Information
Security Program Outline
May 2003
Background
Carnegie
Mellon is required by the Gramm–Leach–Bliley Act (“GLBA”) and its implementing
regulations at 16 CFR Part 314, to implement and maintain a comprehensive
written Information Security Program (“ISP”) and to appoint 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.
Related Policies
This ISP is in addition to existing Carnegie Mellon policies and procedures
that address various aspects of information privacy and security, including but
not limited to, the Student Privacy Rights Policy (Family Educational Rights
and Privacy Act Policy), the Data and Computer Security Policy, and the Computing
Policy.
ISP Coordinator
Carnegie
Mellon has designated the Vice Provost for Computing Services as its ISP
Coordinator. The ISP Coordinator may designate other individuals to oversee
and/or coordinate particular elements of the ISP.
Covered Information
“Covered information” means nonpublic personal information about a
student or other third party who has a continuing relationship with Carnegie
Mellon, where such information is obtained in connection with the provision of
a financial service or product by Carnegie Mellon, and that is maintained by
Carnegie Mellon or on Carnegie Mellon’s behalf. Nonpublic personal information includes
students’ names, addresses and social security numbers as well as students’ and
parents’ financial information. Covered information does not include records
obtained in connection with single or isolated financial transactions such as
ATM transactions or credit card purchases.
Elements of the ISP
1. Risk Identification and Assessment. Carnegie Mellon intends
through its ISP to identify and assess external and internal risks to the
security, confidentiality, and integrity of covered information that could
result in the unauthorized disclosure, misuse, alteration, destruction or other
compromise of such information. The ISP Coordinator will provide guidance to
appropriate personnel in the central administration, academic units, and other
university units in evaluating their current
practices and procedures and in assessing reasonably anticipated risks to
covered information in their respective areas. The ISP Coordinator will work
with appropriate personnel to establish procedures for identifying and
assessing risks in the following areas:
2. Designing
and Implementing Safeguards. The ISP
Coordinator will coordinate with appropriate personnel to design and implement
safeguards, as needed, to control the risks identified
in assessments and will develop a plan to regularly test or otherwise monitor
the effectiveness of such safeguards. Such testing and monitoring may be
accomplished through existing network monitoring and problem escalation
procedures.
3. Overseeing
Service Providers.
The ISP Coordinator, in conjunction with the Office of the General Counsel and
with Carnegie Mellon Purchasing Services & Supplier Management, will assist
in instituting methods for selecting and retaining service providers that are
capable of maintaining appropriate safeguards for covered information. The ISP
Coordinator will work with the Office of the General
Counsel to develop and incorporate standard, contractual provisions for service providers that will require providers
to implement and maintain appropriate safeguards. These standards will apply to
all existing and future contracts entered into with service providers to the
extent required under GLBA, provided that amendments to contracts entered into
prior to
4. Adjustments
to Program.
The ISP Coordinator will evaluate and adjust the ISP as needed, based on the
risk identification and assessment activities undertaken pursuant to the ISP,
as well as any material changes to Carnegie Mellon’s operations or other
circumstances that may have a material impact on the ISP.