You are required to request the right to store and work with Highly Sensitive Data.
Some university processes or departmental business may require working with Highly Sensitive Data (HSD), which is data that:
- Its personal nature can lead to identity theft or exposure of personal health information
- A researcher, funding agency, or other research partner has identified as highly sensitive or otherwise requires a high level of security protection
- The impact of the loss of confidentiality, integrity, or availability would have a severe impact on the University in reputation, or the ability to perform its mission
In such cases, special permission is required to ensure this data is used in compliance with university, state, and federal standards and stored properly and securely.
Some examples of HSD include:
- Data classified as secret by the federal government
- Data that is often involved in identity theft (e.g., SSNs)
- Data described in the Health Insurance Portability and Accountability Act (HIPAA) as needing to be secured
- Data that could lead to financial theft (e.g., credit card information)
Managing Access and Rights
The type of access must be restricted to only the rights required to perform work—Read, Write, Delete, Download, Share, Email, and Store on a laptop/workstation. HSD may only be stored on approved systems.
Auditing and Access Review for the HSD Store
The business process owner must have a strategy for initially and periodically evaluating access. An initial justification and schedule to regularly review appropriate staff/business process/data owner must be conducted and documented.
Endpoint Security When Storing HSD Locally
If data will be stored locally on a personal device, these endpoint computers must be managed in MESA, Microsoft Active Directory, or JAMF (Apple devices). An inventory of endpoints approved to store HSD must exist, and additional controls may be applied to the endpoints (i.e., Whole Disk Encryption). The IT Security Office (ITSO) can help assess requirements and processes.
Getting This Service
Access and use of HSD are restricted to those needing access for required business purposes. If you don’t have a hard requirement to store or operate HSD, you should not have access to it. If there is an unnecessary use of HSD in data you currently work with, consider removing these elements. For example, the month and year of birth are not HSD; however, a full birthdate is.
When considering all of the controls necessary to protect HSD reasonably, a simple, effective solution that is supportable is always best. Automated technical controls that don’t hinder business processes are ideal. ITSO can help with identifying requirements and translating them into supportable controls. Chief data stewards and ITSO review requests.
You must request approval if you believe you have a legitimate reason to use or store HSD on university-approved applications, including Microsoft Teams (MS Teams).
Click the Request to store HSD button to submit a request.
If you are looking to store HSD on web applications or other server-based applications, see Additional Information.
All users of HSD must adhere to Policy Number 1114: Data Stewardship.
HSD will almost always have regulatory control requirements described in either university policy, commonwealth, or federal regulation. There may also be requirements stated in a data security standard, data sharing agreement, or grant/other contracts. The Data Owner and Data Custodians must fully understand the requirements for HSD use.
All users of the George Mason University network must adhere to University Policy Number 1301: Responsible Use of Computing.
Storing HSD on Web Applications or Other Server-based Applications
Any new request to store HSD on a served web or other application must be evaluated to ensure that the services are controlled appropriately for HSD. This typically requires an Architectural Standards Review Board (ASRB) request.
Any served application like a web application, third-party Software as a Service (SaaS), or system that stores or presents HSD must use the university authentication services, which require the use of Two-Factor Authentication (2FA).