This Information Security Plan ("Plan") describes Kansas State University's safeguards to protect covered data and information. Covered data and Information for the purpose of this policy 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, KSU 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. Covered data and information includes both paper and electronic records.
Student financial information is that information that KSU 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.
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 KSU;
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.
.020 Identification and Assessment of Risk to Customer Information
KSU 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
KSU 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 Security Incident Response Team will actively participate and monitor advisory groups for identification of new risks.
KSU believes current information technology safeguards are reasonable and, in light of current risk assessments are sufficient to provide security and confidentiality to covered data and information described above maintained by the central University units. Additionally, these safeguards protect against currently anticipated threats or hazards to the integrity of such information.
.030 Information Security Plan Coordinator
The Chair of the Security Information Response Team (SIRT) has been appointed as the coordinator of this Plan. The Chair is responsible for assessing the risks associated with unauthorized transfers of covered data and information and implementing procedures to minimize those risks to KSU. 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 KSU departments comply with the requirements of this policy.
.040 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, and Student Financial Assistance) 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, including "pretext calling" and how to properly dispose of documents that contain covered data and information. "Pretext 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 as employee of the University to release customer identifying 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 ensure, on an annual basis, 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
KSU 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 KSU 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 KSU's computer information system is limited to those employees who have a business reason to know such information. Each employee selects an eID and password. Databases containing personal covered data and information, including, but not limited to, accounts, balances, and transactional information, are available only to KSU employees in appropriate departments and positions.
Systems requiring passwords will specify that they must be changed twice annually, on the first of September and February. Passwords must conform to edits specified in the CNS Policy on User ID & Passwords. Systems that allow remote log-ins over the campus network must have passwords on all accounts. Checking passwords for conformance is the responsibility of the IT Security Coordinator.
KSU 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. The Vice Provost for Academic Services and Technology (VPAST) requires that all servers must be registered before being allowed through KSU's firewall, thereby allowing SIRT to verify that the system meets necessary security requirements as defined by information technology 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 KSU IT Policy.
In addition, an intrusion detection system has been implemented to detect and stop certain external threats, along with incident response procedures defined by SIRT for occasions where intrusions do occur.
When commercially reasonable, encryption technology will be utilized for both storage and transmission. All covered data and information will be maintained on servers that are behind KSU's firewall. All firewall software and hardware maintained by Computing and Network Services will be kept current. The University has a number of policies and procedures in place to provide security to KSU's information systems. These policies are available in the University's Policy and Procedures Manual at www.ksu.edu/policies/ppm.
The University presently maintains a secure firewall for protecting the social security numbers of its students and employees. The University expects by the end of 2007 to have in place information systems for student records and employee records which will identify its students and employees without use of social security numbers.
Management of System Failures
The Security Incident Response Team is developing written plans and procedures to detect any actual or attempted attacks on KSU systems and has defined procedures for responding to an actual or attempted unauthorized access to covered data and information.
.050 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 KSU 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 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 KSU to terminate the contract without penalty; and
A provision ensuring that the contract's confidentiality requirements shall survive any termination of the agreement.
.060 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 the SIRT, 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 Coordinator who will assign specific responsibility for implementation and administration as appropriate. The Coordinator, in consultation with the University Attorney's Office and VPAST, 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.
Questions regarding this policy should be sent to the Director of Academic Services at academicservices@k-state.eduSource : http://www.k-state.edu/policies/ppm/3415.html
