Re: GDPR Question - Part 2

["Madl, Michael" <michael.madl () INDWES EDU>]

I had the same thought (approach) but after speaking to financial aid in regards to Fed retention requirements (I 
believe it is 3 years from the end of the award year) I don’t think a broad brush approach will work for all students.

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Hart, 
Michael
Sent: Thursday, February 8, 2018 3:57 PM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: Re: [SECURITY] GDPR Question - Part 2

I was under the impression that the GDPR protections applied to EU citizens while they are in the EU.  Regardless of 
where our systems and data are residing, the citizenship and location of the individual is what we were told to focus 
on.

I find it daunting to sort through the various directions different interpretations take us.  I am working with our GC 
and shared governance groups to get a campus interpretation we can work with.  I think we’ll be trying to provide this 
GDPR treatment to all data, as I think it’s easier than trying to cherry pick whose data was relevant during which time 
period.

The good news is this is getting attention from our GC office, and they’re really starting to focus on records 
retention and data governance overall, not just specific compliance issues.  I’m astounded by the number of departments 
that haven’t heard of GDPR.

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Theresa 
Rowe
Sent: Thursday, February 8, 2018 1:09 PM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: [SECURITY] GDPR Question - Part 2

Around January 8, there was an interesting discussion about the scope of records covered by GPDR.  At one point, John 
Denune summarized it nicely as:
From the EDUCAUSE/Tambellini Group webinar, one of the scenarios presented involved a US faculty member visiting 
Finland on sabbatical. While in Finland, the scenario concluded that:

  *   All personal data the faculty member sends back to the home institution falls under GDPR
  *   This includes the personal data of her US PhD students that she may send back to the US
  *   This also may include all personal data she has with her when she returns to the US.

So let's say you've determined the scope with your GC.  As an IT professional, what are you doing to comply?
At this point, we are documenting our existing data privacy owners, our security officer, our policies on privacy, and 
reusing existing policy.  Are you finding an big action that requires attention?
Theresa Rowe
Chief Information Officer
Oakland University


On Mon, Jan 8, 2018 at 9:50 AM, Pardonek, Jim <jpardonek () luc edu<mailto: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
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From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () 
LISTSERV EDUCAUSE EDU>] On Behalf Of Joanna Grama
Sent: Monday, October 2, 2017 9:16 AM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto: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.thetambellinigroup.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
Uncommon Thinking for the Common Good
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