Third-Party Data Transfer Policy

Version 1.5

For Students, Faculty, Staff, Guests, Alumni


The purpose of this policy is to ensure the data transmitted/transferred between University IT Resources and a third party is secure.


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 Information Security and Assurance (ISA).
  • 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 the University's Office of Legal Counsel (OLC).
  • A secure transmission method must be used as specified in the Data in Transit Policy.
  • Information Security and Awareness will have final approval of these protocols mentioned in the Data in Transit Policy for specific applications on a case-by-case basis.


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 History

Review Frequency Triennial 
Responsible Person Senior Director, IT Security Operations and Assurance 
Approved By CISO
Approval Date October 1, 2018

Revision History

1.2 01/15/2016 Supersedes September 1, 2009 version
1.3 01/01/2018 Supersedes January 15, 2016 version
1.4 01/16/2020 Updated policy statement
1.5 02/22/2021 Updated purpose and policy statements

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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