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UNIVERSITY INFORMATION SECURITY PLAN | No. 5-17 | Rev. |
| Date: 04-13-04 | |||
OLD VERSION
POLICY
A. This Information Security Plan ("Plan") describes Weber State University's safeguards to protect personal financial information.1 These safeguards are provided to:
- Ensure the security and confidentiality of personal financial information;
- Protect against anticipated threats or hazards to the security or integrity of such information; and
- Protect against unauthorized access to or use of personal financial information that could result in substantial harm or inconvenience to any customer.
B. This Information Security Plan also provides for mechanisms to:
- Identify and assess the reasonably foreseeable risks that may threaten personal financial information maintained by Weber State University;
- Develop written policies and procedures to manage and control these risks;
- Implement and review the plan; and
- Adjust the plan to reflect changes in technology, the sensitivity of personal financial information and internal or external threats to information security.
IDENTIFICATION AND ASSESSMENT OF RISKS
The University recognizes that it has both internal and external risks. These risks include, but are not limited to:
- Unauthorized access of personal financial information by someone other than the owner of the personal financial information;
- Compromised system security as a result of system access by an unauthorized person;
- Interception of data during transmission;
- Loss of data integrity;
- Physical loss of data in a disaster;
- Errors introduced into the system;
- Corruption of data or systems;
- Unauthorized access of personal financial information by employees;
- Unauthorized access through hardcopy files or reports; and
- Unauthorized transfer of personal financial information through third parties.
The University recognizes that this may not be a complete list of the reasonably foreseeable risks associated with the protection of personal financial information. Since technology growth is not static, new risks are created regularly. Accordingly, the Information Technology Division ("ITD") will actively participate and monitor advisory groups for identification of new risks.
The University believes ITD current safeguards are reasonable and, in light of current risk assessments, are sufficient to provide security and confidentiality to personal financial information maintained by the University. Additionally, these safeguards protect against currently anticipated threats or hazards to the integrity of such information.
INFORMATION SECURITY PLAN COORDINATORS
University will appoint two administrators to act as the coordinators of the Plan. They are responsible for assessing the risks associated with unauthorized transfers of personal financial information and implementing procedures to minimize those risks to Weber State University. Internal Audit personnel will also conduct reviews of areas that have access to personal financial information to assess the internal control structure put in place by the administration and to verify that Weber State University departments comply with the requirements of this policy.
DESIGN AND IMPLEMENTATION OF SAFEGUARDS PROGRAM
Employee Management and Training
References of new employees working in areas that regularly work with personal financial information (Cashier's Office, Registrar, Development and Financial Aid) are checked. During employee orientation, each new employee in these departments will receive proper training on the importance of confidentiality of student records, student financial information, and other types of personal financial information. Each new employee is also trained in the proper use of computer information and passwords. Training also includes controls and procedures to prevent employees from providing confidential information to an unauthorized individual, including "pretext calling"2 and how to properly dispose of documents that contain personal financial information. Each department responsible for maintaining personal financial information is instructed to take steps to protect the information from destruction, loss or damage due to environmental hazards, such as fire and water damage or technical failures. Further, each department responsible for maintaining personal financial information should coordinate with the Office of University Legal Counsel on an annual basis for the coordination and review of additional privacy training appropriate to the department. These training efforts should help minimize risk and safeguard personal financial information security.
Physical Security
Weber State University has addressed the physical security of ITD personal financial information by limiting access to only those employees who have a business reason to know such information. For example, personal customer information, accounts, balances and transactional information are available only to University employees with an appropriate business need for such information.
Loan files, account information and other paper documents are kept in file cabinets, rooms or vaults that are locked each night. Only authorized employees know combinations and the location of keys. Paper documents that contain personal financial information are shredded at time of disposal.
Information Systems
Access to personal financial information via the University's computer information system is limited to those employees who have a business reason to know such information. Each employee is assigned a user name and password. Databases containing personal financial information including, but not limited to, accounts, balances, and transactional information, are available only to University employees in appropriate departments and positions.
The University will take reasonable and appropriate steps consistent with current technological developments to make sure that all personal financial information is secure and to safeguard the integrity of records in storage and transmission. ITD requires that all servers must be registered before being allowed through Weber State University's firewall, thereby allowing ITD to verify that the system meets necessary security requirements as defined by ITD policies. These requirements include maintaining the operating system and applications, including application of appropriate patches and updates in a timely fashion. User and system passwords are also required to comply with the Weber State University Password Policy. In addition, an intrusion detection system has been implemented to detect and stop certain external threats, along with an Incident Response Policy for occasions where intrusions do occur.
When commercially reasonable, encryption technology will be utilized for both storage and transmission. All personal financial information will be maintained on servers that are behind the University's firewall. All firewall software and hardware maintained by ITD will be kept current. ITD has a number of policies and procedures in place to provide security to the University's information systems. These policies are available upon request from the University's Chief Information Officer.
Management of System Failures
ITD has developed written plans and procedures to detect any actual or attempted attacks on University systems and has an Incident Response Policy which outlines procedures for responding to an actual or attempted unauthorized access to personal financial information. This policy is available upon request from the University's Chief Information Officer.
Selection of Appropriate Service Providers
Due to the specialized expertise needed to design, implement, and service new technologies, vendors may be needed to provide resources that the University determines not to provide on its own. In the process of choosing a service provider that will maintain or regularly access personal financial information, the evaluation process shall include the ability of the service provider to safeguard confidential financial information. Contracts with service providers may include the following provisions:
- An explicit acknowledgment that the contract allows the contract partner access to confidential information;
- A specific definition or description of the confidential information being provided;
- A stipulation that the confidential information will be held in strict confidence and accessed only for the explicit business purpose of the contract;
- An assurance from the contract partner that the partner will protect the confidential information it receives according to commercially acceptable standards and no less rigorously than it protects its own confidential information;
- A provision providing for the return or destruction of all confidential information received by the contract provider upon completion or termination of the contract;
- An agreement that any violation of the contract's confidentiality conditions may constitute a material breach of the contract and entitles the University to terminate the contract without penalty; and
- A provision ensuring that the contract's confidentiality requirements shall survive any termination agreement.
Continuing Evaluation and Adjustment
This Information Security Plan will be subject to periodic review and adjustment. The most frequent of these reviews will occur within ITD, where constantly changing technology and evolving risks mandate increased vigilance. Continued administration of the development, implementation and maintenance of the program will be the responsibility of the designated Information Security Plan Coordinators who will assign specific responsibility for ITD implementation and administration as appropriate. The Coordinators, in consultation with the Office of University Legal Counsel, will review the standards set fort in this policy and recommend updates and revisions as necessary. It may be necessary to adjust the plan to reflect changes in technology, the sensitivity of student/customer data and internal or external threats to information security.
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1Personal financial information for the purpose of this policy is defined as all nonpublic personal financial information of a consumer (customer) obtained by the University in connection with a transaction involving a financial product or service. It specifically includes student financial information (defined below) required to be protected under the Gramm Leach Bliley Act (GLB). In addition to this coverage which is required under federal law, Weber State University chooses as a matter of policy to also include in this definition any credit card information received in the course of business by the University, whether or not such credit card information is covered by GLB. Personal financial information includes both paper and electronic records.
Student financial information is that information that Weber State University has obtained from a customer in the process of offering a financial product or service, or such information provided to the University by another financial institution. Offering a financial product or service includes offering student loans to students, receiving income tax information from a student's parent when offering a financial aid package, and other miscellaneous financial services. Examples of student financial information include addresses, phone numbers, bank and credit card account numbers, income and credit histories and Social Security numbers, in both paper and electronic format.
2Pretext calling occurs when an individual improperly obtains personal information of university customers so as to be able to commit identity theft. It is accomplished by contacting the University, posing as a customer or someone authorized to have the customer's information, and through the use of trickery and deceit, convincing an employee of the University to release customer identifying information.