Data Breach Response Policy

Scope

This policy covers all computer systems, network devices, and any additional systems and outputs containing or transmitting Loyola Protected data or Loyola Sensitive data.

Purpose

The purpose of this policy is to provide a process to report suspected thefts involving data, data breaches or exposures (including unauthorized access, use, or disclosure) to appropriate individuals; and to outline the response to a confirmed theft, data breach or exposure based on the type of data involved.

Policy

Reporting of suspected thefts, data breaches, or exposures

Any individual who suspects that a theft, breach or exposure of Loyola Protected data or Loyola Sensitive data has occurred must immediately provide a description of what occurred via email to DataSecurity@luc.edu, by calling 773-508-7373, or through the use of the anonymous reporting web page at https://www.luc.edu/its/uiso/contacttheuiso/report_anon.shtml. This email address, phone number, and web page are monitored by Loyola’s Information Security team.  This team will investigate all reported thefts, data breaches, and exposures to confirm if a theft, breach, or exposure has occurred. If a theft, breach, or exposure has occurred, the Information Security team will follow the University Incident Response Plan accompanied by the Incident Response Appendix for the appropriate procedure depending on the class of data involved.

If the incident is a suspected theft, Loyola’s Department of Campus Safety shall also be contacted at 773-508-6039.  They will determine whether a local law enforcement agency should be contacted based on the location and details of the incident.  If a local law enforcement agency is contacted, the name of the agency and the report number should be provided to Loyola via the methods of contact outlined above.

Confirmed theft, data breach or exposure of Loyola Protected data or Loyola Sensitive data

As soon as a theft, data breach, or exposure containing Loyola Protected data or Loyola Sensitive data is identified, the process of removing all access to that resource will begin as soon as possible.  If the information is available on a site outside of Loyola, that site will be contacted to have the information removed as soon as possible.

The CISO, under direction of the CIO, will chair a response team to handle the breach or exposure. The team will include members from:

• ITS
• University Marketing and Communications (UMC)
• The Office of the General Counsel, Risk Management
• The affected unit or department that uses the involved system or output or whose data may have been breached or exposed
• Additional departments based on the data type involved, as listed in the appendix
• Additional individuals as deemed necessary by the CISO

If a theft of physical property occurred, the Department of Campus Safety will be notified by ITS. This team will provide information to UMC regarding how the breach or exposure occurred, the types of data involved, the Loyola classifications of those data types, any protective measures around the involved data (such as encryption), and the number of internal/external individuals and/or organizations impacted. UMC will handle all communications about the breach or exposure.  ITS will work with the appropriate parties to remediate the root cause of the breach or exposure.

Confirmed theft, breach or exposure of Loyola Public data

The CISO will be notified of the theft, breach or exposure, and will inform UMC as soon as possible. ITS will analyze the breach or exposure to determine the root cause.  ITS will work with the appropriate parties to remediate the root cause of the breach or exposure. ITS will also examine any involved systems to ensure that they did not also house any Loyola Protected data or Loyola Sensitive data. If the systems are found to also contain Loyola Protected data or Loyola Sensitive data, the CISO will be notified and the “Confirmed data breach or exposure of Loyola Protected data or Loyola Sensitive data” section of this policy will be invoked. If a theft of physical property occurred, the Department of Campus

Safety will be notified by ITS.  The Department of Campus Safety will determine if it is also appropriate to necessary other law enforcement agencies based on where the theft occurred.

Questions about this Policy

If you have questions about this policy, please contact the Information Security team at DataSecurity@luc.edu.

Policy Adherence

Failure to follow this policy can result in disciplinary action as provided in the Staff Handbook, Student Worker Employment Guide, and Faculty Handbook. Disciplinary action for not following this policy may include termination, as provided in the applicable handbook or employment guide.