Who is responsible for my data?

By engaging with a service provider, you have the responsibility as the Resource Proprietor for ensuring compliance with laws, regulations and policies, including standards (UC Business Finance Bulletin IS-2 and IS-3).

For example, if notice-triggering data is involved, the service (whether on or off campus) must meet the protective measures defined in the campus Minimum Security Standard for Electronic Information.

Information that is subject to state or federal regulations will have use and disclosure restrictions that must be maintained.  Student records are protected by FERPA regulations.  Medical records are protected by HIPAA, FERPA, and state laws.

The Resource Proprietor, in consultation with the Resource Custodian, is responsible for determining the level of risk (subject to law, regulation, and policy) and ensuring the implementation of appropriate security controls to address that risk.  This puts responsibility for evaluation of the service's security controls (e.g., hardening, patching and monitoring) in the hands of the Resource Proprietor. Although not directly applicable to services outside of the campus network, the campus Minimum Security Standard for Networked Devices provides a useful set of baseline security requirements.