Data Policy

Last Updated
May 31, 2022

1. Introduction

This policy describes the lifecycle of data, from creation to destruction, and also addresses the backup, recovery, and security of such data.

2. Access Management

Access management refers to identification and management of access to and use of technology and information resources, including authorization and de-authorization or deactivation, physical access, and electronic access.

Staff are only given access to the files they need to perform their work duties. Initial file access is granted when a staff member begins employment, is revoked when they leave, and adjusted from time to time to ensure they continue to have only appropriate file access.

The IT Services administrator and their delegates have administrative system privileges to view and edit all IT resources, including confidential files, but such staff are forbidden from accessing confidential files unless permission has been granted from the person responsible for such files. In addition, leadership and supervisors have access to the confidential records of employees for whom they are responsible.

3. Audit Capabilities

Audit capabilities refers to a record or audit log showing who has accessed a computer system and what operations the person has performed during a given period of time. The Division maintains automatic audit logs through the cloud platforms it uses. IT Services staff have access to this data on an as required basis.

4. Data Export and Transfer Capabilities

Personal devices used for accessing organizational data must be in compliance with the Division’s policies on personal devices for work use. In addition, confidential data accessed from personal devices must not be stored outside the cloud filesystem for more than 15 minutes at any given time and then only for the purposes of file processing or transformation.

Confidential documents about program participants are never to be transferred by email without the participant’s express consent.

5. Virtual Private Network

Connection to the organizations network resources must be accomplished through the use of a virtual private network (VPN) so that resources and systems can be accessed remotely in a secure manner.

Remote access to other desktop, laptop, or mobile devices must use either Microsoft Remote Desktop Protocol, Secure Shell (SSH), or NVDA Remote via servers and be appropriately secured to avoid the leakage of confidential data.

Remote technical support may only be administered to devices storing confidential organization data by COBD IT Services staff.

6. Digitization of Confidential Physical Files

Physical files containing confidential participant information dated after January 1, 2011 must be digitized and physical copies destroyed unless required to be held for a period of time for legal or regulatory purposes and, if this is the case, they shall be digitized and physical copies destroyed when no longer needed. Physical copies of data must be secured with appropriate measures to ensure confidentiality.

7. Backup and Recovery

The Division uses cloud storage to backup all Division-related files. The recovery functionality of the cloud provider is used to recover files in the event of accidental file deletion, data loss, or data corruption. If needed, IT Services can advise on the procedure for recovering files through the individual cloud provider’s interface.

Backup and recovery is tested and documented at least annually as part of the testing of the Business continuity/disaster recovery procedure.

8. Business continuity/disaster recovery

The Division’s Business continuity/disaster recovery procedure is used to help the Division recover from a disaster and continue or resume routine operations. Business continuity addresses the availability of essential operational functions and processes during and after a disaster and may include the replacement of personnel, service availability issues, operational impact analysis, and change management. The Division’s disaster recovery portion of the procedures includes, as applicable, server and network restoration, hardware replacement, and restoring access to backup data from backup systems.

Testing of this procedure is carried out, analyzed, and documented at least annually. Analysis covers the effectiveness, any areas needing improvement, any actions to address the improvements needed identified in the previous test,. any implementation of the actions identified in the previous test, whether the actions taken accomplished the intended results, and any necessary education and training of personnel that may be required.

9. Destruction of Data

When the Division decommissions hardware, all data on such hardware must be properly destroyed. All computer or server hard drives that support the functionality must be wiped with a 7-pass wipe that also writes random data to disk on each pass. All encryption keys used to encrypt data must be disposed of and properly removed from the device. Non-functioning hard drives must be disposed of through an appropriate entity specializing in the secure destruction of hard drives.

10. Legal and Regulatory Compliance

Data must be stored in compliance with all applicable organizational procedures, policies, and bylaws, as well as any applicable bylaws, laws, and regulations from outside the organization.

11. Review

This policy will be reviewed at least annually and updated as needed.