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Home > Help & Support > Knowledge Base > Security > Highly Sensitive Data > Data Classification and Storage Requirements
Highly Sensitive Data | Restricted | Public Use |

Data Classification and Storage Requirements

The following information is to help university employees effectively manage information. Determining how to protect & handle information depends on a consideration of the information’s type, importance, and usage. Classification is necessary to understand which security practices should be used to protect different types of information. The more protected the information needs to be, the more practices are required.

APPLIES TO:

University employees (faculty, staff, student employees) and other covered individuals (e.g., affiliates, vendors, independent contractors, etc.) in their handling of university data, information, and records in any form (paper, digital text, image, audio, video, microfilm, etc.) during the course of conducting university business (administrative, financial, education, research or service). “Handling” information includes, but is not limited to, the following: creating, collecting, accessing, viewing, using, storing, transferring, mailing, managing, preserving, disposing, or destroying.

This is not an all-encompassing list. For information or attributes not listed, or when in doubt, please contact [email protected] or set up a consultation with IT Security Office.

When mixed data falls into multiple categories, use the highest classification. That is the high watermark to which the controls must be applied.

Highly Sensitive Data

Storage Location

Additional Information

Protected - Highly Sensitive Data

Justification

  • MESA Departmental Shares
  • Patriot Drive
  • Secure SharePoint (Refer to Highly Sensitive Data)

The following student Information/ records:

  • Non-directory data
  • Student records (including directory data) flagged as confidential/private.

Attributes defined as ‘Directory Information’ in Mason: FERPA

For Student Financial Aid that constitutes Federal Tax Information (FTI)**, refer to the separate listing below.

  • 34 CFR 99 (FERPA)
  • Va. Code § 23.1-405
  • 34 CFR § 99.3 and 34 CFR § 99.37
  • Protecting Student Information
  • FERPA for Staff and Faculty: FAQs by Office of University Registrar

Passwords/PINs and cryptographic private keys associated with User ID and/or system or technology services

  • Cybersecurity and fraud risk considerations
The following attributes when used in this combination should only be released to non-school officials for verification purposes.

  • Student ID (G Number)
  • Date of Birth
  • Office of the University Registrar: FERPA
  • Va. Code § 23.1-405 (C)

Datasets containing Date of Birth

  • Date of Birth is often used for password resets and account claim processes.
  • Va. Code §18.2-186.3

Personally Identifiable Information (PII)*

*Any personal information that can lead to identity theft if exposed.

IMPORTANT: credit card data MUST NEVER be stored on Mason systems.

Social Security Numbers (SSN)

  • Va. Code § 2.2-3808
  • Va. Code §18.2-186.6
  • Va. Code § 18.2-186.3

Financial account numbers

  • NACHA
  • Va. Code §18.2-186.6
  • Va. Code § 18.2-186.3

Driver’s license, state ID, military ID, passport, visa numbers

  • Va. Code §18.2-186.6
  • Va. Code § 18.2-186.3

Protected Health Information

Medical/mental history, treatment, or diagnoses information; health insurance policy numbers, protected health information in hard copy or electronic formats.

  • Va. Code § 2.2-3705.2
  • 45 CFR 160.103
  • HIPAA
  • HITECH

Allegation and investigation records (all roles including students)

  • Title IX
  • Law Enforcement
  • American Disabilities Act 
  • Privacy and confidentiality

Data that must be withheld from release under the Virginia Freedom of Information Act (FOIA).

  • Va. Code § 2.2-3705.2

Engineering, design, or operational information associated with Mason’s infrastructure. Such information should also be evaluated for FOIA exemption.

This would include Network diagrams that contain detailed configuration information or network devices associated with systems categorized as ‘High” category.

  • Mason Policies and Standards
  • Va. Code § 2.2-3705.2

Draft financial statements and similar reports that have not been approved for publication or distribution.

  • Drafts that may not be complete or accurate for being ‘work in progress’ can have material negative impact (e.g., reputational) if disclosed without being finalized.
  • MESA Departmental Shares
  • Patriot Drive
  • Archer Integrated Risk Management (IRM)

Information shared by vendors or other parties under confidentiality or non-disclosure agreements.

  • Contractual obligations
  • Systems approved to store FTI such as Banner
  • NIST 800-53 and NIST 800-171 compliant systems only

**Federal Tax Information (FTI) for Federal Student Aid Programs

  • Internal Revenue Service (IRS) Publication 1075
  • Department of Education Announcement
  • Secure Research Computing (SRC)*
* Contact the Office of Research Integrity and Assurance for applicable requirements and control restrictions

Research Support Services: Export control, Controlled Unclassified Information (CUI)

  • CUI
  • NIST SP 800-171
  • ITAR
  • Rapid Prototyping Research Center*

Research Support Services: Controlled Unclassified Information (CUI)

  • CUI
  • NIST SP 800-171
  • ITAR, EAR

Restricted Data

Storage Location

Protected - Restricted

Justification

  • George Mason’s subscribed M365 including OneDrive
Student information attributes that may not be released under the directory information exception of FERPA. These are:

  • Student Email
  • Address
  • Phone Number

See Code of Virginia § 23.1-405(C) for conditions.

Office of the University Registrar: FERPA

Va. Code § 23.1-405 (C)

Unpublished research data that are not classified as Highly Sensitive Data (by the Principal Investigator or the Data Owner)

  • Patent, competitive and commercial potential, intellectual property, work product
G numbers, Cardinal ID (by themselves, without any context or other attributes)
  • Privacy and potential fraud considerations

Employment applications, employee performance evaluations, and personnel files without PII, as well as non-directory contact information

  • Privacy

Personnel and financial information not covered by the definition of Highly Sensitive Data, but not intended to be made public.

Internal communications and email, non-public reports or contracts, intellectual property, and all other information releasable in accordance with the Virginia Freedom of Information Act.

  • Least privilege, need-to-know
Donor contact information and non-public gift information
  • Donor Privacy
  • Hopper Cluster by Office of Research Computing

Research project datasets that:

  • Do NOT contain Personally Identifiable Information
  • Are de-identified
  • 45 CFR 46
  • HIPAA (Research Perspective)
  • Secure custom-configured George Mason-managed encrypted laptop or desktop

Research project datasets with agreements that DO NOT contain restrictions from the Data Owner/Sponsor/Prime/Sub around not storing that data on laptops or desktops, AND:

  • Do NOT contain Personally Identifiable Information
  • Are de-identified
  • 45 CFR 46
  • HIPAA (Research Perspective)

Public Use Data

Storage Location

Public Use Data

Justification

  • George Mason’s subscribed M365 including OneDrive
Published directory information (faculty, staff, students, etc.)
  • Office of the University Registrar: FERPA
  • Va. Code § 23.1-405 (C)
  • Va. Code § 23.1-405
Research data that is unrestricted or based on publicly available information Public Use
George Mason’s Public Websites Public Use
Procedure manuals designated by the owner as intended for public use Public Use
Employment advertisements Public Use
Information in the public domain (e.g., campus maps, parking information, published news releases and announcements, events calendars) Public Use
Last modified: May 14, 2025

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