Information Classification and Determination Policy

This document establishes the Information Classification and Determination Policy for the University of Arizona. This policy establishes security controls to identify, classify, and protect University Information.

This policy applies to all Information Systems and Information Resources owned or operated by or on behalf of the University. All University-Related Persons with access to University Information or computers and systems operated or maintained on behalf of the University are responsible for adhering to this policy.

This policy applies to all University Information and to all User-developed data sets and systems that may access this information regardless of the environment where the information resides (e.g., cloud systems, servers, personal computers, mobile devices). The policy applies regardless of the media on which information resides (e.g., electronic, hardcopy format) or the form it may take (e.g., text, graphics, video, voice).

CISO: The senior-level University employee with the title of Chief Information Security Officer.

Information Owner: The individual(s) or Unit with operational authority for specified University Information and responsibility for establishing the controls for its generation, collection, processing, dissemination, and disposal. This individual or Unit is responsible for making risk tolerance decisions related to such Information on behalf of the University and is organizationally responsible for any loss associated with a realized information security risk scenario.

Information Resources: University Information and related resources, such as equipment, devices, software, and other information technology.

Information System: A major application or general support system for storing, processing, or transmitting University Information. An Information System may contain multiple subsystems. Subsystems typically fall under the same management authority as the parent Information System. Additionally, an Information System and its constituent subsystems generally have the same function or mission objective, essentially the same operating characteristics, the same security needs, and reside in the same general operating environment.

Information System Owner: The individual(s) or Unit responsible for the overall procurement, development, integration, modification, and operation and maintenance of an Information System. This individual or Unit is responsible for making risk tolerance decisions related such Information Systems on behalf of the University and is organizationally responsible for the loss, limited by the bounds of the Information System, associated with a realized information security risk scenario.

ISO: The University's Information Security Office, responsible for coordinating the development and dissemination of information security policies, standards, and guidelines for the University.

Unit: A college, department, school, program, research center, business service center, or other operating Unit of the University.

University Information: Any communication or representation of knowledge, such as facts, data, or opinions, recorded in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual, owned or controlled by or on behalf of the University.

University-Related Persons: University students and applicants for admission, University employees and applicants for employment, Designated Campus Colleagues (DCCs), alumni, retirees, temporary employees of agencies who are assigned to work for the University, and third-party contractors engaged by the University and their agents and employees.

User: Individual or group that interacts with a system or benefits from a system during its utilization.

ISO shall define the minimum standards for security controls that must be applied to each classification of University Information, as set forth in the Data Classification and Handling Standard.

Information Owners and Information System Owners shall ensure both the implementation of processes and procedures for the classification of information, as defined in the Data Classification and Handling Standard, and the application of security controls.

Compliance 

Tracking, Measuring, and Reporting

ISO shall initiate mechanisms for tracking compliance with this policy and shall produce reports representing these measures to support University decision making.

Recourse for Noncompliance

ISO is authorized to limit network access for individuals or Units not in compliance with information security policies (including this one) and related procedures. In cases where University resources are actively threatened, the CISO shall act in the best interest of the University by securing the resources in a manner consistent with the Information Security Incident Response Plan. In an urgent situation requiring immediate action, the CISO is authorized to disconnect affected individuals or Units from the network. In cases of noncompliance with this policy, the University may apply appropriate employee sanctions or administrative actions, in accordance with relevant administrative, academic, and employment policies. 

Exceptions

Requests for exceptions to information security policies (including this one) may be granted for Information Systems with compensating controls in place to mitigate risk. Any requests must be submitted to the CISO for review and approval pursuant to the exception procedures published by the CISO.

Frequency of Policy Review

The CISO shall review information security policies and procedures annually, at minimum. This policy is subject to revision based upon findings of these reviews.

Responsibilities

University-Related Persons

All University-Related Persons are responsible for complying with this policy and, where appropriate, supporting and participating in processes related to compliance with this policy.

Information Owners and Information System Owners

Information Owners and Information System Owners are responsible for implementing processes and procedures designed to provide assurance of compliance with the minimum standards, as defined by ISO, and for enabling and participating in validation efforts, as appropriate.

Chief Information Security Officer

ISO shall, at the direction of the CISO:

• identify solutions that enable consistency in compliance and aggregate and report on available compliance metrics;
• develop, establish, maintain, and enforce information security policy and relevant standards and processes;
• provide oversight of information security governance processes;
• educate the University community about individual and organizational information security responsibilities;
• measure and report on the effectiveness of University information security efforts; and
• delegate individual responsibilities and authorities specified in this policy or associated standards and procedures, as necessary.

Vice Presidents, Deans, Directors, Department Heads, and Heads of Centers

All Vice Presidents, Deans, Directors, Department Heads, and Heads of Centers shall take appropriate actions to comply with information technology and security policies. These individuals have ultimate responsibility for University resources, for the support and implementation of this policy within their respective Units, and, when requested, for reporting on policy compliance to ISO. While specific responsibilities and authorities noted herein may be delegated, this overall responsibility may not be delegated.