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University Policy 97

Information Security and Privacy Governance

Approved by: Executive Council: March 5, 2007
Posted: March 22, 2007
Revised: April 25, 2016
Revised: February 21, 2018
Revised: March 24, 2020
Revised and Renamed: November 15, 2022

Policy Topic: Information Technology
Administering Office: Office of CIO


Institutional data is both a valuable asset and a potential liability to the University. As such, the security and privacy of university data are important responsibilities for every member of the university that has access to it. As an academic institution we must encourage the free flow of most information, while protecting critical operational information. The purpose of this policy is to:

  1. protect the university’s data from misuse;
  2. establish categories of data and their definitions.
  3. provide a framework defining the appropriate protection required for each category of data.
  4. define who is responsible for ensuring that data is handled in an appropriate manner
  5. establish a governance structure for information security and privacy.


  1. The Policy applies to all university enterprise-level data as defined below.
  2. The Policy applies to data housed on the campus itself or hosted on an outsourced system.
  3. The Policy applies to data in physical form, including but not limited to paper, as well as data in a digital format.
  4. The policy addresses both access to and disclosure of data.


  1. The terms “enterprise level data” or “data” shall mean any and all information generated by, owned by, created by, or otherwise managed by Western Carolina University, including that created by students, faculty, and/or staff pursuant to the university related duties or obligations. Data may exist in physical form, including but not limited to paper, as well as in a digital form. Data shall include both public records as well as records exempt from the North Carolina Public Records Act.
  2. The term “campus” shall mean all colleges, schools, departments, units, or other subdivision(s) of Western Carolina University.


  1. The Chancellor, Provost, Vice Chancellors, General Counsel, CIO, Chief of Staff and the Director of Athletics are the institutional Data Stewards (Data Stewards). The Data Stewards may appoint designees for their various areas of responsibility.  The Data Stewards are responsible for ensuring the appropriate handling of the enterprise-level data produced and managed by their division/unit, including the classification of data and the authorization of access.
  2. The Information Technology Division is responsible for ensuring that the appropriate technologies and system policies and permissions are in place to ensure appropriate access to electronic data.
  3. The Office of Institutional Planning and Effectiveness (OIPE) has primary responsibility for meeting the University's reporting obligations and overseeing the movement of unit record data between the campus and the University of North Carolina. It is the responsibility of all other divisions/units charged with the reporting of institutional data to ensure that OIPE has a record of the parameters of such reporting and timelines that OIPE will maintain as part of an inventory updated annually.
  4. The Chancellor will establish an Information Security and Privacy Committee (ISPC),  that shall report to the Chancellor. The charge of this Committee is to oversee the implementation of this policy, ensure campus data security and privacy policies and related standards and procedures are up to date, coordinate the review of campus data security and privacy, advise the campus with regard to data security and privacy, and assist the campus with risk assessments, etc. The members of the Committee are: 
    1. Chief Information Officer – Chair
    2. Chief Information Security Officer
    3. Chief Privacy Officer
    4. General Counsel / Chief Compliance Officer or designee
    5. FERPA Officer
    6. HIPAA Officer
    7. GLBA Officers
    8. Assistant Vice Chancellor Institutional Planning and Effectiveness or designee
    9. Associate Vice Chancellor of Human Resources or designee
    10. Internal Auditor or designee
    11. Director of Research Administration or designee
    12. Director of Student Financial Aid or designee
    13. Bursar
    14. Senior Director of Advancement Services
    15. Faculty representative (Appointed by the Chancellor in consultation with the Faculty Senate Chair. Term is 3 years)

  5. The Chief Privacy Officer and the ISPC are responsible for developing, implementing, maintaining, and monitoring an organization-wide governance and privacy program in alignment with the adopted privacy framework, to ensure compliance with all applicable laws and regulations regarding the processing of personally identifiable information (PII).
  6. The Chief Information Security Officer is responsible for overseeing the implementation of the information security program for the campus in alignment with University Policy 117 Information Security.


  1. All enterprise-level data will be assigned to one of the following categories by the appropriate Data Steward. The categories are not mutually exclusive. Data is to be handled according to the most sensitive category that it falls within.
    1. GREEN - Low Sensitivity
    2. BLUE - Guarded Sensitivity
    3. YELLOW - Elevated Sensitivity
    4. ORANGE - High Sensitivity
    5. RED - Severe Sensitivity

  2. Definitions of each category and requirements for how data is to be stored and transmitted are specified in the document Data Handling Procedures Related to the Information Security and Privacy Governance Policy.
  3. Classification of data and requirements may change due to changes in laws or contractual obligations.
  4. Staff authorized to access or disclose, YELLOW, ORANGE, OR RED data are required to sign a confidentiality statement upon hire or as directed.


  1. Willful inappropriate access to or disclosure of data may result in appropriate disciplinary action, up to and including dismissal, or legal action being taken.
  2. Liability for the willful inappropriate access to or disclosure of data may, in certain circumstances, rest with the individual and not the institution.


International Standards Organization (ISO/IEC 27002:2022, Clause 5 Organizational Controls)

International Standards Organization (ISO/IEC 27701:2019, Clause 6 PIMS-specific guidance related to ISO/IEC 27002) 

University Policy 106, “Protecting the Privacy and Security of PII”

University Policy 117, “Information Security”

Data Handling Procedures Related to the Information Security and Privacy Governance Policy

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