Local and Cloud Services Decision Matrix

Risks and Considerations of Cloud Services
Approved Services
- Cloud Services
- Local Services
Security Review for New Services
Non-Compliance and Exceptions
Related UT Austin Policies

Risks and Considerations of Cloud Services

Approved Services

This table indicates which data categories (Published, Controlled, and Confidential) are allowed on a selection of common IT services.

Published Data -----> Generally Low Risk
Controlled Data -----> Generally Presents a Moderate Risk
Confidential Data -----> Can be High to Very High Risk Depending on the Type of Data and the Compliance Framework it Falls Under

For more information on data classification, please see UT's Data Classification Standard.

The cloud services below have color coded checkboxes below to help you know which types of university data is authorized to be used.

Some data types require additional steps to process and store securely. Additional information can be found in the linked footnotes. For products displaying "Contact the ISO", please reach out at security@utexas.edu.

Cloud Collaboration Services

Cloud Collaboration Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Cisco Spark/Webex Teams	YES	YES	NO	NO	NO	NO	NO	NO	NO
Slack (slack.com)³	YES	YES	NO	YES	NO	NO	NO	NO	NO
Microsoft 365 Platform (e.g, OneDrive, Sharepoint, Teams, Forms)⁴	YES	YES	YES	YES	NO	NO	NO	YES	NO
Zoom	YES	YES	YES	YES	NO	NO	NO	NO	NO
Panopto	YES	YES	NO	YES	NO	NO	NO	NO	NO
Canvas¹⁰	YES	YES	NO	YES	NO	NO	NO	NO	NO

Cloud Document Services

Cloud Document Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Apple iCloud ⁵	YES	NO	NO	NO	NO	NO	NO	NO	NO
Google Suite for Education ⁸	YES	YES	NO	YES	NO	NO	NO	NO	NO
Docusign	YES	YES	YES	YES	YES	NO	NO	YES	NO
Smartsheet	YES	YES	NO*	YES	NO	NO	NO	NO	NO

Cloud Email Services

Cloud Email Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Apple iCloud ⁵	YES	NO	NO	NO	NO	NO	NO	NO	NO
UTmail ⁸	YES	YES	NO	NO	NO	NO	NO	NO	NO
UT Outlook 365 ⁴	YES	YES	YES	NO	NO	NO	NO	NO	NO

Cloud Infrastructure Services (IaaS)

Cloud Infrastructure Services (IaaS)	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Google GCP ⁹	YES	YES	YES	YES	Contact the ISO	Contact the ISO	NO	YES	NO
Amazon (AWS)⁹	YES	YES	YES	YES	Contact the ISO	NO	NO	YES	NO
MS Azure ⁴	YES	YES	YES	YES	NO	NO	NO	YES	NO

Cloud Storage Services

Cloud Storage Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Apple iCloud ⁵	YES	NO	NO	NO	NO	NO	NO	NO	NO
Box	YES	YES	YES	YES	Contact the ISO	Contact the ISO	Contact the ISO	YES	NO
DropBox ⁵	YES	NO	NO	NO	NO	NO	NO	NO	NO
Google Suite for Education (utmail.utexas.edu)⁸	YES	YES	NO	YES	NO	NO	NO	NO	NO
Microsoft 365 Platform (e.g, OneDrive, Sharepoint, Teams, Forms)⁴	YES	YES	YES	YES	Contact the ISO	Contact the ISO	Contact the ISO	YES	NO
UT Backup (e.g., Code42/Crashplan)	YES	YES	YES	YES	Contact the ISO	NO	NO	YES	NO

Cloud Survey Services

Cloud Survey Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Qualtrics	YES	YES	YES	YES	NO	NO	NO	YES	NO
Microsoft 365 Platform (e.g, OneDrive, Sharepoint, Teams, Forms)⁴	YES	YES	YES	YES	NO	NO	NO	YES	NO

Cloud Web Hosting Services

Cloud Web Hosting Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Content Management: UT Drupal Kit - Managed, Pantheon Web Hosting (Drupal, WordPress, etc.)	YES	YES	NO	YES	NO	NO	NO	NO	NO

Cloud Workflow Platforms

Cloud Workflow Platforms	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Salesforce	YES	YES	YES	YES	NO	NO	NO	NO	NO
ServiceNow	YES	YES	YES	NO	NO	NO	NO	NO	NO

AI Services

AI Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
OpenAI ChatGPT (free) ⁷	YES	NO	NO	NO	NO	NO	NO	NO	NO
OpenAI ChatGPT Teams ⁷	YES	NO	NO	NO	NO	NO	NO	NO	NO
OpenAI ChatGPT Enterprise ⁷	YES	YES	YES	YES	NO	NO	NO	NO	NO
Microsoft Copilot (free) ⁷	YES	YES	NO	NO	NO	NO	NO	NO	NO
Microsoft Copilot for M365 (paid) ⁷	YES	YES	YES	YES	NO	NO	NO	NO	NO
Microsoft Azure OpenAI API ⁷	YES	YES	YES	YES	NO	NO	NO	NO	NO
Google Gemini ⁷	YES	NO	NO	NO	NO	NO	NO	NO	NO
AWS Bedrock and AI Services ⁷	YES	YES	YES	YES	NO	NO	NO	NO	NO

Local Services

For comparison purposes, select services run by ITS and offered to campus are listed below with the types of data that are approved for use with each. Use of locally hosted services is encouraged over cloud services when possible. This table is not intended to be a comprehensive list of all ITS offered services.

Local Services	Published	Controlled	Confidential
			HIPAA¹	FERPA	SSNs¹¹	PCI²	ITAR⁶	IRB	CUI
Database Hosting: ITS-Supported MySQL, SQLServer, Oracle	YES	YES	3	YES	YES	YES	NO	YES	NO
File Storage: Austin Disk	YES	YES	NO	YES	YES	YES	NO	YES	NO
UT Wikis	YES	YES	NO	NO	NO	NO	NO	NO	NO
UT Backup (e.g., Code42/Crashplan) - see above - The cloud option is the only available option.	YES	YES	YES	YES	YES	YES	NO	YES	NO
Virtual Servers (UT VMG)	YES	YES	YES	YES	YES	YES	NO	YES	NO
REDCap (instance maintained by VP Research)	YES	YES	NO	YES	NO	NO	NO	YES	NO
REDCap (instance maintained by Dell Medical School)	YES	YES	YES	YES	YES	NO	NO	YES	NO
On Premise GitHub	YES	YES	NO	YES	YES	YES	NO	YES	NO

Footnotes
1 HIPAA data has special regulatory requirements; read this for more info. If you have any questions about storing/procesing HIPAA data, reach out to the Information Security Office (security@utexas.edu).
2 Payment Card Industry (PCI) data has special regulatory requirements; read this for more info. It may be necessary to store PCI data but faculty/staff must consult with the Information Security Office to determine how to do so securely.
3 No enterprise contract currently; each department must go through the Contracts Office for their own contract with a FERPA agreement.
4 Authorized usage is limited to Microsoft services provided under the ITS-managed vendor contract to remain compliant. Any use of the standard consumer-grade offerings of these products is not approved. Emailing FERPA protected information via O365 is not acceptable and such correspondence should be limited to Canvas or other university approved services to ensure compliance with https://provost.utexas.edu/the-office/academic-affairs/canvas-adoption-policy/. HIPAA protected information may only be emailed via O365 if the data is encrypted in transit and only decrypted by the intended recipient.
5 As there is no university contract in place for this vendor, no usage involving protected or restricted university data is permitted. Use of this vendor product with Confidential data is a violation of Section 2 of the IRUSP.
6 It may be possible to store ITAR protected data if properly encrypted prior to being uploaded, but staff/faculty must consult with the Information Security Office (security@utexas.edu) prior to storing/processing ITAR data.
7 AI products must have been an active university contract in place and have a vendor security assessment completed to be considered compliant with state requirements if confidential university data is to be involved. Please see the Acceptable Use of AI Tools for more details. For ChatGPT-specific services, approved usage only applies to the dedicated UT instances of ChatGPT Enterprise covered by UT Austin contracts. For the Microsoft-specific services, approved usage only applies to the dedicated UT instances covered by UT System contracts. If you aren't sure if your use case is covered please contact ISO (security@utexas.edu). For information on obtaining ChatGPT Enterprise licenses, please email: security@utexas.edu. For information on obtaining Microsoft CoPilot for M365 licenses, please email: microsoft365@utexas.edu.
8 Authorized storage of FERPA protected data is limited to the Google Drive service of the UTmail offering. Emailing FERPA protected information via UTmail is not acceptable and such correspondence should be limited to Canvas or other university approved services to ensure compliance with https://provost.utexas.edu/the-office/academic-affairs/canvas-adoption-policy/.
9 Authorized usage of Google GCP or AWS is limited to services provided under the ITS-managed vendor contract to remain compliant. Any use of the standard consumer-grade offerings of these products is not approved. Also, depending on the associated university data for certain cloud infrastructure it may be necessary to implement additional security monitoring. Please consult with the Information Security Officer to determine if monitoring is needed and to understand how we can assist you.
10 Canvas Conversations/Inbox are not approved for FERPA protected communications since copies of the message are forwarded to email addresses that are often not in a protected university service and thereby not encrypted.
11 SSN data has special risks and requirements; read this for more info. If SSNs must be stored/processed, reach out to the Information Security Office (security@utexas.edu) to request an exception.

Security Review for New Services

Departments evaluating the purchase and/or use of a cloud service not covered on this page with any Confidential university data must request a security review of that service by sending a written description of the proposed implementation to the Information Security Office. During service selection, departments should inform vendors that security testing (either performed by the Information Security Office or a qualified third party to the vendor) is mandatory for the university purchasing process.

Non-Compliance and Exceptions

If, for any purpose, a non-approved cloud service is used with any Confidential university data, an Exception Process must be initiated that includes reporting the non-compliance to the Information Security Office, along with a plan for risk assessment and management. (See Security Exception Report) Non-compliance with these standards may result in revocation of system or network access, notification of supervisors, and reporting to the Office of Internal Audit.

University of Texas at Austin employees are required to comply with institutional rules and regulations, applicable UT System rules and regulations, state laws and regulations, and federal laws and regulations.

Related UT Austin Policies

The policies and practices listed here inform the system hardening procedures described in this document and with which you should be familiar. (This is not an all-inclusive list of policies and procedures that affect information technology resources.)

Revision History
Version	Date	New	Original