Re: GDPR Question - Part 2

[Karl Kowalski <kekowalski () ALASKA EDU>]

But if I'm not mistaken, the Federal Financial Aid retention policy would
serve as your "legal basis" for data retention. And should an EU citizen
ask to be expunged, that data could still be retained for the retention
period. You would just need to document that and inform the customer.  But
would like to hear others' thoughts/interpretations if I'm wrong..

Karl

On Thu, Feb 8, 2018 at 12:06 PM, Madl, Michael <michael.madl () indwes edu>
wrote:

> 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 <SECURITY () LISTSERV EDUCAUSE EDU>] *On
> Behalf Of *Theresa Rowe
> *Sent:* Thursday, February 8, 2018 1:09 PM
> *To:* 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> 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
> <https://maps.google.com/?q=1032+W.+Sheridan+Road+%7C+Chicago,+IL%C2%A0%C2%A060660+%0D+*+%0D+(**:+(773*&entry=gmail&source=g>
>   60660
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> *
> * (**: (773
> <https://maps.google.com/?q=1032+W.+Sheridan+Road+%7C+Chicago,+IL%C2%A0%C2%A060660+%0D+*+%0D+(**:+(773*&entry=gmail&source=g>)
> 508-6086*
>
>
>
> *Loyola University Chicago will never ask your for your username or
> password.*
>
> *For the lastest information security news at Loyola, please follow us
> online,*
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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.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*
> 282 Century Place, Suite 5000, Louisville, CO 80027
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> direct: 720.406.6769 <(720)%20406-6769> | cell: 720.507.5983
> <(720)%20507-5983> | jgrama () educause edu
>
>
>
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-- 
Karl Kowalski, Chief Information Technology Officer
University of Alaska
Office of Information Technology
2025 Yukon Drive, Suite 103
Fairbanks, Alaska  99775

Phone: 907-450-8383
http://www.alaska.edu/oit

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