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Electronic Data Disposal Procedure

Procedure
Purpose: 

The purpose of this procedure is to implement the University of Kansas Electronic Data Disposal Policy.

Applies to: 

University employees (e.g., faculty, staff, student employees) and other covered individuals (e.g., affiliates, vendors, independent contractors, etc.) in their handling of University data, information, and records in electronic form during the course of conducting University business (administrative, financial, teaching, research, or service).

Campus: 
Lawrence
Policy Statement: 

Overview

When a file is deleted, the operating system does not completely remove the file from the disk; rather, the file deletion removes only the reference to the file from the file system table. The file remains on the disk until a subsequent file is created over the original file. However, even after the file is overwritten, it is possible to recover data from the original file by studying the magnetic fields on the disk platter surface if the drive was manufactured before 2001. This is referred to as a “laboratory attack”. Other drives may contain data that can be retrieved with specialized software. This is referred to as “deleted file retrieval”. The only way to prevent these kinds of inadvertent file sharing or file access is to appropriately clean (e.g., sanitize) the hard drive or other media by performing a data wipe or over-write, or to physically destroy the hard drive or other media before it reaches its next owner or destination. The required procedures for performing a data wipe or over-write, or for physically destroying the hard drive or other media, are set forth below.

Any official University records must be appropriately retained / disposed of based on the University’s records retention policy prior to cleaning or destruction of the system, device, or media.

Overwriting Hard Drives or other Media

The sanitization method for the media depends on the information stored on the media, the age of the media, and on its next destination. The following table should help decide how to handle a particular computer or device.

NIST Special Publication 800-88, “Guidelines for Media Sanitization”, defines the terms and methods for sanitizing hard drives and other media.

Clearing: Overwriting the media

Purging: Magnetic erasure of the media

Destruction: Physical destruction of the media

Examples of Sensitive and Confidential Information include, but are not limited to, the following data types:

  • Social Security Numbers
  • Student educational records
  • Health care records
  • Bank account and other financial information
  • Research data
  • Personnel data
  • Other confidential or sensitive University business information
  • Proprietary software

If you need assistance removing data, or if you are not sure whether the data stored on a device is Sensitive or Confidential, please contact the IT Security Office at 785-864-9003 or itsec@ku.edu.

New Location of Device Data stored on Device Recommendation
Same department No Sensitive/Confidential data Reformat or reimage
Another department or unit No Sensitive/Confidential data Reformat or reimage
Same department to staff with access to same information Sensitive/Confidential data Reformat or reimage
Same department to staff with lower access (or student worker) Sensitive/Confidential data Clear
Another department or unit Sensitive/Confidential data Clear
Recycling or disposal (including surplus) All data Clear
Drive manufacture date prior to 2001 or unknown Sensitive/Confidential data Purge
Non-functioning media All data Purge (magnetic); Destroy (solid state)

The most current research on data retrieval indicates a single pass of random data or zeros (Clearing) is all that is required to sanitize a functioning hard drive manufactured after 2001. Clearing the drive prevents deleted file retrieval. Laboratory attacks are not possible on modern hard drives.

Tools

To properly clean your electronic media, please use the utility called "Darik's Boot and Nuke" (DBAN).

This tool will create an easy-to-use cleaning floppy or CD that can be used in most computers. It will allow you to boot from the media and begin the cleaning process without needing to install any other software on the computer. DBAN allows you to choose a number of options.

Physical Destruction of Hard Drives or other Media

If the computer system, electronic device, or electronic media will not be reused, physical destruction is an acceptable method of disposing of the University data. Individuals desiring to have a computer system, electronic device, or electronic media destroyed may contact the IT Customer Service Center (CSC) at 864-8080 to arrange for drop-off or pick-up of their eWaste.

eWaste Delivered to the Computing Services Facility (CSF)

  1. All items must have been approved for disposal following University disposition of property guidelines.
  2. Department must have the hard drives removed from CPU’s and Servers before they are delivered to the CSF loading dock.
  3. Department must have University of Kansas/IT Department eWaste Processing Form filled out before bringing items to CSF dock.
  4. When hard drives are degaussed, departments requesting confirmation will be sent a Certificate of Destruction. All certificates must be signed by a fulltime IT employee.
  5. Department will be charged for disposal of CRT’s and televisions at the current published rate, provided on the eWaste Recycling site.

eWaste Pickup Procedure

  1. All equipment must have been approved for disposal following University disposition of property guidelines.
  2. Departments must remove hard drives from CPU’s and Servers before pick-up.
  3. Departments must call the IT CSC to schedule a pick-up.
  4. Departments must fill out a University of Kansas/IT Department eWaste Processing Form before equipment is picked up for disposal.
  5. When hard drives are degaussed, departments requesting confirmation will be sent a Certificate of Destruction. All certificates must be signed by a fulltime IT employee.
  6. Department will be charged for disposal of CRT’s and televisions at the current published rate, provided on the eWaste Recycling site.
Consequences: 

Faculty, staff, and/or student employees who violate this University policy may be subject to disciplinary action for misconduct and/or performance based on the administrative process appropriate to their employment.

Students who violate this University policy may be subject to proceedings for non-academic misconduct based on their student status.

Faculty, staff, student employees, and students may also be subject to the discontinuance of specified information technology services based on the policy violation.

Contact: 

Office of the Chief Information Officer
1001 Sunnyside Avenue 
Lawrence, KS 66045
785-864-4999
kucio@ku.edu

Approved by: 
Provost and Executive Vice Chancellor
Approved on: 
Thursday, August 14, 2008
Effective on: 
Thursday, August 14, 2008
Review Cycle: 
Annual (As Needed)
Definitions: 

These definitions apply to these terms as they are used in this document.

Sanitization (of computer hard drives): Removing data on a system through one or more various methods that may include overwriting or erasing data utilizing the methods described in NIST Special Publication 800-88.

Confidential Information: Subset of Private Information that includes information protected by state and/or federal law and information that the University is contractually obligated to protect. The mishandling of Confidential Information may impact the University through financial and legal sanctions, loss of public confidence, and damage to the University’s reputation. Examples of Confidential Information include Social Security numbers, bank account information, BPC account numbers, healthcare records, educational records, and risk assessments that highlight potential weaknesses in the University’s utility/service infrastructure.

Degaussing: Process by which storage media is subjected to a powerful magnetic field to remove the data on the media.

eWaste: Discarded electronics.

Reformat: (Computing) format again after a previous use, especially to clean a disk drive (or partition) so it contains no data and only formatting information.

Reimaging: Reimaging is the process of removing all software on a computer and reinstalling everything. A “reimage” is necessary if your operating system becomes damaged or corrupted. You may also need to reimage if your system is plagued with spyware problems. The word “reinstall” is often used in place of “reimage”.

Sensitive Information: Subset of Private Information that includes non-public information (other than Confidential Information) that may cause harm to the University or to individuals if inappropriately used or disclosed. This category includes, for example, research data with commercial or societal value, and individual works of intellectual property.

Keywords: 
Secure data disposal, electronic shredding, erasing media, data removal, discarding computers, data wipe, eWaste, media sanitization
Change History: 

01/26/2022: Updated contact section.
01/27/2015: Policy formatting cleanup (e.g., bolding, spacing).
11/17/2014: Policy formatting cleanup (e.g., bolding, spacing).
08/17/2010: Updated to reflect NIST Guidelines for Media Sanitization.
07/21/2009: Updated to include eWaste recycling process.

Information Access & Technology Categories: 
Privacy & Security

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