Data Documentation Policy

Version 1.2

For Students, Faculty, Staff, Guests, Alumni


The purpose of this policy is to establish the practice of reporting the type of data being stored and processed on IT Resources owned or leased by the University.


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

  • When deploying a new system, retrofitting, or updating existing systems, data must be classified in accordance with the Data Classification Guidelines to include:
    • Name of the major system (e.g., Banner, PowerFAIDS)
    • Location (on-premise vs. cloud)
    • Type of data (e.g., FERPA, PCI, PHI, PII)
  • The data classification must be documented in an accessible, auditable manner.


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

Implementation Information

Review Frequency: Triennial
Responsible Person: Senior Director of IT Security and Assurance
Approved By: AVP/CIO
Approval Date: March 1, 2017

Revision History

1.0 01/24/2017 Initial document
1.0.1 03/01/2017 Grammatical changes only
1.0.2 05/23/2018 Updated disclaimer, scope, and definitions
1.1 09/11/2020 Updated policy statement
1.2 07/12/2023 Updated policy statement

Policy Disclaimer Statement

Deviations from policies, procedures, or guidelines published and approved by Information Security and Assurance (ISA) may only be done cooperatively between ISA and the requesting entity with sufficient time to allow for appropriate risk analysis, documentation, and possible presentation to authorized University representatives. Failure to adhere to ISA written policies may be met with University sanctions.

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