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Policy title
Graham-Leach-Bliley Act Information (Data) Security Program
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Category
Information Technology
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Owner
CSIT
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Approved by
Ad Council
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Nebraska Wesleyan University (NWU) recognizes the importance of and is committed to creating effective administrative, technical, and physical safeguards to protect faculty, staff and student information from unauthorized access. NWU is an academic community dedicated to intellectual and personal growth within the context of a liberal arts education and in an environment of Christian concern. In the normal course of pursuing this mission, NWU receives some sensitive information from our faculty, staff and students which may include financial, educational or medical information.
In compliance with federal and state laws, NWU has developed this information (data) security program (“ISP”) which outlines the University’s policy and procedures for evaluating and addressing the electronic and physical methods for accessing, collecting, storing, using, transmitting and protecting faculty, staff and student information.
The Chief Information Officer is designated as the person who shall be responsible for overseeing and updating the ISP as needed (ISP Representative). The ISP Representative reports directly to the NWU Vice President for Finance and Administration. The ISP Representative may assign or delegate other NWU representatives to oversee and coordinate elements of the ISP. Any questions regarding the implementation of the ISP or with interpreting this document should be directed to the ISP Representative or their designees.
The ISP Representative will verify compliance with this policy through various methods, including but not limited to, periodic walkthrough, monitoring, business tool reports, and internal and external audits. The ISP Representative will report all findings, regulatory and state security laws changes, and any other information technology security related matters directly to the NWU Vice President for Finance and Administration.
Compliance with this policy is mandatory for all University employees and any independent contractors. Employees should notify their immediate supervisor of any member of management upon learning of violations of this policy. The supervisor or member of management will be responsible for notifying the University’s ISP representative. Violations for this policy (including knowingly failing to notify a supervisor or member of management of a violation) will be subject to disciplinary action, up to and including termination of employment.
Risk Identification and Assessment
NWU has undertaken, as part of the ISP, to identify and assess potential internal and external risks to the security, confidentiality and integrity of information held or managed by NWU that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromises of such information.
The risk assessment and safeguard control policies described here shall apply to all methods of handling or disposing of client information, whether in electronic, paper or other form. The ISP Representative will, on a regular basis, implement safeguards to control the risks identified through such assessments and regularly test or otherwise monitor the effectiveness of such safeguards in relevant areas of the University’s operations, including:
The NWU ISP Representative will implementation methods to identify potential risks to the security, confidentiality and integrity of NWU information and monitor the effectiveness of safeguards implemented to mitigate those risks. These methods may include (but are not limited to):
NWU has identified critical areas of internal and external risk to the security, confidentiality and integrity of institutional information and which could result in the unauthorized access, disclosure, misuse, alteration, destruction or some other way compromise such information. The University has implemented safeguards for controlling risks associated with these risks related to the handling, collecting, storing, using, transmitting and protecting information.
The ISP Representative shall coordinate with those responsible for the third-party service procurement activities within NWU CSIT and other affected departments to raise awareness of, and to institute methods for, selecting and retaining only those service providers that are capable of maintaining appropriate safeguards for institutional information to which they will have access. In addition, the ISP Representative will work with the NWU Controller or other designate official to develop and incorporate standard, contractual protections applicable to third-party service providers, which will require such providers to implement and maintain appropriate safeguards. Any deviation from these standard provisions will require the approval of the NWU Controller or designate official.
The ISP Representative will be responsible for reviewing the ISP at least annually and reporting the results of that review to the Vice President for Finance and Administration. The ISP Representative will evaluate the program based on the risk identification and assessment activities undertaken under the terms of the program, as well as any material changes to the University’s operations or other factors that may have an impact upon the program. The ISP Representative will propose adjustments to the program based on this review.