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Secure Movement of Physical and Electronic Files

Policy
Purpose: 

To provide guidance to KU faculty, staff and researchers when planning a move of office files from one location to another, regardless of media used.

Applies to: 

All University of Kansas faculty, staff and research units reporting to the Lawrence campus.

Campus: 
Lawrence
Edwards
Parsons
Juniper Gardens
Yoder
Topeka
Policy Statement: 

When a unit is planning a move to a new location and that unit possesses University files and systems, it is essential for these files and systems to be handled and relocated in a secure fashion. 

Depending upon the nature of files being moved, there may government regulations that mandate securing such files from unauthorized access and an office move may introduce certain risks that must be addressed and mitigated.

Special consideration must be given to the means by which files, either paper-based or electronic, are to be transferred to new location.  The University is responsible for compliance with federal and state laws and regulations as well as Kansas Board of Regents and university policies. In order to ensure that files are handled in a manner that complies with laws, regulations, and policies, unit leaders are advised to review the Factors for Assessing Security Needs for File Relocation document below.

If the unit leadership believes their personnel cannot physically and securely handle the file move for whatever reason, the University does provide resources to assist in planning and moving of files. The unit leadership can begin the process by submitting an online work request.  A staff member from Special Services (under Campus Operations) will assess the scope of the move and help the unit leadership develop a plan.  Depending upon the scope, it may be necessary to use an outside, University contractor to move the files.  Any related costs will be the responsibility of the unit being moved.

If the files are partially or totally contained within electronic systems, the unit leadership must engage with the Information Technology Security Office (ITSO) to determine the best means for accomplishing this move in a secure fashion.  See ITSO contact information below.

If files or systems are being moved by another University unit or by a University contractor, good business practice means having an accurate inventory of the files being moved and having both parties sign-off on the inventory.

Once the files or systems are delivered to the new location, both parties should validate that all materials were delivered per the inventory and sign an acknowledgement to that fact.

Implementing File Relocation
If files are to be moved by anyone other than authorized unit personnel, the leadership must consider how the “chain of custody” for the files can be assured during the move.  For example, it may be necessary to use a van or truck that can be secured with a lock for which only the leadership will have the keys during the move. It may also be appropriate for the unit leadership to follow the vehicle from the old to the new location.

Contact: 

Physical files:
Special Services, Campus Operations
Facilities Services
1503 Sunflower Road
Lawrence, KS 66045-7617
785-864-4770

Electronic files:
Information Technology Security Office (ITSO)
1001 Sunnyside Ave.
Lawrence KS 66045
itcsc@ku.edu
785-864-8080

Approved by: 
Provost and Executive Vice Chancellor
Approved on: 
Thursday, March 16, 2017
Effective on: 
Friday, March 17, 2017
Review Cycle: 
Biennial (Every Two Years)
Definitions: 

Chain of Custody:  Refers to a documentation process identifying the individuals responsible for and the chronology of the custody, control, transfer, and disposition of files.

Keywords: 
Confidentiality, relocate, record, health, transport, protected, cabinet
Change History: 

03/17/2017: Policy uploaded to Policy Library. 


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