Level 4

Report location and volumes of identifiable records with full Social Security Numbers annually

SSN4: The Harvard “business owner” of any records containing identifiable records with full SSNs, whether electronic or paper, stored by the Harvard unit or by a vendor, must annually report that there are such records and describe the system or systems on which they are maintained, the retention schedule, the location of the system(s), and the approximate number of such records containing full SSNs.

 

Dispose of or archive identifiable records with full Social Security Numbers securely when retention no longer required by law

SSN3: When no longer required by law or for the business purpose approved through the exception process, electronic or printed identifiable records containing full SSNs and not subject to a legal hold must be properly disposed of so that the information cannot be retrieved or reassembled. In cases where selected records are identified as having archival value, such as stated in the General Records Schedule, those records are to be transferred securely to the Harvard University Archives (HUA), school-specific archives, or appropriate Harvard specialty archives and then securely removed from...

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Compile and maintain identifiable records with Social Security Numbers only when required by law

SSN2: New collection processes or new research grants effective on or after July 1, 2017: Identifiable records containing full SSNs may be compiled and maintained only to comply with a specific legal requirement. Full SSNs plus identifiable information may only be used or printed in documents where it is legally required. Identifiable records with full SSNs may not be compiled or maintained if there is no legal requirement for that specific data. For example, maintaining full SSNs only as a tool for differentiating records does not satisfy a legal requirement; the same purpose could be...

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Central Authentication Services

SB12: Servers or applications handling data classified as L3 or higher, whether managed directly by Harvard or a contracted vendor (e.g. SaaS), must use a centrally-managed Harvard authentication system where feasible, e.g. HarvardKey or HUIT Active Directory, or an authentication system approved by the School or University CIO.