not, by itself, sufficient for permitted use of Vendor B's service with FERPA data. Although the Regulated Data Chart would indicate that this use is permissible, your data steward or your department/unit guidelines may still prohibit use of Vendor B's service. See Data Stewardship and Custodianship, Policy 4.12 and the list of data stewards below.

Why ask these questions?

  • Federal laws in the area of education, financial and health care records, as well as a number of state data breach notification laws and contractual provisions in government research grants, impose legal and technical restrictions on the appropriate use of institutional information. The university must comply with laws, contract provisions and other restrictions.
  • As a matter of university policy (Data Stewardship and Custodianship, Policy 4.12), custodians should follow data management guidelines set by their department/unit polices and data stewards.
  • At this time, it is not possible to use all institutional information indiscriminately on all IT services offered at Cornell. University Counsel and the Directors of IT Policy and Security work together to obtain proper agreements and technical safeguards on both cloud and on-premise IT applications, but right now not all information has legal protection for use with all technologies.

Simply by asking the two questions above and using the answers to guide your choices, you can comply with legal, contractual and policy rules surrounding Cornell's institutional information.

Who are the data stewards?

Direct questions about data stewardship and custodianship to the following office.

Subject Contact
Policy Clarification Unit Administrative Office

Vice President for Planning and Budget

Alumni Affairs and Development Data Vice President for Alumni Affairs and Development
Facilities Data Associate Vice President, Facilities Services
Financial Data Vice President for Financial Affairs and University Controller
Human Resources Data Vice President, Human Resources
Implementation Vice President, Planning and Budget
Information Technology Data Vice President, Information Technologies
Planning and Budget Data Vice President, Planning and Budget
Sponsored Research Administrative Data Vice Provost for Research
Student Services Data Vice President, Student and Campus Life

Related policies

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