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Regulated Data Chart

Before using any Cornell service to send, store or share institutional information, review Guidelines for Using Campus IT Services with Regulated Data.

  • Incident Management Tool

Regulated and Confidential Data Definitions

FERPA (Education Records): Education records (i.e., files and documents which contain information related to an identifiable student) are protected by FERPA (Family Educational Rights and Privacy Act). Examples: class lists, grade rosters, records of advising sessions, grades, financial aid applications. See Policy 4.5, Access to Student Information

HIPAA (Health Records): Certain health information is protected by HIPAA (Health Information Portability and Accountability Act) and is considered confidential if it is individually identifiable and held or transmitted by a covered entity. Examples: health records, patient treatment information, health insurance billing information. The HIPAA-covered entities at Cornell are Weill Cornell Medicine, Cornell Health, Benefit Services (both for the Ithaca campus and WMC), and University Counsel.

Personal Identifiers (Confidential Data): Personal identifiers are Social Security numbers, credit card numbers, driver’s license numbers, and bank account numbers. These are considered confidential data when they appear in conjunction with an individual’s name or other identifier.

GLBA (Bursar Records): Cornell’s Bursar records are protected by GLBA (Gramm-Leach-Bliley/Financial Services Modernization Act) and also by FERPA.

Human Subjects: Sensitive Identifiable Human Subject Research: Information that reveals or can be associated with the identities of people who serve as research subjects. Examples: names, finger prints, full-face photos, a videotaped conversation, or information from a survey filled out by an individual.

Export Controlled Research: Export Controlled Research is protected by ITAR (International Traffic in Arms Regulations) and EAR (Export Administration Regulations). Sending, or otherwise making available, export-controlled information to a foreign national, either in or outside of the United States territory, is an export. Similarly, storing export-controlled information on a cloud computing server or other third-party server that is located in a foreign country or accessible by foreign nationals is an export. Example: dual-use technology used for scientific advancement as well as military applications.

Credit Card Payment Processing: Credit card numbers used for payment processing are regulated through a trade association agreement with the Payment Card Industry (PCI). Examples: credit card numbers, names, and other information used for payment processing.

Restricted Research Data: Restricted Access Research Data Sets: Example: census data.

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