I. Executive Summary and Purpose
This document summarizes The University of North Carolina at Charlotte’s (the “Institution’s”) comprehensive written information security program (the “Program”) mandated by the Federal Trade Commission’s Safeguards Rule and the Gramm-Leach-Bliley Act (“GLBA”). In particular, this document describes the Program elements pursuant to which the Institution intends to:
- ensure the security and confidentiality of covered records,
- protect against any anticipated threats or hazards to the security of such records, and
- protect against the unauthorized access or use of such records or information in ways that could result in substantial harm or inconvenience to customers.
The Program incorporates by reference the Institution’s policies and procedures enumerated below, and is in addition to any institutional policies and procedures that may be required pursuant to other federal and state laws and regulations, including, without limitation, FERPA.
The Program applies to any record containing nonpublic financial information about a student or other third party who has a relationship with the Institution, whether in paper, electronic or other form, which is handled or maintained by or on behalf of the Institution or its affiliates. For these purposes, the term nonpublic financial information shall mean any information:
- a student or other third party provides in order to obtain a financial service from the Institution,
- about a student or other third party resulting from any transaction with the Institution involving a financial service, or
- otherwise obtained about a student or other third party in connection with providing a financial service to that person.
III. Designation of Representatives
The Institution’s Information Technology Security Officer (ITSO) is designated as the Program Officer who shall be responsible for coordinating and overseeing the Program. The Program Officer shall have a committee composed of the following representatives:
- Director of Student Financial Aid
- University Registrar
- Associate Vice Chancellor for Financial Services
- General Counsel
- Director of Development Services
The Program Officer may designate other representatives of the Institution to oversee and coordinate particular elements of the Program. Any questions regarding implementation of the Program or the interpretation of this document should be directed to the Program Officer or his/her designees.
IV. Program Element
a. Risk Identification and Assessment
The Institution intends, as part of the Program, to undertake to identify and assess external and internal risks to the security, confidentiality, and integrity of nonpublic financial information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information. In implementing the Program, the Program Officer or his/her designee will establish procedures for identifying and assessing such risks in each relevant area of the Institution’s operations, including:
i. Employee Training and Management The Program Officer will coordinate with representatives in the Institution’s Division of Business Affairs, Division of Student Affairs and Division of Academic Affairs to evaluate the effectiveness of the Institution’s procedures and practices relating to access to and use of student records, including financial aid information. This evaluation will include assessing the effectiveness of the Institution’s current policies and procedures in this area.
ii. Information Systems and Information Processing and Disposal
The Program Officer will coordinate with representatives of the other relevant departments to assess the risks to nonpublic financial information associated with the Institution’s information systems, including network and software design, information processing, and the storage, transmission and disposal of nonpublic financial information. This evaluation will include assessing the Institution’s current policies and procedures relating to acceptable use of the University computing facilities network security and related matters. The Program Officer will also assess procedures for monitoring potential information security threats associated with software systems and for updating such systems by, among other things, implementing patches or other software fixes designed to deal with known security flaws.
iii. Detecting, Preventing and Responding to Attacks
The Program Officer will, in coordination with other appropriate administrative units, evaluate procedures for and methods of detecting, preventing and responding to attacks or other system failures and existing network access and security policies and procedures, as well as procedures for coordinating responses to network attacks and developing incident response teams and policies. In this regard, the Program Officer may recommend that another administrator assume responsibility for monitoring and participating in the dissemination of information related to the reporting of known security attacks and other threats to the integrity of networks utilized by the Institution. b. Designing and Implementing Safeguards
The risk assessment and analysis described above shall apply to all methods of handling or disposing of nonpublic financial information, whether in electronic, paper or other form. The Program Officer will, on a regular basis, implement safeguards to control the risks identified through such assessments and 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.
c. Overseeing Service Providers
The Program Officer shall coordinate with those administrators responsible for the third party service procurement activities related to the Information Technology services unit 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 nonpublic financial information of students and other third parties to which they will have access. In addition, the Program Officer will work with the Office of Legal Affairs 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 Office of Legal Affairs. These standards shall apply to all existing and future contracts entered into with such third party service providers.
The Program Officer is responsible for evaluating and adjusting the Program based on the risk identification and assessment activities undertaken pursuant to the Program, as well as any material changes to the Institution’s operations or other circumstances that may have a material impact on the Program.
The GLBA procedural document provides details for implementation of this regulation. This separate document carries the full force of this regulation. This separation allows for easier modifications to the procedures due to the changing nature of business, technology and security.
Failure to comply with this regulation and the associated required procedures will be deemed a violation and subject to disciplinary action in accordance with appropriate University disciplinary procedures (University Policy 801: Violation of University Policy).
Upon approval, this regulation shall be published on the appropriate UNC Charlotte website(s). The following offices and individuals shall be notified in writing with any subsequent revisions or amendments made to this regulation:
- Chancellor’s Council
- Associate Provosts
- Deans, Directors and Department Heads
Approved by the Chancellor, December 20, 2007