Educause Security Discussion mailing list archives

Re: GDPR Question


From: Ben Marsden <bmarsden () SMITH EDU>
Date: Mon, 8 Jan 2018 11:17:53 -0500

expanding a bit (and with the standard IANAL caveat, it is my evolving
understanding that...),  the regulation also states that EU citizens living
abroad (ie, outside EU-covered states) are NOT covered by the regulation
while they remain abroad.  Ie. ex-pats aren't covered, so your faculty
members who may have EU citizenship but live & work at your US-based
institution are not covered by GDPR (erm, unless they go visit the homeland
and then exchange PI covered data while there).

  yes, ymmv ...

On Mon, Jan 8, 2018 at 11:09 AM, Brian T. Huntley <bhuntley () clarkson edu>
wrote:

Hi Jim -

Most everything I've seen and council advice we've received would indicate
that a US student studying abroad would indeed be entitled to protections
under the GDPR.

In fact, some have gone so far as to suggest that based on the somewhat
vague definition in Article 3:  "...data subjects who are in the Union..."
would include anyone who was physically within the bounds of the EU -
whether expat, resident, citizen or "just visiting".

YMMV though, so definitely worth engaging your GC to get their take and
enable your senior management to make an informed risk decision about the
whole thing.

Brian


--
Brian T. Huntley
Director of Network Services and Information Security
Office of Information Technology
Clarkson University
315.268.6723 <(315)%20268-6723>

On Mon, Jan 8, 2018 at 9:50 AM, Pardonek, Jim <jpardonek () luc edu> wrote:

Good Morning,



We have been having some discussions regarding what population’s records
are subject to GDPR.  The discussion centers around whether or not the
records of US citizens that study abroad fall under GDPR.  Some say it’s
only those who are citizens of the EU.  Is there any guidance on this topic?



Thanks and have a great day.



Jim



*James Pardonek, MS, CISSP, CEH*

*Information Security Officer*


* Loyola University Chicago  1032 W. Sheridan Road | Chicago, IL
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*From:* The EDUCAUSE Security Constituent Group Listserv [mailto:
SECURITY () LISTSERV EDUCAUSE EDU] *On Behalf Of *Joanna Grama
*Sent:* Monday, October 2, 2017 9:16 AM
*To:* SECURITY () LISTSERV EDUCAUSE EDU
*Subject:* [SECURITY] October 24 GDPR Webinar from Tambellini Group and
EDUCAUSE



Good morning,

Many of us continue to struggle with understanding the scope and finer
points of the EU GDPR and its application to US higher education
institutions. To that end, EDUCAUSE and the Tambellini Group have been
working together to share more information on this topic and we are pleased
to announce an upcoming webinar that you may be interested in.



The jointly sponsored webinar will be held on Tuesday, October 24, 2017,
from 1-2pm ET.  You can register for the webinar and read more about the
webinar content here:  https://marketing.thetambellin
igroup.com/acton/media/10722/gdpr-and-us-higher-education-
institutions-webinar



As GDPR questions have been coming up on our various EDUCAUSE lists, we
have been sharing those questions with the Tambellini group so that they
can be specifically addressed in the upcoming webinar.



Kind regards,

Joanna



*(This message has been cross posted on the EDUCAUSE security, privacy,
and IT GRC discussion listservs.)*



*Joanna Grama, JD, CISSP, CRISC, CIPT*
Director of Cybersecurity and IT GRC Programs



*EDUCAUSE*
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