Third-Party Data Transfer Policy
Version 1.3
Purpose
The purpose of this policy is to ensure the data transmitted/transferred between the University’s IT Resources and non-University controlled systems is secure.
Scope
This IT policy, and all policies referenced herein, shall apply to all members of the University community including faculty, students, administrative officials, staff, alumni, authorized guests, delegates, and independent contractors (the “User(s)” or “you”) who use, access, or otherwise employ, locally or remotely, the University’s IT Resources, whether individually controlled, shared, stand-alone, or networked.
Policy Statement
- Transmission of data, to or from the University to a third-party must be reviewed and approved by the University Information Security Office (UISO).
- The requestor must submit a service request to initiate a third-party data transfer request per the Third-Party Data Transfer Procedure.
- Any third-party vendor that stores the University’s data must have a signed contract with Fordham University.
- The University's Office of Legal Counsel (OLC) must approve the contract before transmission of the University’s data.
- The OLC must confirm that the proper legal protections and requirements for confidentiality are in place before the execution of any such contract.
- A secure transmission method must be used as specified in the Data in Transit Policy.
- The UISO will have final approval of these protocols for specific applications on a case-by-case basis.
Definitions
IT Resources include computing, networking, communications, application, and telecommunications systems, infrastructure, hardware, software, data, databases, personnel, procedures, physical facilities, cloud-based vendors, Software as a Service (SaaS) vendors, and any related materials and services.
Related Policies and Procedures
- Data Classification Policy
- Data Classification Guidelines
- Data in Transit Policy
- Third-Party Data Transfer Procedure
Implementation History
| Review Frequency | Annual |
|---|---|
| Responsible Person | Director, IT Security |
| Approved By | CISO |
| Approval Date | October 1, 2018 |
Revision History
| Version | Date | Description |
|---|---|---|
| 1.2 | 01/15/2016 | Supersedes September 1, 2009 version |
| 1.3 | 01/01/2018 | Supersedes January 15, 2016 version |
Policy Disclaimer Statement
Deviations from policies, procedures, or guidelines published and approved by the University Information Security Office (UISO) may only be done cooperatively between the UISO and the requesting entity with sufficient time to allow for appropriate risk analysis, documentation, and possible presentation to authorized University representatives. Willful failure to adhere to UISO written policies may be met with University sanctions.