Policy # 5000-20
Title: Information Security Program
Current Version Approved: (by Cabinet on 1-13-04)
Primary Responsible Office: Information Services
Secondary Responsible Office: Legal Affairs

University of Wisconsin-Green Bay
Information Security Program

Section I.

Privacy Protection

The Gramm-Leach Bliley Act (GLBA) requires financial institutions to develop, implement and maintain a comprehensive written information security program that contains administrative, technical and physical safeguards appropriate to the size and complexity of the institution, the nature and scope of its activities and the sensitivity of any customer information issue. Because higher education institutions participate in financial activities, such as making Federal Perkins Loans, Federal Trade Commission (FTC) regulations consider them financial institutions for GLBA purposes.

The University of Wisconsin-Green Bay is committed to safeguarding all personally identifiable information we obtain about individuals. The only personally identifiable information the University collects is that which is voluntarily provided. This information is kept confidential to the University of Wisconsin-Green Bay.

The University of Wisconsin-Green Bay will share personally identifiable information about you to other companies or people only when one or more of the following conditions apply:

• We have your consent to share the information;
• We need to share your information to provide the product or service you have requested;
• We need to send the information to companies/agencies who work on behalf of the University of Wisconsin –Green Bay to provide a product or service you have requested. These companies do not have any right to use the personally identifiable information we provide beyond what is necessary to assist us.
• We respond to legally issued subpoenas, court orders or a legal process;
• We need to fulfill an obligation as an educational institution of the State of Wisconsin; or
• We find it necessary to protect and defend the legal rights or property of the University of Wisconsin-Green Bay.

Section II.

Access, Security and Control of Data and Information Policy

Purpose and Scope

The University of Wisconsin-Green Bay maintains both paper records and computer information systems to carry out its educational mission. Federal and State laws and regulations govern access to these records. The University establishes local policies and procedures to ensure compliance with these laws and regulations and to protect the integrity of University records and the privacy of individuals. The following policy statements are applicable to all areas of the University and must be observed by all persons dealing with such information, including all University employees and students, as well as other individuals or entities that share University information for business purposes.

Policy and Principles

Data contained in the University’s systems are the property of the University of Wisconsin-Green Bay and represent official University records. Exceptions to this policy are: faculty developed curricular material, student developed curricular material, or certain licensed information such as electronic journal subscriptions. Questions regarding exceptions should be discussed with the University Legal Counsel.

Users who are granted access to University data, regardless of the medium, also accept responsibility for adhering to certain principles in the use and protection of that data. These principles are:

1. Information systems within the University shall be used only for and contain only data necessary for fulfillment of the University’s mission.
2. University data shall be used solely for the legitimate business of the University.
3. Due care shall be exercised to protect University data and information systems from unauthorized use, disclosure, alteration or destruction.
4. University data regardless of who collects or maintains it, shall be shared among those faculty or staff whose responsibilities require knowledge of such data.
5. Applicable federal and state laws and University policies and procedures concerning storage, retention, use, release, transportation and destruction of data and/or all information systems, content and components shall be observed.
6. Appropriate university procedures shall be followed in reporting any breach of security or compromise of safeguards.
7. University computerized information systems shall be constructed in such a manner to assure that:
   1. Accuracy and completeness of all system contents are maintained during storage and processing;
   2. Data, text and software stored and processed can be traced forward and backward for audit ability;
   3. Information systems capabilities can be reestablished within an acceptable time due to loss or damage by accident, malfunction, breach of security or act of God; and
   4. Actual or attempted breaches of security can be detected promptly.
8. Any faculty or staff member engaging in unauthorized use, disclosure, alteration or destruction of information systems or data in violation of this policy shall be subject to appropriate disciplinary action, including possible dismissal.
9. Any student engaging in unauthorized use, disclosure, alteration or destruction of information systems or data in violation of this policy shall be subject to appropriate disciplinary action, including possible expulsion.
10. Users may not use, query, release or print data in any application which they have not been given deliberate access to, which can include but is not limited to:
    1. Transcripts, grade reports, enrollment reports;
    2. Financial Aid information;
    3. Personnel, leave, salary reports;
    4. Reports for government or funding agencies;
    5. Fund-raising activities;
    6. Mailing lists and labels; and
    7. Private or public release of data to outside parties such as student, parents, and the news media.
11. All requests for information under the Freedom of Information Act, the Wisconsin Public Records Law, law enforcement agencies, subpoenas, etc. must be referred to the University Legal Counsel before releasing any records. Records will only be released at the direction of the University Legal Counsel.
12. All contracts with third parties must include the following privacy clause or a similar clause approved by the University Legal Counsel:

    Privacy Assurance. The University of Wisconsin-Green Bay is committed to safeguarding all personally identifiable information we obtain about individual. UW-Green Bay selects appropriate service providers that in the normal course of business may need personally identifiable information in order to provide the service requested by UW-Green Bay’s customers. All such service providers are required to protect the confidentiality of this personally identifiable information according to the Gramm Leach Bliley Act (“GLB”) and the FTC Safeguards Rule (16 CFR Part 314) and no less rigorously than it protects its own confidential information. Service providers shall not use or disclose confidential customer information received from or on behalf of UW-Green Bay except as permitted by or required by this Agreement, as required by law, or otherwise authorized in writing by UW-Green Bay.

Responsibilities

Safeguarding of University information systems and data shall be the responsibility of each faculty, staff or student with knowledge of and access to the records system or data. Specific responsibilities are as follows:

• Supervisors – Supervisors are responsible for ensuring that staff within their area of accountability are aware of their responsibilities as defined in this policy. Specifically, supervisors are responsible for validating the access requirements of their staff according to their job functions prior to submitting requests for access, and for ensuring a secure office environment with regard to University information systems. Offices that have records custodian responsibilities should appoint an individual within their staff to ensure these responsibilities are carried out. Supervisors are also responsible for ensuring that their staff members attend appropriate training sessions offered by the University to ensure compliance with laws, regulations and local policies.

• Employees – Faculty, staff, and student employees, are responsible for the protection, privacy, and control of all University data they access or create, regardless of the data storage medium. All employees must ensure that the data and data media are maintained and disposed of in a secure manner. All employees are responsible for understanding the meaning and purpose of the data to which they have access, and may use this data only to support the normal functions of the employees’ administrative and academic duties. All employees are responsible for all transactions occurring under his/her userid and/or password. Passwords and userids may not be shared with anyone under any circumstances unless the Associate Provost for Information Services in consultation with the University Legal Counsel approves an exception.

• Students – Students are responsible for protecting their userids and passwords so that no unauthorized persons would have access to their University records. Students are responsible for reading and understanding the Acceptable Use Policy, Email Policy, and Student Handbook, and complying with these policies and practices. Students should participate in University sponsored training sessions to improve their understanding of how to safeguard their own privacy.

• Associate Provost for Information Services is responsible for providing administrative, technical and educational support in the area of information security for all users of the information systems. This support includes but is not limited to: computer account management; system and network security administration; firewall management; and information security training program.

Responsibility for Implementation

The Associate Provost for Information Services serves as the coordinator of the Information Security Program of the University of Wisconsin-Green Bay.

Responsibility for Interpretation

The Associate Provost for Information Services will consult with the University Legal Counsel regarding interpretation of this policy. Final authority for interpretation rests with the Chancellor and is generally delegated to the University Legal Counsel.