Policy 7.1.9 - Information Security Plan


I. OVERVIEW

In accordance with the Gramm-Leach-Bliley Act (“GLBA”), 16 CFR Part 314, Montgomery Community College implements and maintains a comprehensive written Information Security Plan (“ISP”) and appoints a coordinator for the program. The objectives of the ISP are to (1) insure the security and confidentiality of covered information; (2) protect against anticipated threats or hazards to the security and integrity of such information; and (3) protect against unauthorized access or use of such information that could result in substantial harm or inconvenience to customers.

II. INFORMATION SECURITY PLAN

This Information Security Plan (“Plan”) describes safeguards implemented by the College to protect covered data and information in compliance with the FTC’s Safeguards Rule promulgated under the Gramm Leach Bliley Act (GLBA). 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 Program also identifies mechanisms to:

  • Identify and assess the risks that may threaten covered data and information maintained by the College;
  • Develop written policies and procedures to manage and control these risks;
  • Implement and review the program; and
  • Adjust the program to reflect changes in technology, the sensitivity of covered data and information and internal or external threats to information security.

III. INFORMATION SECURITY PROGRAM COORDINATOR(S)

The Vice President of Administrative Services and the Dean of Technology & Learning Resources serve as the coordinators of this Program at MCC. They are responsible for assessing the risks associated with unauthorized transfers of covered data and information, and implementing procedures to minimize those risks to the College. Designated staff in both areas 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 verify that all departments comply with the requirements of the security policies and practices delineated in this program.

IV. IDENTIFICATION AND ASSESSMENT OF RISKS TO CUSTOMER INFORMATION

MCC recognizes that it is exposed to both internal and external risks, including but 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

Recognizing that this may not represent a complete list of the risks associated with the protection of covered data and information, and that new risks are created regularly, MCC’s Information Services Committee actively participates and monitors appropriate cybersecurity advisory groups for identification of risks.

V. EMPLOYEE MANAGEMENT AND TRAINING

References and/or background checks (as appropriate, depending on position) of new employees working in areas that regularly work with covered data and information (e.g. Business Office, Financial Aid) are checked/performed. During employee orientation, each new employee in these departments receives proper training on the importance of confidentiality of student records, student financial information, and all other covered data and information. Each new employee is also trained in the proper use of computer information and passwords. Training includes controls and procedures to prevent employees from providing confidential information to an unauthorized individual, as well as how to properly dispose of documents that contain covered data and information. These training efforts minimize risk and safeguard covered data and information.

VI. PHYSICAL SECURITY

MCC addresses the physical security of covered data and information by limiting access to only those employees who have a legitimate business reason to handle such information. For example, financial aid applications, income and credit histories, accounts, balances and transactional information are available only to College employees with an appropriate business need for such information. Furthermore, 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.

VII. INFORMATION SYSTEMS

Access to covered data and information via the College’s computer information system is limited to those employees and faculty who have a legitimate business reason to access such information. The college has policies and procedures in place to complement the physical and technical (IT) safeguards in order to provide security to the College’s information systems.

MCC adheres to best practices and standards set forth in the NC Institutional Information Processing System (IIPS) Manual prepared by the IIPS Security Standards Committee and provided to North Carolina community colleges.

Social security numbers are considered protected information under both GLBA and the Family Educational Rights and Privacy Act (FERPA). By necessity, student social security numbers will remain in the student information system; however, access to social security numbers is granted only in cases where there is an approved, documented business need.

VIII. OVERSIGHT OF SERVICE PROVIDERS

GLBA requires the College to take reasonable steps to select and retain service providers who maintain appropriate safeguards for covered data and information. This Information Security Program will ensure that such steps are taken by contractually requiring service providers to implement and maintain such safeguards.

IX. CONTINUING EVALUATION AND ADJUSTMENT

This information security program will be subject to periodic review and adjustment annually. Continued administration of the development, implementation and maintenance of the program is the responsibility of the designated Information Security Program Coordinator(s), who assign specific responsibility for technical (IT), logical, physical, and administrative safeguards implementation and administration as appropriate. The Information Security Program Coordinator(s) will review the standards set forth in this program and recommend updates and revisions as necessary; it may be necessary to adjust the program to reflect changes in technology, the sensitivity of student/customer data, and/or internal or external threats to information security.