Foreword
In the era of rapid technological advancement and proliferation of digital information, the management of electronic data repositories has become a cornerstone of organizational success and integrity. This policy is designed to guide our institution in the effective, secure, and ethical handling of electronic data, ensuring that our practices meet the highest standards for data management and regulatory compliance.
The creation, storage, and dissemination of electronic data are vital for operational efficiency, research initiatives, and collaborative efforts. Therefore, it is imperative that we adopt a structured approach to managing these repositories to protect the integrity, confidentiality, and availability of our data assets.
This Policy outlines the responsibilities, procedures, and standards required to maintain the electronic data repository. It addresses critical areas, such as data governance, security protocols, access controls, data integrity, and lifecycle management. By adhering to these guidelines, we aim to foster a culture of accountability and transparency that enhances our data stewardship practices.
The digital landscape is continually evolving and creating new challenges and opportunities. Our commitment to regularly reviewing and updating this policy reflects our dedication to staying ahead of the technological trends and emerging threats. We recognise the importance of balancing innovation with robust data governance to ensure that our data remain a reliable and secure resource for all stakeholders.
We encourage all members of our organisation to familiarise themselves with this policy and to actively participate in its implementation. By working together, we can safeguard our data repositories, support our strategic goals, and uphold our reputation for excellent data management.
Sincerely,
Professor Francis Moto
Chairperson of Council
PREFACE
Electronic data repositories are integral to daily operations, research endeavours, and strategic decision-making processes. They enable us to store vast amounts of information, facilitate seamless data sharing, and support robust analytics that drives innovation and progress. However, with the increasing volume and complexity of data, it is necessary to ensure security, integrity, and proper utilisation.
This document serves as a guide for all stakeholders, delineating the principles, standards, and procedures necessary for the sound management of our electronic data repository. It addresses key areas, such as data classification, security measures, access controls, compliance requirements, and data lifecycle management. Our goal is to promote best practices that protect our data assets, mitigate risks, and ensure compliance with the relevant laws and regulations.
This policy reflects our commitment to maintaining the highest standards of data governance and integrity. It has been crafted with input from various departments and experts to ensure that it meets the diverse needs of our organisation while aligning with industry best practices. By adhering to this policy, we can enhance our data management capabilities, safeguard sensitive information, and maintain stakeholder trust.
As the digital landscape continues to evolve, our approach to managing electronic data must be considered. This policy is designed to adapt to new technologies, regulatory changes, and emerging threats. Regular reviews and updates will be conducted to ensure continued relevance and effectiveness.
We urge all members of our organisation to engage in this policy, understand their roles and responsibilities, and contribute to a culture of excellence in data management. Thus, we can ensure that our electronic data repositories remain secure, reliable, and valuable resources for the advancement of our institution.
Sincerely,
Professor MacPherson Mallewa
Vice-Chancellor
ACKNOWLEDGEMENTS
This policy is the result of collaborations among various players. This work has been made possible by the tireless efforts of the KUHeS family, affiliates, and other stakeholders in the arena. The Task Force's dedication to the development of the policy was admirable. We thank Dr Cecelia Maliwichi Nyirenda and Mr Gibson Masache from the Research Support Centre under the CHEER Project for their financial assistance in meeting the costs of developing this policy, as no special funds were set aside for this purpose.
The acknowledgement section will be incomplete unless we mention the staff members who worked tirelessly on this piece of work. Dr Patrick Mapulanga, Mrs Diana Mawindo Chitimbe, and Mr Tobias Makweya from the Library; Mr Chikumbutso Geremu from the ICT Department; and Mr Praise Kafulatira Archivist from the Malawi Liverpool Wellcome Trust. Mr Yesaya Nyirenda, Data Manager; Mr Amos Msopera, Data Officer; Mrs Atusaye Ngwira, Senior Clinical Research Associate; Mrs Esther Gondwe, Grants Manager; Richard M'madi, Training Coordinator Officer; Mr Peter Mchenga, IT Data Management Unit; Ms Khama Mita, COMREC Administrator; Mr Andrew Bauleni, Data Coordinator, Malaria Alert Center, Mrs Sthembiso Msisha, and Mrs Gloria Namacha, Administrative Assistant deserve special recognition.
LIST OF ABBREVIATIONS AND ACRONYMS
COMREC - College of Medicine Research and Ethics Committee
KUHeS - Kamuzu University of Health Sciences
ICT - Information and Communication Technologies
IT - Information Technology
M & E - Monitoring and Evaluation
MFA - Multi-Factor Authentication
RBAC - Role-based access controls
XML - eXtensible Markup Language
DEFINITIONS
Data Access - Refers to the process of retrieving and manipulating data stored in a database or other storage systems.
Data Classification Tools - Refers to software applications designed to categorize, label, and manage data based on predefined criteria such as sensitivity, confidentiality, or compliance requirements.
Data Compliance - Refers to the adherence to laws, regulations, and standards that govern how data is managed, stored, processed, and shared.
Data Integrity - Refers to the accuracy, consistency, and reliability of data throughout its lifecycle
Data Management Standards - Refers to frameworks and guidelines designed to ensure the proper handling, storage, processing, and protection of data across an organization
Data Quality - Refers to the condition of data based on factors that make it appropriate for its intended use. High-quality data is essential for effective decision-making, operational efficiency, and maintaining trust within an organization
Data Repository - Refers to centralized place where data is stored, managed, and maintained.
Data Security - Refers to the practice of protecting digital information from unauthorized access, corruption, or theft throughout its lifecycle
Data Stewardship - Involves managing and overseeing an organization's data assets to ensure their quality, security, and proper use.
1. BACKGROUND & SCOPE
In the modern digital era, electronic data are the lifeblood of organizational operations, enabling efficient workflows, insightful analytics, and strategic decision making. The exponential growth of data generated and utilised by organisations has necessitated the establishment of robust policies for managing electronic data repositories. These repositories, which contain vast amounts of digital information, are critical to the functioning and success of our institution.
Data is not just a by-product of our operations; it is a strategic asset that, when harnessed effectively, can drive growth and differentiation. With the rise in cyber threats and data breaches, protecting sensitive information stored in electronic repositories is paramount to safeguarding our organization and its stakeholders. The proliferation of data privacy regulations, such as the General Data Protection Regulation (GDPR) and the Malawi Privacy Act, Electronic Transactions and Cybersecurity Act necessitates rigorous compliance in data handling. Effective data governance is essential for ensuring data accuracy, consistency, and accountability across the organization.
The necessity of a comprehensive policy stems from several factors:
- Data Proliferation: The volume of data generated by various activities, ranging from routine administrative functions to complex research projects, continues to increase rapidly.
- Security Risks: The rise of cyber threats and data breaches poses significant risks to the confidentiality, integrity, and availability of data.
- Regulatory Compliance: There ever-growing landscape of legal and regulatory requirements governing data management, including data privacy laws and industry-specific regulations.
- Operational Efficiency: Effective data management enhances operational efficiency, enabling better decision making, resource optimisation, and innovation.
- Stakeholder Trust: Proper handling of data is crucial for maintaining the trust and confidence of stakeholders, including employees, partners, clients, and the public.
In response to these drivers, this policy has been developed to provide a structured approach to the management of electronic data repositories, ensuring that our data assets are managed securely and efficiently and in compliance with applicable laws and regulations.
This policy applies to all electronic data repositories managed by our institution and encompasses all types of data generated, collected, processed, stored, and disseminated as part of our operations. The scope of this policy includes, but is not limited to
- Data Types: All forms of electronic data, including structured data (databases, spreadsheets), unstructured data (documents and emails), semi-structured data (XML, JSON files), and multimedia data (images, videos, and audio files).
- Data Life Cycle: All stages of the data life cycle, from creation and collection to processing, storage, usage, sharing, and eventual archiving or deletion.
- Data Repositories: All platforms and systems used for storing electronic data, including on-premises servers, cloud storage solutions, databases, data warehouses, and backup systems.
- Stakeholders: All individuals and departments within the institution that interact with electronic data repositories, including IT staff, data stewards, researchers, administrators, and end users.
- Processes and Practices: All activities related to data management, including data classification, access control, data security measures, data integrity checks, compliance audits, and data disposal procedures.
By clearly defining the background and scope, this policy aims to establish a coherent and unified approach for managing our electronic data repository. It provides a foundation for developing specific guidelines, procedures, and responsibilities that will ensure effective governance and protection of our data assets.
This Policy applies to all university employees, contractors, consultants, volunteers, service providers, and vendors who acquire, create, manage, preserve, store, and make available digital content from collections as well as other digital content for which the university is responsible. The Policy also applies to funding organisations, philanthropic organisations, donors, researchers, and all users of the university’s digital content.
2. THE RATIONALE FOR THE POLICY
In today's information-driven world, electronic data serve as a crucial asset for organisations, underpinning everything from daily operations to strategic decision making and innovation. The rationale for establishing a comprehensive electronic data repository policy is rooted in several key factors.
- Ensuring Data Integrity and Accuracy: Electronic data repositories must be managed to maintain the integrity and accuracy of the data they contain. Accurate data are essential for reliable decision-making, research outcomes, and operational efficiency. By implementing stringent data management practices, we can minimise errors, ensure consistency, and improve the data quality.
- Enhancing Data Security: With rise of cyber threats and data breaches, safeguarding electronic data repositories is more critical than ever. This policy outlines security measures for protecting sensitive information from unauthorised access, theft, and other malicious activities. These measures include access controls, encryption, and regular security audits, which collectively help mitigate risks and protect data assets.
- Compliance with legal and regulatory requirements: Organisations are subject to a myriad of legal and regulatory requirements related to data management, including data privacy laws, industry-specific regulations, and internal governance standards. This policy ensures compliance with these requirements, helping avoid legal penalties, reputational damage, and operational disruptions. It provides a framework for adhering to relevant laws and guidelines, thereby ensuring that our data practices meet the highest compliance standards.
- Promoting Operational Efficiency: Effective management of electronic data repositories contributes to operational efficiency by enabling streamlined data access, processing, and storage. A well-defined policy facilitates better resource management, reduces redundancy, and ensures that data are readily available to those who require it. This in turn enhances productivity and supports the institution's overall goals and objectives.
- Supporting Research and Innovation: In many organisations, particularly those engaged in research and development, the ability to efficiently manage and utilise data is fundamental to innovation. This policy provides a framework for proper data stewardship, ensuring that valuable research data are preserved, accessible, and usable in future projects. It supports collaboration and data sharing, while maintaining data integrity and security.
- Maintaining Stakeholder Trust: Stakeholders, including employees, clients, partners, and the public, place significant trust in their ability to manage their data responsibly. By implementing a robust electronic data repository policy, we demonstrate our commitment to protecting information and upholding ethical standards. This fosters trust and confidence, which are vital for maintaining strong relationships and positive reputations.
- Facilitating Data Lifecycle Management: Data have a lifecycle that includes creation, storage, usage, sharing, and eventual disposal. This policy outlines the best practices for managing each stage of the data lifecycle, ensuring that data are handled appropriately throughout its existence. Proper lifecycle management helps optimise storage resources, reduce costs, and ensure timely and secure disposal of data when it is no longer needed.
- Adapting to Technological Advances: The digital landscape is constantly evolving, with new technologies and methodologies emerging regularly. This policy is designed to be flexible and adaptive, allowing for regular updates to address new challenges and opportunities. By staying ahead of the technological trends, we can ensure that our data management practices remain current and effective.
In summary, an electronic data repository policy is essential for maintaining the integrity, security, and usability of our data. It provides a structured approach to data management that supports compliance, operational efficiency, research and stakeholder trust. By adhering to this policy, we can safeguard our data assets, enhance organizational capabilities, and achieve strategic objectives.
3. KUHeS VISION
A world-class University and Centre of excellence in health education, research, and innovation.
4. KUHeS MISSION
To advance knowledge, professional competencies, skills, and innovations in health sciences through high-quality student-centred and innovative education and research that responds to national policy, health, and development needs in an efficient, sustainable, and result-oriented manner.
5. AIM OF THE POLICY
The aim of the Electronic Data Repositories Policy is to establish a comprehensive framework for the effective, secure, and ethical management of electronic data repositories in our institution.
6. POLICY OBJECTIVES
The objectives of this policy are as follows:
- Ensure accuracy, consistency, and reliability of the data across all repositories.
- Protect electronic data repositories from unauthorised access, breaches, and other security threats.
- Adhere to all relevant legal, regulatory, and institutional requirements regarding data management.
- Streamline data access, processing, and storage to enhance operational efficiency.
- Provide a robust framework for managing research data to facilitate innovation and collaboration.
- Build and maintain trust with stakeholders by demonstrating responsible data management practices.
- Manage data through its entire lifecycle from creation to disposal.
- Stay current with new technologies and methodologies in data management.
- Promote accountability and responsibility for data management across the institution.
7. POLICY PRIORITY AREAS
7.1 POLICY PRIORITY AREA 1: DATA SECURITY
Policy Issue: Ensuring the protection of electronic data repositories from unauthorised access, breaches, and other security threats.
Policy Statement: KUHeS is committed to implementing robust security measures to safeguard all electronic data repositories against unauthorised access, data breaches, and other malicious activities.
Policy Strategies:
- Implement multi-factor authentication for accessing data repositories.
- Employ encryption for data at rest and during transit.
- Conduct regular security audits and vulnerability assessments.
- Establish a comprehensive incident response plan to address data breaches.
- Provide ongoing security training and awareness programs for all staff members.
7.2 POLICY PRIORITY AREA 2: DATA INTEGRITY AND QUALITY
Policy Issue: Maintaining the accuracy, consistency, and reliability of data within electronic repositories.
Policy Statement: KUHeS will ensure the highest standards of data integrity and quality across all electronic data repositories to support accurate and reliable decision-making.
Policy Strategies:
- Implement data validation and verification procedures.
- Use automated tools to detect and correct data anomalies.
- Regularly review and update data management practices and protocols.
- Conduct periodic data quality assessments.
- Foster a culture of data accuracy and accountability among all data users.
7.3 POLICY PRIORITY AREA 3: REGULATORY COMPLIANCE
Policy Issue: Adhering to relevant legal, regulatory, and institutional requirements regarding data management.
Policy Statement: KUHeS is dedicated to maintaining compliance with all applicable legal, regulatory, and institutional data-management standards.
Policy Strategies:
- Conduct regular compliance audits to ensure adherence to the relevant laws and regulations.
- Develop and maintain comprehensive documentation of data management practices.
- Provide training on regulatory requirements for all the staff involved in data management.
- Establish clear roles and responsibilities for compliance monitoring.
- Stay updated with changes in data protection laws and accordingly adjusted policies.
7.4 POLICY PRIORITY AREA 4: DATA ACCESS AND USE
Policy Issue: Ensuring appropriate and efficient access to data while protecting sensitive information.
Policy Statement: KUHeS will provide efficient and controlled access to electronic data repositories, balancing accessibility with the need to protect sensitive information.
Policy Strategies:
- Implement role-based access controls (RBAC) to ensure that only authorised personnel can access specific data.
- Regularly review and update access permissions.
- Utilize data masking and anonymization techniques for sensitive data.
- Monitor and log access to data repositories for accountability.
- Provide training on data access policies and protocols.
7.5 POLICY PRIORITY AREA 5: DATA LIFECYCLE MANAGEMENT
Policy Issue: Managing data throughout its entire lifecycle from creation to disposal.
Policy Statement: KUHeS is committed to effective data lifecycle management, ensuring the proper handling of data from creation to disposal.
Policy Strategies:
- Establish guidelines for data creation, classification, and storage.
- Implement regular data review and archival processes.
- Develop procedures for secure data disposal and destruction.
- Utilize automated tools for lifecycle management.
- Train staff on best practices for data lifecycle management.
7.6 POLICY PRIORITY AREA 6: DATA GOVERNANCE
Policy Issue: Establishing a structured framework for data governance and accountability.
Policy Statement: KUHeS will establish a robust data governance framework to ensure accountability, transparency, and effective management of electronic data repositories.
Policy Strategies:
- Form a data governance committee with representatives from the key departments.
- Define data stewardship roles and responsibilities.
- Develop and enforce data governance policies and standards.
- Implement regular data governance audits and reviews.
- Promote a culture of data stewardship and accountability across the institution.
7.7 POLICY PRIORITY AREA 7: DATA INNOVATION AND UTILIZATION
Policy Issue: Promoting the use of data to drive innovation and support research and operational initiatives.
Policy Statement: KUHeS will encourage the innovative use of data to support research, enhance operations, and drive strategic decision-making.
Policy Strategies:
- Provide access to advanced data analytics tools and technologies.
- Foster collaboration across departments to leverage data for innovative solutions.
- Support data-sharing initiatives while ensuring data security and compliance.
- Offer training and resources for data analysis and interpretation.
- Recognise and reward data-driven innovations and contributions.
8. IMPLEMENTATION GUIDELINES
Successful implementation of the Electronic Data Repositories Policy requires a structured approach that includes clear guidelines, roles, and responsibilities. These implementation guidelines are designed to provide a practical roadmap for enacting the policy across the institution:
8.1 Establish Governance Structure
Guidelines:
- Form a Data Governance Committee: Comprising representatives from key departments (IT, Legal, Compliance, Research, etc.) to oversee policy implementation.
- Appoint Data Stewards: Designate individuals responsible for data management within their respective departments.
Roles and Responsibilities:
- Data Governance Committee: Ensure policy adherence, conduct regular reviews, and recommend updates.
- Data Stewards: Implement data management practices, monitor compliance, and report issues.
8.2 Develop and Disseminate Procedures
Guidelines:
- Create Detailed Procedures: Develop specific procedures for data security, access control, data quality, lifecycle management, and regulatory compliance.
- Disseminate Procedures: Ensure that all relevant personnel have access to and understand the procedures.
Roles and Responsibilities:
- IT Department: Develop technical procedures and provide the necessary tools.
- Compliance Department: Ensure that the procedures meet legal and regulatory standards.
- HR Department: Integrate procedures into onboarding and training programs.
8.3 Implement Security Measures
Guidelines:
- Multi-Factor Authentication (MFA): Enforce MFA for accessing sensitive data.
- Encryption: Apply encryption to data at rest and in transit.
- Regular Audits: Conduct regular security audits and vulnerability assessments.
Roles and Responsibilities:
- IT Security Team: Implement and monitor security measures.
- Internal Audit Team: Conduct and report security audits.
8.4 Conduct Training and Awareness Programs
Guidelines:
- Training Programs: Develop and deliver training on data management practices, security protocols, and compliance requirements.
- Awareness Campaigns: Regularly update staff on best practices and emerging threats.
Roles and Responsibilities:
- Training Unit: Design and facilitate training sessions.
- Communications Team: Develop and distribute awareness materials.
8.5 Monitor and Review Compliance
Guidelines:
- Regular Audits: Schedule and perform regular compliance audits to ensure adherence to the policy.
- Feedback Mechanisms: Establish channels for reporting issues and suggestions for improvement.
Roles and Responsibilities:
- Compliance Department: Lead compliance audits and track regulatory changes.
- Data Stewards: Monitor compliance within their departments and report findings.
8.6 Facilitate Data Lifecycle Management
Guidelines:
- Data Classification: Classify data based on sensitivity and retention requirements.
- Archival and Disposal: Implement procedures for data archiving and secure disposal.
Roles and Responsibilities:
- Data Management Team: Develop and oversee lifecycle management procedures.
- IT Department: Provide tools and support for data archiving and disposal.
8.7 Promote a Culture of Data Stewardship
Guidelines:
- Engagement Programs: Engage staff through workshops, seminars, and recognition programs.
- Policy Integration: Embed data stewardship principles into daily operations and decision-making processes.
Roles and Responsibilities:
- Leadership Team: Champion data stewardship and lead by example.
- HR Department: Incorporate data stewardship into performance evaluations and rewards.
8.8 Leverage Technology and Innovation
Guidelines:
- Advanced Analytics: Provide access to advanced analytics tools to support data-driven decision-making.
- Collaborative Platforms: Implement platforms that facilitate data sharing and collaboration.
Roles and Responsibilities:
- IT Department: Identify and deploy suitable technologies.
- Innovation Team: Promote and support the use of new tools and methodologies.
8.9 Regular Policy Review and Update
Guidelines:
- Annual Reviews: Conduct annual reviews of the policy to ensure it remains relevant and effective.
- Feedback Integration: Incorporate feedback from audits, staff, and technological advancements.
Roles and Responsibilities:
- Data Governance Committee: Lead policy review process.
- All Departments: Provide feedback and suggest improvements.
By following these implementation guidelines, our institution can ensure that the Electronic Data Repositories Policy is effectively enacted, fostering a secure, compliant, and efficient data-management environment.
9.0 MONITORING AND EVALUATION
Effective monitoring and evaluation (M&E) is crucial to ensure that the electronic data repository policy is implemented successfully and achieves its objectives. This section outlines the processes and structures necessary for ongoing assessment and improvement of the policy.
9.1 Establish Monitoring Framework
- Data Governance Committee: Define KPIs and benchmarks, oversee the monitoring framework, and ensure alignment with strategic goals.
- Data Stewards: Collect and report data related to KPIs in their departments.
9.2 Conduct Regular Audits and Assessments
- Internal Audit Team: Lead internal audits, compile findings, and recommend corrective actions.
- External Auditors: Conduct independent audits and report findings to the Data Governance Committee.
- IT Security Team: Perform risk assessments and implement necessary security measures.
9.3 Training and Capacity Building
- Training Department: Develop and deliver training programs and conduct skill assessments.
- Data Stewards: Ensure that departmental staff receive the necessary training and understand their responsibilities.
9.4 Performance Reviews and Reporting
- Data Governance Committee: Review performance reports, approve action plans, and oversee their implementation.
- Senior Management: Review and endorse performance reports and action plans.
By establishing a robust monitoring and evaluation framework, our institution can ensure that the electronic data repository policy is effectively implemented and continuously improved. This approach will help maintain high standards of data integrity, security, and compliance, ultimately supporting the institution’s strategic objectives and operational needs.
10.0 FINANCIAL IMPLICATIONS
10.1 Infrastructure and Technology Costs
Investment in hardware, software, and other technological infrastructure is required to implement the policy effectively.
- Servers and Storage Solutions: Acquisition or upgrading of servers and storage solutions to support secure and scalable data repositories.
- Security Software: Purchase advanced security software for encryption, access control, and threat detection.
- Data Management Tools: Investment in data management and analytics tools to facilitate efficient data processing and analysis.
- Backup and Recovery Systems: Implementation of robust backup and disaster recovery systems to ensure data availability and resilience.
10.2 Personnel and Training Costs
Expenditures related to hiring, training, and retaining skilled personnel to manage and oversee data repositories.
- Staffing: Hiring additional IT and data management professionals to support policy implementation and maintenance.
- Training Programs: Development and delivery of training programs to ensure that staff are proficient in data management practices and are aware of security protocols.
- Ongoing Education: Continuous professional development opportunities to keep staff updated on emerging technologies and best practices.
10.3 Compliance and Audit Costs
Expenses associated with ensuring compliance with legal and regulatory requirements and conducting regular audits.
- Legal and Compliance Consulting: Engaging legal experts and compliance consultants to guide policy implementation and ensure adherence to relevant regulations.
- Audit Services: Hiring external auditors to perform regular compliance audits and security assessments.
- Internal Audit Team: Establishing or expanding an internal audit team to conduct ongoing assessments and reviews.
10.4 Security Enhancements
Investment in security measures to protect data repositories from unauthorized access, breaches, and other threats.
- Multi-Factor Authentication: Implementation of MFA across all data access points.
- Encryption Solutions: Deployment of encryption technologies for data at rest and during transit.
- Security Monitoring: Subscription to advanced security monitoring and incident response services.
- Physical Security: Enhancements to physical security measures for on-premise data centres.
10.5 Data Lifecycle Management
Costs associated with managing the entire lifecycle of data, from creation and storage to archiving and disposal.
- Data Classification Tools: Acquisition of tools to classify and manage data according to their sensitivity and retention requirements.
- Archival Systems: Implementation of archival solutions for long-term storage of inactive data.
- Secure Disposal Services: Engaging services for the secure disposal of data that are no longer required.
10.6 Contingency Fund
Contingency fund to address unforeseen expenses related to policy implementation and maintenance.
- Incident Response: Funds allocated for managing data breaches or other security incidents.
- Unexpected Upgrades: Costs for unplanned upgrades or replacements of critical infrastructure.
The financial implications of an electronic data repository policy encompass a range of costs related to infrastructure, personnel, compliance, security, lifecycle management, policy development, and contingency planning. These investments are essential to ensure secure, efficient, and compliant management of our data repositories, ultimately supporting the institution's strategic goals and operational needs.