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Information Security Plan--DRAFT

This Information Security Plan describes BYU-Hawaii's safeguards to protect covered data and information.1 These safeguards are provided to:

  • Ensure the security and confidentiality of covered data and information;

  • Protect against anticipated threats or hazards to the security or integrity of such information; and

  • Protect against unauthorized access to or use of covered data and information that could result in substantial harm or inconvenience to any customer.

This Information Security Plan also provides for mechanisms to:

  • Identify and assess the risks that may threaten covered data and information maintained by BYU-Hawaii;

  • 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 covered data and information and internal or external threats to information security. 

 

Identification and Assessment of Risks to Customer Information 

BYU-Hawaii recognizes that it has both internal and external risks. These risks include, but are not limited to:

  • Unauthorized access of covered data and information by someone other than the owner of the covered data and 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 covered data and information by employees

  • Unauthorized requests for covered data and information

  • Unauthorized access through hardcopy files or reports

  • Unauthorized transfer of covered data and information through third parties 

BYU-Hawaii recognizes that this may not be a complete list of the risks associated with the protection of covered data and information. Since technology growth is not static, new risks are created regularly. Accordingly, the Office of Information Technology will actively participate and monitor advisory groups such as the Educause Security Institute, the Internet2 Security Working Group and SANS for identification of new risks.

BYU-Hawaii believes OIT current safeguards are reasonable and, in light of current risk assessments are sufficient to provide security and confidentiality to covered data and 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

The Chief Information Officer and IT Security Coordinator have been appointed as the coordinators of this Plan. They are responsible for assessing the risks associated with unauthorized transfers of covered data and information and implementing procedures to minimize those risks to BYUH. Internal Audit personnel will also conduct reviews of areas that have access to covered data and information to assess the internal control structure put in place by the administration and to verify that BYUH 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 covered data and 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 covered data and 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, and how to properly dispose of documents that contain covered data and information. Each department responsible for maintaining covered data and 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 covered data and information should coordinate with the Office of General 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 covered data and information security.

Physical Security

BYUH has addressed the physical security of covered data and 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 BYUH 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 covered data and information are shredded at time of disposal.

Information Systems

Access to covered data and information via BYUH’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 covered data and information, including, but not limited to, accounts, balances, and transactional information, are available only to BYUH employees in appropriate departments and positions.

BYUH will take reasonable and appropriate steps consistent with current technological developments to make sure that all covered data and information is secure and to safeguard the integrity of records in storage and transmission. OIT requires that all servers must be registered before being allowed through BYUH’s firewall, thereby allowing OIT to verify that the system meets necessary security requirements as defined by OIT 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 BYU-Hawaii Password Policy (see related article). In addition, a CES-wide intrusion detection system is being evaluated to detect and stop certain external threats, along with an existing Incident Response Policy (see related article on breach of personally identifiable information) for occasions where intrusions do occur.

When commercially reasonable, encryption technology will be utilized for both storage and transmission. All covered data and information stored on campus will be maintained on servers that are behind BYUH’s firewall. All firewall software and hardware maintained by OIT will be kept current. OIT has a number of policies and procedures in place to provide security to BYUH’s information systems. These policies are available in the TeamDynamix Knowledge Base.

Social Security numbers are not used for any campus identification or usernames. When Social Security numbers are required (Financial Aid, employment, and health insurance, for example), OIT regularly reviews use, storage, and disposal as part of its review of other personally identifiable information.

Management of System Failures

OIT, with assistance of CES, is developing plans and procedures to detect any actual or attempted attacks on BYUH systems, with an Incident Response Policy outlining procedures for responding to an actual or attempted unauthorized access to covered data and information. 

 

Selection of Appropriate Service Providers

Due to the specialized expertise needed to design, implement, and service new technologies, vendors are often used to provide resources that BYUH determines not to provide on its own. In the process of choosing a service provider that will maintain or regularly access covered data and 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 acknowledgement 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 OIT 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 BYUH 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--at least annually. The most frequent of these reviews will occur within OIT, 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 OIT implementation and administration as appropriate. The Coordinators, in consultation with the Office of General Counsel, will review the standards set forth 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. 


1Student financial information is that information that BYU-Hawaii 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. 

Details

Article ID: 38732
Created
Wed 9/6/17 9:35 AM
Modified
Wed 9/6/17 10:08 AM