Data Classification and Usage Guidelines
All students, employees, volunteers and contractors/agents at Hope College possess and/or access information that should be protected, and each individual plays a crucial role safeguarding that information. The purpose of this document is to assist with identifying and categorizing data that requires protection, as well as to set expectations and limitations for storing, transmitting, processing, sharing and protecting information based on its category.
Data Classification
Information owned, used, created or maintained by Â鶹ÊÓƵÍøÕ¾ is classified as outlined below. In the event there is uncertainty about how to classify a type of data, assume it to be in a more protected category until definitively determined otherwise. Questions regarding classification should be directed to one’s supervisor or department/division head in consultation with the Director of CIT.
Protected
- Data that is required by law or contract to be entirely private.
- A breach or inadvertent disclosure would violate state or federal privacy or data security laws and may involve criminal or civil penalties.
- Includes data protected by GLBA and the Michigan Identity Theft Protection Act.
Outside of one’s own personal information, few individuals have access to data in this category and only when strictly required to fulfill their assigned and defined duties.
Data in the Protected category should be shared only in rare cases and never by email. If an unexpected request is received for this information, it should be fulfilled only after definitively verifying (typically with a colleague or supervisor) the request’s validity and appropriateness.
Confidential
- Data that should not be discussed or disclosed to others except as required to perform one’s job.
- A breach or inadvertent disclosure would impact Hope College’s reputation or violate educational privacy requirements (FERPA).
- Includes education records for students (as defined by Hope College policy).
While only a few individuals have access to data in the Confidential category at an institutional scale, many require access to subsets to fulfill their assigned duties.
Internal
- Information that is potentially sensitive and is not actively shared with the public, but is generally shared broadly within Hope College.
- Should not be disclosed outside of Hope College without permission.
In general, many or all individuals with a Hope College login have access to data in this category while those without such a login do not.
It is the responsibility of the department/division that is primarily responsible for a type of data to designate that information as Internal when appropriate.
Public
- Information that may be disclosed to any person regardless of their affiliation with Hope College.
- Applies to data that do not require any level of protection from disclosure.
- Includes directory information for students (as defined by Hope College policy).
Data in this category could potentially be available through Internet searching or Hope College’s public website. If any/all Public data were exposed or published broadly, there would be no negative ramifications to Hope College or individuals.
Example Data Classifications
The following is a non-exhaustive sampling of data classifications. When it is unclear how a type of data should be classified, it should be treated as Protected until determined otherwise.
| Type of Data | Data Classification |
|---|---|
| Social Security numbers | Protected |
| Bank account numbers | Protected |
| Driver license numbers | Protected |
| Medical records | Protected |
| Education records | Confidential |
| Job applicant information | Confidential |
| Student applicant information | Confidential |
| Alumni information | Confidential |
| Institutional financial information & budgets | Confidential |
| Vendor and third-party contract terms | Confidential |
| Building floorplans | Internal |
| Student contact details | Internal |
| Proprietary business strategies/budgets | Internal |
| Security-focused technical configurations | Internal |
| Event calendars | Public |
| Athletic team rosters | Public |
Storage/Processing of Classified Data
The following is a non-exhaustive sampling of data storage/processing options detailing the classification(s) of data where use is appropriate. The absence of a class means the data cannot be stored/processed using that site/service.
| Location/Service | Data Classification |
|---|---|
| Enterprise software applications licensed by Hope College and designed specifically for managing such information (e.g. Banner, Slate) | Can be used for Protected, Confidential, Internal, Public |
| On-campus network storage (U: drive) | Can be used for Protected, Confidential, Internal, Public |
| Moodle and Canvas (only instances that have been set up by CIT) | Can be used for Confidential, Internal, Public |
| Local computer storage (e.g. internal drive, C: drive) |
Can be used for Confidential, Internal, Public. Can be used for Protected only when encrypted, when EDR software is installed and when lockscreen timers are enabled. |
| Removable/portable physical storage (e.g. flash drive, portable drive) | Can be used for Internal, Public |
| Google Workspace Core Services (e.g. Gmail, Drive, Meet, Gemini) when accessed using a Hope account | Can be used for Confidential, Internal, Public |
| Google Workspace non-Core Services or any Google service accessed without using a Hope account | Can only be used for Public |
| Artificial intelligence tools that are not explicitly named in this document | Can only be used for Public |
| Other storage services (e.g. Dropbox) | Can only be used for Public |
| Any location/service that has not been contracted by Hope College and vetted by a qualified Hope College employee to ensure security, privacy and compliance | Can only be used for Public |
| Non-electronic physical media (paper, film, fiche, etc.) |
Can be used for Internal, Public Can be used for Protected or Confidential only when the room containing the paper is occupied by the individual whose duties require access or when secured in a locked filing cabinet. |
Artificial Intelligence and Hope College Data
Hope College requirements to protect data extend to all areas of artificial intelligence (AI). AI tools that are free and/or are not licensed by Â鶹ÊÓƵÍøÕ¾ in an enterprise manner have the potential to expose this data to both current and future unintended uses. The contracts and business models for AI tools are complex, requiring consideration and analysis beyond what is necessary for non-AI services. Excluding data from training is not, on its own, sufficient; many other protections must be ensured.
While all aspects of this document apply universally to both AI and non-AI situations, for the purpose of clarity:
- Protected data may not be used with any AI tool.
- Google Gemini is the only AI tool that may be used with Confidential and Internal data, but only when Gemini is accessed using a Hope College account.
- Public data may be used with any AI tool.
It is not the intention of CIT to develop and enforce policies to bureaucratically offend and limit the people it serves; rather, these policies exist to ensure reliable, secure and fair technology solutions continue at Hope College.
As you read this policy statement, please keep in mind that its intention is to maintain an excellent technology infrastructure and not to limit creativity, academic freedom, or other appropriate and welcomed activities.
workP. 616.395.7670
cit@hope.edu