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Increasing amounts of electronic data are being transmitted and stored on computer systems and electronic media by virtually every person conducting business for UNC-Chapel Hill. Some of that data contains sensitive information, including student records, personnel records, financial data, and protected health information. If the information on those systems is not properly removed before the equipment is disposed of, that information could be accessed and viewed by unauthorized individuals. As such, all users of computer systems within UNC-Chapel Hill, including contractors and vendors with access to UNC systems, are responsible for taking the appropriate steps, as outlined below to ensure that all computers and electronic media are properly sanitized before disposal. Electronic Media is defined as any electronic storage device that is used to record information, including, but not limited to hard disks, magnetic tapes, compact disks, videotapes, audiotapes, and removable storage devices such as floppy disks and zip disks.
The purpose of this policy is to establish a standard for the proper disposal of electronic media containing sensitive data. The disposal procedures used will depend upon the type and intended disposition of the media. Electronic media may be scheduled for reuse, repair, replacement, or removal from service for a variety of reasons and disposed of in various ways as described below.
The scope of this policy includes all personnel who are responsible for or who use UNC-Chapel Hill computer systems. Vendors and contractors who have access to UNC-Chapel Hill computer systems are also subject to this policy.
All electronic media must be properly sanitized before it is transferred from the custody of its current owner. The proper sanitization method depends on the type of media and the intended disposition of the media.
Overwriting Hard Drives for Sanitization
Overwriting is an approved method for sanitization of hard disk storage media. Overwriting of data means replacing previously stored data on a drive or disk with a random pattern of meaningless information. This effectively renders the data unrecoverable, but the process must be correctly understood and carefully implemented. Overwriting consists of recording data onto magnetic media by writing a pattern of fluxes or pole changes that represent binary ones (1) and zeros (0). These patterns can then be read back and interpreted as individual bits, 8 of which are used to represent a byte or character. If the data is properly overwritten with a pattern (e.g., “11111111” followed by “00000000”) the magnetic fluxes will be physically changed and the drives read/write heads will only detect the new pattern and the previous data will be effectively erased. To purge the hard drive requires overwriting with a pattern, and then its complement, and finally with another pattern (e.g., overwrite first with “00110101 “, followed by “11001010”, then “10010111”). Sanitization is not complete until the third overwrite passes and a verification pass are completed. A variety of software packages are available on the open market that properly perform this function. Examples of software programs that can be used to overwrite media include Pretty Good Privacy, Eraser, and KillDisk.
Destruction of Electronic Media
Destruction is the process of physically damaging a medium so that it is not usable by any device that may normally be used to read electronic information on the medium, such as a computer, tape reader, audio or video player.
Transfer of Hard Drives to Other Departments or Outside of UNC-Chapel Hill
Prior to transfer, operable hard drives must be overwritten in accordance with the procedures in paragraph A1 above. Departments should maintain documentation of proper sanitization for hard drives. Equipment designated for surplus or other re-use should have a label affixed stating that the hard drive has been properly sanitized.
Transfer of Hard Drives Within a Department
Before a hard drive is transferred from the custody of its current owner, appropriate care must be taken to ensure that no unauthorized person can access data by ordinary means. All electronic media should be sanitized per paragraph A1, however; because the drive is remaining within the department, the hard drive may instead be formatted prior to transfer. Insofar as special recovery tools would have to be used by an individual to access the data erased by this method, any attempt by an individual to access unauthorized data would be viewed as a conscious violation of state or federal regulations and the UNC-Chapel Hill Confidentiality Statement.
Sending a Hard Drive Out for Repair or for Data Recovery
The vendor repairing or recovering data on the hard drive must sign an appropriate agreement with UNC, insuring that the vendor will take proper care of the data. Once data is recovered or the hard drive is repaired, the original hard drive must be returned to the owner so that the owner can then handle it as per this UNC-Chapel Hill policy for proper disposal of hard drives.
Disposal of Damaged or Inoperable Hard Drives
The owner must first attempt to overwrite the hard drive in accordance with the procedures in paragraph A1 above. If the hard drive can not be overwritten, the hard drive must be disassembled and mechanically damaged so that it is not usable by a computer. It is recommended that a hard-drive shredding service be used to ensure mechanical damage to the hard drive so that it is no longer usuable. The Surplus Property Warehouse provides shredding services for hard drives and tape drives. If visual verification of shredding is required, contact the Surplus Property Warehouse at 962-2134 for an appointment. The shredding fee is $3.00 per hard drive, charged to your department account.
Transfer of Electronic Media Other Than Hard Drives Within a Department
Before electronic media is transferred from the custody of the current owner, appropriate care must be taken to ensure that no unauthorized person can access data by ordinary means. Electronic media such as floppy disks, rewritable CD-ROMS, zip disks, videotapes, and audiotapes should be erased if the media type allows it or destroyed if erasure is not possible.
Disposal of Electronic Media Outside of UNC-Chapel Hill
All electronic media other than computer hard drives must be erased, degaussed, or rendered unusable before leaving UNC-Chapel Hill. The University encourages use of certified commercial disposal systems such as mentioned in the Electronic Media Disposal FAQ.
If there is a reasonable basis to believe that the proper procedures as outlined in this policy have not been or are not being followed, a report must be filed with the Information Security Officer. If improperly sanitized electronic media is found, then the media should be reported to the appropriate departmental I.T. support personnel.
Any employee found to have violated this policy may be subject to disciplinary action, including but not limited to, termination under the appropriate University disciplinary policy.