Sanitization and Disposal of Information Resources Policy
A large volume of University Data is stored on Systems (as each such term is defined in the Columbia University Information Security Charter (the “Charter”)) throughout Columbia University. A substantial amount of such Data consists of Sensitive Data or Confidential Data. Unauthorized disclosure of such Data may expose the University to legal liability. Data sanitization is the deliberate and permanent removal of University Data from an Information Resource. This Policy defines the appropriate sanitization and disposal methods to be used.
Capitalized terms used herein without definition are defined in the Charter.
II. Policy History
The effective date of this Policy is November 1, 2013. This Policy and the other Information Security Policies replace (A) the following University Policies:
- Data Sanitization and Disposal of Electronic Equipment Policy, dated January 1, 2008, as amended in February 2008
- Electronic Information Resources Security Policy, dated March 1, 2007
and (B) the following CUIMC Policy:
- Information Security: Backup, Device and Media Controls
III. Policy Text
Each System Owner, Data Owner, IT Custodian and User is responsible for determining if Sensitive Data is present on an Information Resource by, for example, periodically scanning the Information Resource using software provided by CUIT or CUIMC IT, and sanitizing all Information Resources with hard drives and Removable Media under his/her control prior to removal from the University in accordance with the following guidelines:
A. Non-Sensitive Data.
University Data other than Sensitive Data may be deleted and/or reformatted.
B. Sensitive Data.
Sensitive Data must be sanitized or disposed of in a manner that leaves such Data fully unrecoverable. Except as provided below, this can be accomplished by using one of the following methods:
- Data deletion software provided by CUIT or CUIMC IT data disposal processes;
- Information Security Office-approved destruction hardware to physically render the Sensitive Data storage media inoperable, such as degaussing, shredding, pulverizing or melting;
- Release of the Information Resource containing storage media to CUIT or CUIMC IT for destruction and disposal; or
- Release of the Information Resource containing storage media to an Information Security Office-approved vendor.
Sensitive Data constituting EPHI must be sanitized and disposed of in accordance with the CUIMC Information Security Procedures.
C. Paper Based Data
All paper based Sensitive Data or Confidential Data must be destroyed using cross-shredding or through a contract with an Information Security Office approved-vendor.
IV. Cross References to Related Policies and Other Documentation
The Information Security Policies and certain additional documentation referred to in this Policy are listed in Appendix A hereto.