91ֱ��

Purpose

This Policy establishes an enterprise-wide oversight framework to support effective Information Governance across the 91ֱ�� and facilitate the integration of the following standards and attributes into applicable 91ֱ�� decision-making:

1. Authenticity;
2. Availability;
3. Confidentiality;
4. Data Governance;
5. Data Mapping;
6. Data Minimization;
7. Integrity;
8. Privacy; and
9. Security.

1. This Policy applies to all 91ֱ�� operations involving 91ֱ�� Information or its Information Resources.
2. This Policy applies to all 91ֱ�� Employees as well as adjunct faculty, Contractors, consultants, temporary employees, and other third parties performing duties on behalf of the 91ֱ��.

Definitions

Defined terms are capitalized throughout this Policy and can be found in the Information Governance Glossary.

1. The 91ֱ�� shall establish an Information Governance Team (”IGT”) comprised of representatives from the various functional areas of the 91ֱ��. The primary responsibilities of the IGT shall be to:
   1. Provide interdepartmental oversight and strategic management of the 91ֱ��'s Information and Information Resources;
   2. Facilitate the integration of Privacy by Design into 91ֱ�� operations; and
   3. Support the development and review of Information Governance related policies and procedures across the 91ֱ��.
2. The 91ֱ�� shall establish an Information Governance Operations Team that shall provide support to the Information Governance Team by performing the following tasks, among others, on behalf of the Information Governance Team:
   1. Provide all necessary background information and research materials on topics put before the Information Governance Team for review or approval.
   2. Provide frequent and regular updates on on-going matters previously introduced to the Information Governance Team for review or approval.
   3. Determine topics for Information Governance Team to review, discuss and/or approve.
   4. Ensure that all tasks required to enforce decisions determined by the Information Governance Team are completed in a timely, effective, and efficient manner.
   5. This group shall meet as needed to collate, review, and evaluate Information Governance topics.
3. 91ֱ�� Employees and third parties performing duties on behalf of the 91ֱ�� shall consult with the 91ֱ��'s Data Protection Officer ("DPO") and, when applicable, the IGT when:
   1. Initiating a new program, project, policy, practice, acquisition, or business operation that involves Information Resources or the Processing of 91ֱ�� Information;
   2. Updating an existing program, project, policy, practice, acquisition, or business operation that involves Information Resources or the Processing of 91ֱ�� Information; and
   3. Assessing other issues that may fall under the scope of Information Governance.