Data Trustees must consult with the Vice President for Legal Affairs and General Counsel prior to approving a law enforcement request to examine, share or distribute University data. Stewards and/or Custodians of University data must escalate and report any legal or law enforcement request made of them to their respective Data Trustee prior to fulfilling any such request.
University Data
This consists of all information related to the business of Bradley University that exists in electronic, digital, printed, or other forms. It includes but is not limited to text, graphics, video, audio, still images, databases, and spreadsheets.
Data Categories
- are high-level classifications of University Data that require specific security or privacy considerations.
- represent a collection of data sets with unique access requirements; e.g., specified users, job duties, scope.
- should be granular enough to assign to a distinct university Data Trustee and Data Steward.
- should be minimal; i.e. If related sets of data have the same Data Trustee, the same Data Steward, and the same access requirements, then they should be placed in the same data category.
Data Trustees
- are members of the senior administration.
- have oversight responsibility for the portion of data that is related to the university functions managed, administered or run by the units who report to the Data Trustee.
- manage, protect, and ensure the integrity and usefulness of the data.
- identify the sensitivity and criticality of data.
- ensure appropriate business processes are in place.
- designate Data Stewards.
Data Stewards
- have primary responsibility for the accuracy, security, and privacy of a specific dataset. In some instances Data Stewards and Data Custodians may be the same individual.
- are the dataset or subject matter expert.
- implement data standards and monitor data quality.
Data Custodians
- are responsible for managing the technology and security controls around the confidentiality, integrity, and availability of the data. In some instances Data Custodians and Data Stewards may be the same individual.
- provide secure infrastructure and processes, including recoverability of data.
- control access rights.
- implement data policies.
Changes to this table
A request to change an entry in this table must be submitted in writing (email is acceptable) as follows:
- A Data Category change must be requested by the designated Data Trustee or Data Steward.
- A Data Trustee change will be handled by ?.
- A Data Steward change must be requested by the designated Data Trustee.
- A Data Custodian change must be requested by the designated Data Steward.
- The request must be submitted to the Data Governance Committee.
Trustee, Steward, Custodian and User Definitions
Table of data categories, trustees, stewards, and custodians
Academic Affairs
| Category | Trustee | Steward | Custodian | Retention Period | Retention Standard Reference |
|---|---|---|---|---|---|
| Classroom Occupation & Utilization data | Registrar | Associate Registrar | Information Technology, Illinois Record Keepers | Until Academic Need Is Satisfied (UANS) | FERPA |
| Classroom Recordings | Provost and Senior Vice President for Academic Affairs | Executive Director of Learning Design and Technology | Panopto, Zoom? | ||
| Continuing Education | Provost and Senior Vice President for Academic Affairs | Exec. Director of Continuing Education & Professional Development | Events Air | ||
| Continuing Education Unit (CEU) Operational Data | Provost and Senior Vice President for Academic Affairs | Exec. Director of Continuing Education & Professional Development | Unit-specific | ||
| Contracts and/or Grants: Pre-Award, Proposals & Submissions | Associate Provost | Director of Sponsored Programs | Office of Sponsored Programs, Information Technology, Facilities | ||
| Counseling Recordings for Classes | Provost and Senior Vice President for Academic Affairs | Online Program Director | Zoom | ||
| Event (Non-Conference) Data | Provost and Senior Vice President for Academic Affairs | Program Director, Continuing Education and Professional Development | Events Air | ||
| Event Management System (Class Scheduling) | Registrar | Office of the Registrar | Information Technology | Indefinite | FERPA |
| External Surveys (e.g. U.S. News, Princeton Review) | Provost and Senior Vice President for Academic Affairs | Director of Institutional Effectiveness | Office of Institutional Effectiveness, Enrollment Management, Student Affairs, Provost’s Office | ||
| Faculty Activity Report | Provost and Senior Vice President for Academic Affairs | Director of Institutional Effectiveness | Office of Institutional Effectiveness, Information Technology, Illinois Record Keepers, Watermark | ||
| Grant Application & Management Data | Associate Provost | Director of Sponsored Programs | Office of Sponsored Programs, Information Technology | ||
| GTS/Assistantship Data | Associate Provost | Director of Graduate Education Student Fees, HR, Payroll, Controller’s Office | Technolutions, Information Technology, Illinois Record Keepers | ||
| HLC Assurance Argument | Provost and Senior Vice President for Academic Affairs | Director of Institutional Effectiveness (ALO) | Evidence Coordinator, HLC | ||
| IBHE/ILDS Enrollment and Graduation files | Registrar | Office of Institutional Effectiveness Analyst | Office of Institutional Effectiveness, Information Technology, Illinois Record Keepers, IBHE | Indefinite | FERPA |
| International Employment Faculty VISA Files | Provost and Senior Vice President for Academic Affairs | Assistant to the Provost | Human Resources, Director of Payroll | Until faculty separate from the University | |
| IPEDS – Academic Student Records | Registrar | Office of Institutional Effectiveness Analyst | Office of Institutional Effectiveness, Information Technology, Illinois Record Keepers, IPEDS | Indefinite | FERPA |
| IPEDS Admissions | Registrar | Vice President of Enrollment Management | Registrar’s Office, Enrollment Management, IPEDS | Indefinite | FERPA |
| IPEDS Financial | Registrar | Controller | Controller’s Office, Registrar’s Office, Information Technology, Illinois Record Keepers, IPEDS | Indefinite | FERPA |
| IPEDS Financial Assistance | Registrar | Director of Financial Assistance | Registrar’s Office, Financial Aid Office, IPEDS | Indefinite | FERPA |
| IPEDS HR Data | Registrar | Director of Human Resources (classified), Director of Institutional Effectiveness (exempt) | Registrar’s Office, Human Resources Office, Information Technology, Provost’s Office, Illinois Record Keepers, IPEDS | Indefinite | FERPA |
| Math Placement | Provost and Senior Vice President for Academic Affairs | Director of the Math Success Center and Associate Provost | Information technology, McGraw-Hill Education / ALEKS | Indefinite | FERPA |
| NSC Enrollment and Graduate files | Registrar | Office of Institutional Effectiveness Analyst | Office of Institutional Effectiveness, Information Technology, Illinois Record Keepers, NSC, NSLDS | Indefinite | FERPA |
| Nursing Student Background Checks | Provost and Senior Vice President for Academic Affairs | Dean of the College of Education and Health Sciences | Castle Branch, Shadow Health? | ||
| Online Courses | Provost and Senior Vice President for Academic Affairs | Executive Director of Learning Design and Technology | Information Technology, Illinois Record Keepers, Instructure, Longsight, | ||
| Registration & Grade Data | Registrar | Registrar | Information Technology, Illinois Record Keepers, Instructure, Longsight | Indefinite | FERPA |
| Research Data | Associate Provost | Director of Sponsored Programs | Office of Sponsored Programs, contributing faculty | ||
| Student Record Data | Registrar | Registrar | Information Technology, Illinois Record Keepers | Indefinite | FERPA |
| Study Abroad | Provost and Senior Vice President for Academic Affairs | Director of International Programs and Associate Provost | Information Technology, Illinois Record Keepers | ||
| Teacher Ed Student Background Checks | Provost and Senior Vice President for Academic Affairs | College of Education and Health Sciences Assessment Coordinator | College of Education and Health Sciences Assessment Coordinator | ||
| University-wide Assessment Data | Provost and Senior Vice President for Academic Affairs | Director of Institutional Effectiveness | Office of Institutional Effectiveness |
Advancement and Alumni
| Category | Trustee | Steward | Custodian | Retention Period |
|---|---|---|---|---|
| Donor Records (Electronic) | Vice President for Advancement | Director, Advancement Data Management, Technology and Strategy | Blackbaud, GiveCampus, Illinois Record Keepers, Information Technology | |
| Donor Records (Paper) | Vice President for Advancement | Staff – Advancement | Case Files | |
| Donor Payments | Vice President for Advancement | Gift Records Coordinator | Blackbaud, CyberSource, GiveCampus, HEP, Illinois Record Keepers, Information Technology, Match Finder | |
| Alumni | Vice President for Advancement | Executive Director, Alumni Relations | Information Technology, Blackbaud, Cvent, Illinois Record Keepers | |
| Alumni (Smith Career Center) | Vice President for Student Affairs | Assistant VP / Executive Director, Smith Career Center | Information Technology, GradLeaders, Illinois Record Keepers |
Bradley University Police
| Category | Trustee | Steward | Custodian | Retention Period | |
|---|---|---|---|---|---|
| Background Investigation Information (fingerprint results, etc.) | AVP of Public Safety & Chief of Police | Access Control Specialist | Bradley University Police Department, Illinois State Police, TLOxp | 3 years | |
| Blackboard (door access) | AVP of Public Safety & Chief of Police | Access Control Specialist | Information Technology, Illinois Record Keepers | Indefinite | |
| CAD/RMS | AVP of Public Safety & Chief of Police | Information Technology Software Architect | Information Technology, Google, Illinois Record Keepers | Indefinite | |
| Clery Act | AVP of Public Safety & Chief of Police | Clery Compliance Coordinator | Information Technology, Illinois Record Keepers | 7 years | |
| Dispatch Audio Recordings | AVP of Public Safety & Chief of Police | Access Control Specialist | Information Technology, Illinois Record Keepers | 30 days, except when kept as evidence | |
| Evidentiary Photos/Videos | AVP of Public Safety & Chief of Police | Captain, Bradley University Police Department | Bradley University Police Department | Indefinite | |
| In-car Video Recordings | AVP of Public Safety & Chief of Police | Access Control Specialist | Bradley University Police Department, Information Technology, Illinois Record Keepers | 1 year | |
| Police Reports | AVP of Public Safety & Chief of Police | Clery Compliance Coordinator | Bradley University Police Department, Peoria Police Department | Indefinite | |
| S2 (door access) | AVP of Public Safety & Chief of Police | Access Control Specialist | Information Technology, Illinois Record Keepers, S2? | Indefinite | |
| Security Cameras | AVP of Public Safety & Chief of Police | Access Control Specialist | Information Technology, Illinois Record Keepers | 30 days, except when kept as evidence | |
| TASER video recordings | AVP of Public Safety & Chief of Police | Access Control Specialist | Bradley University Police Department | 30 days, except when kept as evidence |
Enrollment Management
| Category | Trustee | Steward | Custodian | Retention Period |
|---|---|---|---|---|
| Financial Aid Data | Vice President for Enrollment Management | Director of Financial Assistance | Information Technology, Illinois Record Keepers, LeapFILE | |
| Undergraduate Admissions Database | Vice President for Enrollment Management | Director of Admissions Technology and Operations | Technolutions, Information Technology, Illinois Record Keepers | |
| Student Loans Account Data | Vice President for Enrollment Management | Director of Financial Assistance | Information Technology, Illinois Record Keepers, UNISA | |
| Vice President for Enrollment Management | Farrell Day |
Facilities Management
| Category | Trustee | Steward | Custodian | Retention Period |
|---|---|---|---|---|
| Chemical and hazardous material | Director of Facilities | Safety Supervisor | ||
| Facility names and codes | Director of Facilities | General Services Supervisor | Facilities Management, eventually Information Technology |
Financial Services
| Category | Trustee | Steward | Custodian | Retention Period |
|---|---|---|---|---|
| Budget | Senior Vice President and Chief Operating Officer | Assistant Controller | Information Technology, Illinois Record Keepers | |
| Employment Eligibility Verification Form (I-9) | Senior Vice President and Chief Operating Officer | Director of Payroll | ||
| Financial systems data | Senior Vice President and Chief Operating Officer | Information Technology, Illinois Record Keepers | ||
| Foreign national employee taxation file – Windstar | Senior Vice President and Chief Operating Officer | Director of Payroll | Information Technology, Illinois Record Keepers | |
| Kronos timekeeping system files | Senior Vice President and Chief Operating Officer | Director of Payroll | ADP, Information Technology, Illinois Record Keepers | |
| Payroll file | Senior Vice President and Chief Operating Officer | Director of Payroll | ADP, Information Technology, Illinois Record Keepers | |
| University ID photos | Senior Vice President and Chief Operating Officer | Director of Systems Integration | Information Technology, Illinois Record Keepers | |
| Capital asset data | Senior Vice President and Chief Operating Officer | Information Technology, Illinois Record Keepers | ||
| Capital improvement data | Senior Vice President and Chief Operating Officer | Director of Facilities | Information Technology, Illinois Record Keepers | |
| Student financial account data | Senior Vice President and Chief Operating Officer | Assistant Controller | Information Technology, Illinois Record Keepers | |
| Student financial account data / QuickCard | Senior Vice President and Chief Operating Officer | Director of Systems Integration | Information Technology, Illinois Record Keepers | |
| Vendor data | Senior Vice President and Chief Operating Officer | Assistant Controller | Information Technology, Illinois Record Keepers | |
| Reallocations data | Senior Vice President and Chief Operating Officer | Assistant Controller | Information Technology, Illinois Record Keepers | |
| Labor distribution data | Senior Vice President and Chief Operating Officer | Director of Payroll | ||
| Fingerprint information for time clocks | Senior Vice President and Chief Operating Officer | Director of Payroll | 3 years after last interaction |
Human Resources
| Category | Trustee | Steward | Custodian | Retention Period | Retention Standard Reference |
|---|---|---|---|---|---|
| Background Checks | Director of Human Resources | Human Resources Administrator | HireRight | ||
| Benefits | Director of Human Resources | Benefits Administrator | BCBS of Illinois, ADP, Illinois Record Keepers, Information Technology, Voya, TIAA, BPC, AGIS | ||
| CDL Background Checks | Director of Human Resources | Supervisor of Facilities General Services | HireRight, Assistant to the President | ||
| Employee Grievance & Disciplinary Action Files | Director of Human Resources | Director of Human Resources | ADP, Information Technology, Illinois Record Keepers, individual VPs | ||
| Employment Eligibility Verification Form (I-9) | Director of Human Resources | Human Resource Administrator | ADP, Illinois Record Keepers | ||
| Fingerprints for Time Clocks | Director of Human Resources | Human Resource Administrator | ADP | Maximum of 3 years after last interaction | BIPA |
| Human Resources Data | Director of Human Resources | Human Resources Administrator | ADP, Information Technology, Illinois Record Keepers, Office of the Provost (faculty) | ||
| Labor Distribution Data | Director of Human Resources | Human Resource Administrator | ADP | ||
| Required Training Data | Director of Human Resources | Human Resource Administrator | United Educators, Blackboard, Instructure (Canvas), Information Technology, Illinois Record Keepers |
Information Technology
| Category | Trustee | Steward | Custodian | Retention Period |
|---|---|---|---|---|
| Account Credentials (BUnetID usernames and passwords) | Director of Information Security | Security Engineer | Google, Information Technology, Illinois Record Keepers, everyone | 120 days after account is no longer needed |
| Account Information | Director of Information Security | Security Engineer | Google, Information Technology, Illinois Record Keepers, Microsoft, everyone | |
| Backups | Chief Information Officer | Director of Infrastructure | Information Technology, Illinois Record Keepers | 1 year, except for litigation holds, 100 years for email archive |
| Computer Inventory | Chief Information Officer | Director of Endpoint and Client Services | Information Technology, Illinois Record Keepers, Lansweeper | |
| Computer Process Trees | Director of Information Security | Security Engineer | CrowdStrike, Information Technology | 1 year |
| Encryption Keys | Director of Information Security | Security Engineer | Information Technology, Illinois Record Keepers | |
| Phone Logs | Chief Information Officer | Director of Infrastructure | Information Technology, Illinois Record Keepers | |
| Source code | Chief Information Officer | Director, Enterprise Systems | Information Technology, Illinois Record Keepers | |
| Voice Over IP (VoIP) | Chief Information Officer | Director of Infrastructure | Information Technology |
Intercollegiate Athletics
| Category | Trustee | Steward | Custodian | Retention Period | Retention Standard Reference |
|---|---|---|---|---|---|
| Athletics | Vice President for Intercollegiate Athletics | Director of Academics and Student Development | Information Technology | ||
| Auction Sales | Vice President for Enrollment Management | Director of Admissions Technology and Operations | Technolutions, Information Technology, Illinois Record Keepers | ||
| Camps | Vice President for Intercollegiate Athletics | Individual Coaches | Individual coaches, Information Technology, Illinois Record Keepers | User discretion | “Standard” University Retention Period Definition; FTC Safeguard Rules |
| Credit card purchases / Donations | Vice President for Intercollegiate Athletics | Director of Braves Club Membership and Events | Greater Giving, Information Technology, Illinois Record Keepers | Indefinite | |
| EADA | Vice President for Intercollegiate Athletics | Sr. Associate Athletic Director, Controller | NCAA FRS, Dept of Ed, Information Technology, Illinois Record Keepers | Indefinite | NCAA, Dept. of Education |
| Graduation Data/GRS/APR | Vice President for Intercollegiate Athletics | Assistant Registrar | Sr. Assoc. Athletic Director for Compliance, NCAA/Dept of Ed, Information Technology, Illinois Record Keepers | Indefinite | FERPA |
| Hiring Processes | Vice President for Intercollegiate Athletics | Director of Human Resources, Athletics Administrative Assistant | Paper Records | ||
| Integrated Fan base | Vice President for Intercollegiate Athletics | Assoc. Athletic Director for Marketing and Ticketing | Learfield IMG College | ||
| Merchandise Sales / Credit card | Vice President for Intercollegiate Athletics | Sr. Associate Athletic Director / Assoc. Athletic Director for Marketing and Ticketing | Square, Information Technology, Illinois Record Keepers | ||
| NCAA Compliance | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Compliance | Intercollegiate Athletics Director of Compliance, Paper Records, NCAA, Information Technology, Illinois Record Keepers | 7-8 years required per NCAA | NCAA |
| NCAA Demographic/Sport Sponsorship | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Compliance | NCAA | Indefinite | NCAA |
| NCAA/Conference Survey/Shared Data | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Finance and Administration | User discretion | “Standard” University Retention Period Definition; FTC Safeguard Rules | |
| Out bound / Online ticket sales | Vice President for Intercollegiate Athletics | Assoc. Athletic Director for Marketing and Ticketing | Aspire | ||
| Raffles | Vice President for Intercollegiate Athletics | Director of Braves Club Membership and Events | Ascend (50/50 Central), Information Technology, Illinois Record Keepers | ||
| S-A Academic Tracking | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Academic and Student Welfare, Sr. Assoc. Athletic Director for Compliance | Paper Records, Google | 6-8 years | |
| S-A Injury Tracking | Vice President for Intercollegiate Athletics | Athletic Trainer | ATS, paper, Insurance Providers | ||
| S-A Records | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Academic and Student Welfare | Paper Records | 6-8 years | |
| Student Drug Testing | Vice President for Intercollegiate Athletics | Athletic Trainer | Drug Free Sport, possibly on Colston computer | ||
| Student-Athlete COVID Testing | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Academic and Student Welfare, Athletic Trainer | Google Drive, Reditus Labs (Pekin) | ||
| Ticket Sales / Donations | Vice President for Intercollegiate Athletics | Assoc. Athletic Director for Marketing and Ticketing | Ticketmaster Archtics, Information Technology, Illinois Record Keepers | ||
| Volunteers | Vice President for Intercollegiate Athletics | Sr. Assoc. Athletic Director for Finance and Administration, Sr. Assoc. Athletic Director for Communications | Sr. Assoc. Athletic Director for Finance and Administration for paper, Information Technology, Illinois Record Keepers for Advance, Blackbaud for Raiser’s Edge | Indefinite |
Legal Affairs
| Category | Trustee | Steward | Custodian | Retention Period |
|---|---|---|---|---|
| Background Checks | Vice President for Legal Affairs and General Counsel | Director of Human Resources | HireRight | |
| Benefits | Vice President for Legal Affairs and General Counsel | Benefits Administrator | BCBS of Illinois, Greatland, Information Technology, Illinois Record Keepers, Voya, TIAA, BPC, AGIS | |
| CDL Background Checks | Vice President for Legal Affairs and General Counsel | Executive Administrative Assistant | Executive Administrative Assistant, HireRight | |
| Consents | Vice President for Legal Affairs and General Counsel | Illinois Record Keepers, Information Technology | ||
| Employee Grievance and Disciplinary Action Files | Vice President for Legal Affairs and General Counsel | Director of Human Resources | Illinois Record Keepers, individual VPs, Information Technology | |
| Human Resources Data | Vice President for Legal Affairs and General Counsel | Director of Human Resources | Automatic Data Processing, Illinois Record Keepers, Information Technology | |
| Required Training Data | Vice President for Legal Affairs and General Counsel | Director of Human Resources | United Educators, Blackboard, Information Technology, Illinois Record Keepers | |
| Subpeonas | Vice President for Legal Affairs and General Counsel |
Student Affairs
| Category | Trustee | Steward | Custodian | Retention Period | |
|---|---|---|---|---|---|
| Career Search data | Vice President for Student Affairs | Exec. Director, Smith Career Center | 12Twenty | ||
| Conference data | Vice President for Student Affairs | Exec. Director of Student Involvement | Illinois Record Keepers, Information Technology | ||
| COVID-19 Health data | Vice President for Student Affairs | Medical Director, Health Services | Qualtrics | ||
| Event Management System (Student Events) | Vice President for Student Affairs | Director, Student Activities | Information Technology | ||
| Housing data (apartments) | Vice President for Student Affairs | General Manager, Off-Campus Properties | Illinois Record Keepers, Information Technology | ||
| Housing data (residence halls) | Vice President for Student Affairs | Exec. Director, Residential Living and Student Conduct | Director of Admissions Technology & Operations, Illinois Record Keepers, Information Technology, StarRez | ||
| Intramurals | Vice President for Student Affairs / Registrar | Asst. Director of Programs, Campus Recreation and Athletic Facilities | IMLeagues | ||
| Markin Center Member data | Vice President for Student Affairs | Director of Campus Recreation and Athletic Facilities | Information Technology | ||
| SEVIS | Exec. Director, Student Support Services | Administrative Support, Center for Research and Service | Department of Homeland Security | ||
| Student career data | Vice President for Student Affairs | Exec. Director, Smith Career Center | GradLeaders, Handshake, Information Technology, Illinois Record Keepers | ||
| Student counseling record | Vice President for Student Affairs | Medical Director, Health Services | Illinois Record Keepers, Information Technology | ||
| Student Engagement data | Vice President for Student Affairs | Director of Academic Success Center | EAB | ||
| Student judicial data | Vice President for Student Affairs | Exec. Director, Residential Living and Student Conduct | Illinois Record Keepers, Information Technology | ||
| Student medical record, Student Health Services patient record | Vice President for Student Affairs | Medical Director, Health Services | Illinois Record Keepers, Information Technology | ||
| Student organization management data | Vice President for Student Affairs | Director of Student Activities | Presence, Information Technology, Illinois Record Keepers |
