Policy No: 2032 Responsible Office: Information Security Last Review Date: 01/06/2023 Next Required Review: 01/06/2028
Information Systems Security
This general security policy has been developed to ensure data integrity and confidentiality for all administrative computer systems at the University of South Alabama. This document will provide guidelines for the classification of data resources, and subsequent retrieval and dissemination of that data by various user groups. These guidelines will allow individual departments to approve data access authorizations for their data (in general cases). Any exceptions to user access situations covered in this general policy will be taken under special consideration by the University Computer Services Center.
More and more university employees have access to confidential information via computers. This security policy is not intended to hamper the use of computers in obtaining information necessary to conduct University, college, or departmental business. However, it is intended to encourage responsible use of computers and discretion in dissemination of student and employee information.
This policy applies to all University Divisions except for USA Health.
4. Policy Guidelines
4.1 Confidential Data
Confidential data, also referred to as Personally Identifiable Information or PII, includes any information defined as such in Federal, State, University data privacy laws and regulations. Examples include but are not limited to: Social Security; Driver’s License; Passport Numbers; Birth Date; financial information; individual’s medical or academic information; any data covered by FERPA, HIPAA, PCI-DSS Standards, or the Alabama Data Breach Notification Law. Unauthorized access, transmission, collection or storage of confidential data is prohibited. Access to and storage of confidential information on personal (user owned) devices can pose substantial risk to the University (as well as the individual) and is prohibited.
4.2 Data Sources
For the purposes of this policy, data types are categorized as follows:
- Student Information;
- Student Financial Aid Information;
- Student Housing Information;
- Administrative Financial Information;
- Human Resources Information;
- Institutional Research Information.
Within these general categories, the different types of data are broken down into subsets; a University source is provided for each.
4.3 Student Information
4.3.1 Data Owner: University Registrar
The Office of the Registrar is the official source of information on individual students. For security purposes, student information is divided into the two categories of directory and academic.
4.3.2 Directory Information
University personnel may have access to directory information and may, without restriction, disseminate information for official use on and off campus. The Family Educational Rights and Privacy Act of 1974 and the University Attorney specify the following as directory information:
- Student’s name, address, telephone number, e-mail address, photograph, date and place of birth;
- Major, dates of enrollment, degree conferred and dates of conferral, any graduation distinction;
- Institutions attended prior to admission to the University of South Alabama;
- Participation in officially recognized activities and sports and weight and height of members of University athletic teams.
Directory information is available on Banner screens such as SPAIDEN, SPAPERS, SGASTDN, SHADEGR and others.
If a student does not wish any of the above information released to non-institutional persons or organizations, a Non-Disclosure of Directory Information must be completed in the Registrar’s office. Once the student has completed the form, the confidential flag is marked on Banner. A ‘Confidential’ comment will appear in the upper left-hand corner on all Banner screens. This request will remain in effect until the student notifies, in writing, the Registrar’s office to remove the flag.
4.3.3 Academic Information
Academic information, including grades, academic status, class schedules, etc., cannot be released to third parties without the student’s written permission. Academic information can be used by University of South Alabama employees having a legitimate educational interest in the student and who are acting within the limitations of their need to know may access student educational records without prior consent of the student. This includes personnel in academic offices as well as student support offices, such as Admissions, Student Accounting, Financial Aid, Registrar, etc.). This is true even if the student has been granted nondisclosure.
Academic information not available from Banner should be requested from the Office of the Registrar. Requests for information from students or from agencies or individuals outside the University should also be referred to the Office of the Registrar.
4.3.4 Summary Student Information
The Office of Institutional Research is the official source of aggregate or summary student information, such as enrollment or credit hour data intended for on- or off- campus dissemination. Requests for reports and analyses involving summary student data to be produced through Banner will be developed in conjunction with the Office of Institutional Research. This will ensure that reports and analyses are based upon the most accurate information and will enhance the consistency and integrity of information generated by colleges and departments.
4.4 Student Financial Aid Information
Data Owner: Director, Financial Aid Office
The Financial Aid Office is the official source of information on individual University students receiving financial assistance from various aid programs, including grants and scholarships and loans. All requests for this type of information should be addressed to the Director of Financial Aid.
Information on students receiving financial assistance through student loans is maintained by the Financial Aid Office and should be requested from the director of that department.
4.5 Student Housing Information
Data Owner: Director, Department of Housing
Any information pertaining to student housing on campus should be requested from the Director of the Department of Housing. Information on students receiving financial assistance through student loans is maintained by the Student Account’s Office and should be requested from the director of that department.
4.6 Payroll Information
Data Owner: Director, Payroll Office
The Payroll Office is the official source of financial information on individual University employees. All requests for this confidential financial information should be submitted to the Director of Payroll.
4.7 Human Resources Information
Data Owner: Assistant VP, Fin & Admin / Human Resources
Information concerning specific job positions (classifications, descriptions, etc.) at the University is maintained by the Human Resources department. All requests for employee information (excluding payroll information) should be sent to the Assistant VP, Human Resources.
4.8 Institutional Research Information
Data Owner: Exec Director, Research Compliance & Assurance
Institutional research information includes data on student enrollment, faculty reports, credit hour production, surveys (e.g., retention of students), government reports, etc. The official source for this type of information is the Office of Institutional Research, and all requests for such information should be submitted to the Director of that office.
4.9 Financial Accounting Information
Data Owner: Controller, Business Office
Revenue, expenditure and budget information is maintained for each account. Requests for access to information should be submitted to the Controller.
4.10 Classification Standards
Data classification indicates what the user is able to do with the data. Specific restrictions are outlined and enforced by individual departments responsible for the data. Specific levels of access clearance include the following:
- Read only;
- Maintenance (Update, Add, Delete).
Various user classifications will have access to data through one or a combination of these clearance levels. Each user ID is restricted by the forms that the user has been granted to access, i.e., their clearance level will provide them the ability to access a limited number of forms. If a user tries to access a form inappropriate to his/her clearance level, a security violation message will appear on the screen.
Data should not be downloaded to other storage medium without permission from the departmental owner of that data. Downloading of administrative data requires a separate authorization from the data owner. Individual users will be held responsible for any violation of this procedure.
4.11 Department Security
Each department will designate an “owner” for the data it maintains. Appropriate procedure for retrieval and dissemination of University data will be followed as outlined in the previous section, Data Retrieval and Dissemination.
Departments storing data subject to University regulations are responsible for ensuring that all such data is protected in accordance with institutional regulations. This applies to all such data from any source, whether electronically transferred from the administrative systems, or entered by the individual department from printed documents.
Specifically, departments must ensure that access to individual workstations or servers containing this information or access to output generated from departmental systems, is restricted to individuals authorized to access the data. Password security on individual stations or servers is not sufficient to ensure compliance; any such systems on which regulated data is stored must also be in secure, supervised areas, such as departmental or individual offices.
Backup tapes, disks or copies of data on printed or electronic media must be similarly protected. Under no circumstances shall confidential data or access to it be granted to personnel from other departments or non-University personnel without express written authorization from the appropriate administrative office. Any unauthorized storage and/or reproduction of confidential University data (e.g., grades, transcript files, etc.) is strictly prohibited.
In order to maintain the confidentiality and integrity of a department or academic entity's sensitive information, the following steps must be taken upon a change in device owner’s employee classification:
- A device may not be transferred to a new department unless the device has been serviced by the appropriate department technician and the hard drive shredded and replaced.
- If a device is changing ownership within a department, the appropriate department technician needs to be notified. If the device in question is being transferred between employees with the same data access, the hard disk will require a factory reset. If the device is being transferred between employees with different data access, the hard disk is to be shredded and replaced
Any deviation from the above must be approved in writing by the Director of the Office of Information Security.
For the purpose of Section 4.11, a device is defined as a USA-owned workstation, laptop, server, or any other computing device operated by an employee or anyone else acting on behalf of the University of South Alabama.
4.12 Physical Security
Deans and department/division heads are responsible for ensuring the physical security and responsible use of computers located in departments and offices under their authority. The following policy statements should be made available and/or posted prominently so that all personnel working with computers know the extent of their responsibility:
- Computers will be located in physically secure areas which can be locked when not in use;
- Access to computers will be limited to individuals engaged in official University business;
- Use of computers by student workers should be restricted to those cases in which student workers are absolutely necessary to supplement regular University staff members. Student workers should be thoroughly instructed in the proper and responsible use of computers;
- Each individual with access to administrative information is assigned his/her own account credentials (user id and password). The owner of the account is not to share this information with anyone else; the owner is responsible for any misuse of his/her sign-on credentials;
- Under no circumstances will account credentials be posted on or near computers;
- Computers which are “signed on” should never be left unattended;
- Requests for improvement of computer security, as well as suspected violations, should be addressed to the Director of Information Security, USA Office of Information Security.
Computers which are routinely used by individuals not cleared for access to such data are inappropriate locations for confidential data (e.g. computers in student labs or other public locations.) Placing confidential information on systems of this nature constitutes a clear violation of University regulations.
Because of the possibility of theft and discovery of data, neither portable computers (notebooks, laptops, etc.) nor portable storage devices, including USB keys and portable disks, should be used to store confidential or regulated data, unless such data is encrypted.
4.13 Computer Security
Confidential data should only be accessed from non-public, University owned computers assigned to employees. Computers should have University issued Anti-Virus software installed and Windows Update active and patches applied on a regular basis.
In some circumstances, University provided PII searching software should be installed on the system (see Data Security below). If accessing University Information systems, software should not be configured to use a stored password or otherwise bypass entering a password unless your computer is controlled by USADIR/Active Directory and requires a logon before use. Users should log off the computer when not actively using it (for example, when leaving the office for a meeting or lunch). It is recommended that screen lockout be configured to automatically lock the computer after it is inactive for more than 10 minutes.
4.14 Data Security
Any individual who accesses University data, through a computer or a report, is responsible for the confidentiality of that data. Likewise, any individual who stores University data on a personal computer will be held accountable for the confidentiality of that information.
Under no circumstances should confidential data be stored on a cloud service such as Dropbox, OneDrive, Box, etc. The University has a Business Associate Agreement with Google (G Suite) and Google Drive may be a suitable storage location for FERPA and HIPAA data. However, the storage of confidential data in Google is not recommended. For more information, see “G Suite HIPAA Business Associate Amendment” and “G Suite for Education Privacy Notice”.
Electronic files containing Social Security Numbers shall not be stored on desktops, laptops, departmental servers, cloud services, portable media devices, or stored in email without explicit written permission from the Director of Information Security. The files containing SSNs approved for local storage must be encrypted; all unapproved files must be deleted (Please refer to the Social Security Number Protection Policy). For departments that must have access to SSNs, as part of essential business purposes, the University provides PII searching software that is installed on employee computers which assists with removing PII. For more information, please contact the Director of Information Security.
4.15 Web Servers and Departmental Servers
Information subject to University or confidentiality regulation should not be placed on the main University web server without prior written approval from the appropriate administrative offices as well as the Manager of Web Services. Such data should, in general, be placed on Web or other departmental servers only if absolutely essential to University business and only if appropriate safeguards, including appropriate file permissions, access controls and security patch procedures are in place.
4.16 Electronic Mail System Security
Electronic mail poses additional risks in the handling of confidential data. Data may quite readily be transmitted to unintended recipients through misaddressing or similar error. In addition, the routine maintenance of mail systems may require or inadvertently lead to viewing of some pieces of mail by mail systems administrators. The Computer Services Center will respect the privacy of all such mail and will not reveal the contents of such mail to any other parties. However, if activities in violation of law or University regulations are discovered through this procedure, the CSC may report such information to appropriate authorities.
Departments are advised that information subject to confidentiality regulations should not be transmitted via electronic mail without prior written approval from the appropriate administrative offices.
Each set of University data will be classified as having an “owner”. This owner will be represented by a specific individual within the University department responsible for that data. Any time a department or individual wishes to gain access to another department’s data, they must follow the procedure below:
- If you are requesting access to student information, fill out the appropriate Banner Security access forms that can be found at the following link in section 7.1 of the “Related Documents” section and submit it to the Registrar’s Office;
- If you are requesting access to financial information, fill out the appropriate Banner Security access form that can be found at the following link in section 7.2 of the “Related Documents” and submit it to the Business Office;
- Once your request for data access has been approved by the owner/department responsible, you will be asked to sign a “Statement of Accountability” form in order to receive a sign-on code and password from the Computer Center. (If you are gaining access to the Student Records system, you will be asked to sign a “Statement of Confidentiality/Accountability” for the Registrar’s Office, as well.)
Each department is responsible for enforcing this data security policy. University policy states that confidential information is to be used only when necessary for University, college, or departmental business. Refusal to adhere to this policy is a clear violation of the Family Educational Rights and Privacy Act of 1974. Offenders will be subject to disciplinary action and possible referral of the violation to the proper authorities.
7. Related Documents
7.4 Social Security Number Protection (policy)
7.5 Confidential Data Protection (policy)