Don't Cloud SFU Data
Storing information in "the cloud" is becoming more compelling, but great care is required to ensure the cloud is used by SFU faculty and staff only when appropriate. We must ensure we comply with the provisions of the BC Freedom of Information and Protection of Privacy Act (FIPPA).
In general, using the cloud or "Software-as-a-Service" (SaaS) systems is legal only if SFU can guarantee that personal information in the data remains in Canada. This is not true for many SaaS systems (Apple's iCloud, Amazon Web Services including EC2 and S3, ElasticHosts, IBM SmartCloud, Rackspace Cloud, ...), free email and collaboration services (Google, Microsoft, Yahoo, AOL, ...), and various document-storage and backup systems (Dropbox, Windows Live, ASUS WebStorage, FilesAnywhere, IDrive, Syncplicity, and many others).
All systems implemented or controlled by SFU IT Services comply with FIPPA, and should be used by all faculty and staff.
An assumption
As CIO, I have to assume that all email accounts, all electronic calendars, and many SFU documents ("business records") contain personal information subject to FIPPA. Here are some consequences.
Consequences
- Do: Use SFU Connect for all SFU business, including email, calendars, and shared briefcases of documents.
- Do Not: Forward your SFU email to a cloud email account, such as those of Google or Microsoft.
- Do: Access SFU Connect from all your personal devices, whether desktop or laptop computers, tablets or iPads, smart phones or iPhones.
- Do Not: Synchronize your devices through cloud services such as Apple's iCloud, now used by default by iTunes (both PC and Mac), iPhones, iPads, and iPod touch devices.
- Do: Share documents collaboratively through services provided by SFU. Examples include WebCT, protected web sites, Sakai or wiki spaces, WebDAV or sftp sites, and SFU Connect "Briefcases". (Briefcases allow you to create shared folders of documents that can be uploaded and downloaded from any Connect client. New versions of Zimbra, the software of SFU Connect, are expected to provide much improved briefcase functionality similar to Dropbox.)
- Do Not: Synchronize documents containing personal information through Dropbox or similar mechanisms.
- Do Not: Backup a device containing SFU information to any cloud service storing the information outside Canada.
Why are there no cloud services in Canada?
There are a few, but not many. (One example of a survey SaaS company is FluidSurveys, which guarantees to store all data in Canada.) One obvious reason is that the Canadian market is too small to convince the large industry players to bother with creating and maintaining isolated systems in Canada. Some Canadian cloud providers exist and more are emerging, but most are not free. As we note opportunities, we continue to evaluate the business cases for Canadian cloud computing, but still rely mainly on systems housed and maintained at SFU.
On the provincial and national fronts, BCNET (our high-speed research network consortium), CANARIE (the national high-speed research network), and CUCCIO (the Canadian University Council of Chief Information Officers) continue our efforts to develop Canadian cloud capacity appropriate for higher education.
Archived Comments
For iPhone users, we might want to post a configuration profile for setting up SFU Connect on their phone. With the config profile, it's only a few touches to get Mail, Calendar and Address Book setup on an iOS device.
The only way for users for follow the guideline is to make it easy for users to make it work.
I can go to SFU connect through the internet connection on my phone, but it is so slow to respond (taking up to 15 minutes to read a single e-mail, let alone sending one - and yes it is an SFU connect fault, not a fault with my wireless connectionas no other site takes nearly as long to load) that the entire purpose is defeated.
I find it frustrating that there are options available for all smart phone types except android. I will stop forwarding my e-mails to Gmail in light of these legal issues, but something needs to be put in place for android users.
- for the most part, it's useful. It does feel like an extra step to have to go through the web interface to access everything.
Has there been consideration of direct connection for on-campus machines so that the briefcase would function more like a shared server file folder?
For mobile and so forth, briefcase is a relatively good way to go, but hopefully the improvements alluded to above come sooner than later so as to make the experience more user-friendly.
Lastly, using the Connect system is exceptionally difficult given the low quota (5GB) allocated by default. While IT Services can increase this with good reason, many staff don't know it is possible. You can fill 5 GB in only a few months, just with email and attachments. Using the Briefcase diligently would put a lot of strain on this (I'd prefer this route, but we need more realistic quotas if we are to store documents in this way).
SO.... if you want me to use SFU Connect, you need to improve SPAM filtering so that I'm not wasting my days deleting junk.
I also tried to "replicate" my Gmail experience without much success. For example, there doesn't appear to be simple way to "archive" messages from my in-box to multiple folders. For example, in Gmail, I simply add several labels to a message and then archive it so that it doesn't appear in my active inbox.
I think that after reflection SFU as an entity will be forced to break email forwarding for any faculty and staff Connect accounts that are forwarded to external commercial email addresses.
In case you are wondering, I do not work for ITS
The Barracuda spam filter tends to take a few days to catch new types of spam. New patterns will appear in people's Inboxes for a little while, then they tend to disappear as the Barracuda's filtering rules catch up.
Which leads to a question from a non-techie: With iPhone and iPad apparently using iCloud, what other way IS there to update and sync these devices without exposing any SFU info they contain?
For example, I have for years used "Documents to Go" to store volumes of SFU documents that would overwhelm Briefcase. And that would be re-clouded every time I sync my devices? (At least once a week.) Is that now not recommended? And isn't it too late to fix?
What would the instructor do if a student refused?
Can SFU websurvey be used for this purpose?
In the meantime, Vancouver Island University developed, with support from BC Campus, a Privacy Guideline for Faculty Using 3rd Party Web Technology (Social Media) in Public Post-Secondary Courses. It can be downloaded from the BC Campus website. I would advise using the process it describes rather than make students use such tools as a course requirement. I dont know that the latter option, which relies on giving students informed notice and getting their implied consent would withstand scrutiny in this particular type of situation. Unfortunately, there are no immediate, simple, quick and easy fixes.
-What constitutes personal data? A scientific paper I'm working on? Photos from a group meeting? Music? etc.
-How do you propose we transfer moderately large files to external parties? Say it's 100Mb. Dropbox is excellent for this and I haven't seen any SFU service that could replace it.
-How do you propose we share moderately large files within a lab or group, across multiple platforms (Mac, PC, Linux, iOS, Android)? Zimbra briefcase does not cut it.
I'm sure you know that if you want compliance, you need to offer real alternatives.
I've recently discovered the mobile interface for SFUconnect for my iphone and it's pretty good. Trying to use any connect services without switching to the mobile interface is agony, though. :-)
My compromise with Evernote is to use local-only notebooks for internal, non-public SFU data. Catch is one has to copy and paste, not forward via e-mail. But at least my interface for notes is consistent on my laptop across the sensitive and non-sensitive materials. Anything I think I might need to look up away from my desk I'm putting in SFU Connect's document feature but am finding it time consuming so being selective.
Lynda Williams, Learning Technology Analyst, SFU.
it would seem that SFU should give us decent email service. IMO the zimbra
interface is terrible, spam filtering is somewhere between weak and nonexistent,
and service is spotty.
Not liking Zimbra is not a convincing argument for violating BC laws
Until IT Services supports using clients like Thunderbird and Outlook for accessing SFU Mail saying that you can use other clients isn't a convincing argument either.
I really dont see the problem here. The Zimbra web interface is pretty good, you can use any other client software. If you need support for the client software presumably you make the case for that with your local desktop support folks.
Not SFU administration.
The fact that the administration is disseminating information to help others be aware of the issue is quite another (positive) thing.
This is the actual piece of legislation.
And hey, storage is cheap, so why not do some of it locally?
The only way around this is for the people affected to give consent. For instance, if all students in a course agreed that their emails could be stored in Gmail servers then the instructor could use a gmail account.
While at the VMware conference this year, VMware announced a new product they are working on.
http://blogs.vmware.com/euc/2011/08/vmworld-2011-tech-peview-vmware-project-octopus.html
1) B.C.'s privacy law applies to publicly funded bodies including SFU.
2) One purpose of the law is to protect personal privacy by preventing the unauthorized collection, use or disclosure of personal information by public bodies.
3) The law applies to all records in the custody or under the control of SFU with limited exceptions. For example, it does not apply to a record containing teaching materials or research information of: (i) a faculty member of a post-secondary educational body, (ii) a teaching assistant or research assistant employed at a post-secondary educational body, or (iii) other persons teaching or carrying out research at a post-secondary educational body.
4) The protection of privacy requirements and restrictions established by law apply to (a) the employees, officers and directors of SFU, and (b) in the case of a service provider hired by SFU, all employees and associates of the service provider.
5) SFU must by law protect personal information in its custody or under its control by making reasonable security arrangements against such risks as unauthorized access, collection, use, disclosure or disposal. One way we do this is by communicating about our legislated privacy obligations and educating the university community about privacy issues that arise related to our use of information technology. The CIOs proposed message to the SFU community will help us achieve our duty to protect personal information by preventing its unauthorized disclosure, which is in keeping with the spirit, intent and letter of the law.
6) Protection includes the requirement that personal information must be stored and accessed only in Canada. B.C. is the only jurisdiction in Canada with this legislated requirement.
7) A SFU employee, officer or director or a service provider who has access, whether authorized or unauthorized, to personal information in the custody or control of SFU, must not disclose that information except as authorized under the privacy law.
8) SFU may disclose personal information in its custody or under its control only as permitted under the privacy law. The situations when we are authorized to disclose personal information inside and outside Canada are prescribed in very limited and specific terms. That permission does not include using an alternate email service on the grounds that SFU Connect is imperfect or for reasons of personal convenience or preference. SFU Connect may not be perfect but it offers a very important advantage over other email services it allows SFU employees to communicate using a tool that also enables them to comply with their legal responsibility to store and access personal information only in Canada.
9) A person who contravenes the privacy law by way of unauthorized disclosure commits an offence. A person who commits an offence is liable: (a) in the case of an individual to a fine of up to $2000 and (b) in the case of SFU, to a fine of up to $500,000. This is quite apart from the harm a breach of privacy would do to SFUs reputation as a trusted public custodian of personal information belonging to tens of thousands of individuals including students, employees and alumni.
I dont mean the information above to sound heavy-handed. I offer it here in order that we better know and understand the legislated environment in which we operate and the potential consequences for our employer and us. Whether we like or dislike some of the laws current privacy provisions, these are the rules of law under which we live and abide as individual and corporate citizens.
guys. It's fast and supports multiple OS like Windows, Mac, iOS and
android.
You get 5 gb for free and when you use the b.m. Link you will get 5,5
Gb for free. If you go for a premium membership (starts at 30 Gb) each
of you will get additional 10 Gb for free.
Check this out and get a 5,5 Gb account for free.
https://www.sugarsync.com/referral?rf=fgtgw30dr45gt&utm_source=txemail&utm_medium=email&utm_campaign=referral
Google has a new unified privacy policy for all their services, set to go into use March 1 2012: http://www.google.ca/intl/en/policies/ and http://www.google.ca/intl/en/policies/privacy/preview/
A relevant quote: "Google processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live."
Also, web search engines, like Google and Bing, save copies of web pages. Is it necessary to prevent SFU web pages from being indexed?
Also, web search engines, like Google and Bing, save copies of web pages. Is it necessary to prevent SFU web pages from being indexed?
There are many other ways of using sending and receiving email via SFU Connect, and the technical details are unfortunately relevant to the question of whether copies might be saved in some sense outside Canada. That's why the first option is preferred.
Web search engines only save copies of public information on web sites. If someone at SFU is disclosing personal information on a public web site, that's a different, and serious problem that SFU should address directly.
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