Physical Data Audit of Unsecured Areas

During routine operations, a sizable store of paper files containing restricted level data was discovered in an unsecured area. Once discovered the files were immediately removed for destruction or placed in secure storage. We disposed of 10 full secure shred bins worth of paper records.

I would like to ask that each of that each department conduct an inventory and review of their paper files and electronic media in unsecured areas. IM&T would like to schedule a simple audit with a representative from each area during the month of November.

Unsecure Area

A space that is generally accessible without a key card or key and is not under constant supervision by a full-time employee. Any FTE that could act as a data custodian must be familiar with authorized personnel which are allowed access to that space or the resources within that space.

Examples:

• Unlocked file cabinets containing restricted data in hallways which are not under direct and constant observation.
• Offices or storage spaces which are left unlocked or open which contain files or file storage containers with restricted data that are not secure or under constant observation.
• A front office containing unlocked file cabinets which have restricted data which is only under observation part time by a student employee.

Resources:

• Please place any restricted data into a secured disposal bin when it needs to be destroyed. If you need additional bins for a large quantity disposal, please contact facilities management. https://fmservicedesk.unco.edu/ I am happy to help any department coordinate disposal with them.
• If you need to review discovered files before they can be disposed of the files must be stored in a secure room or secure container until a review is completed.
• If files containing restricted must be retained for UNC operations, by law or compliance the restricted files must be secured in a locked container or storage area.

The Office of Information Security will be conducting a campus wide audit during the month of November so get your preferred date and time by scheduling with me early. Matthew.langford@unco.edu.