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Objective

The objective of this policy is to insure that the appropriate safeguards and controls are in place to protect the confidentiality, integrity, and availability of the University’s information assets in direct support of the University's strategic mission and goals.

Background Information

Information is integral to the operations of the University at Albany. The core services of teaching, learning, and research cannot be realized without a robust, reliable, and secure information technology infrastructure. Business operations and academic inquiry are dependent on the availability and integrity of information (both in transit and at rest).

In order to preserve the trust and confidence of its faculty, students, alumni, and parents, and enable the work of professional, support, and research staff, the University must effectively manage and safeguard the information vital to its operations and the activities of the campus community.

Policy Statement

It is the policy of the University to comply with legal and regulatory requirements governing the collection, retention, dissemination, protection, and destruction of information. This requires the University to maintain a vigorous and comprehensive Information Security Program designed to satisfy its statutory obligations, enable and assure core services, and fully support academic inquiry.

The Information Security program will include the administrative, technical and physical safeguards appropriate to the size and complexity of the University and the sensitivity of its information. The program will be based on established risk management practices and applied to a set of Information Security Domains. Each domain will establish protocols that provide a direction and framework for related standards, procedures and other companion documents establishing the compliance requirements for each set of controls.

Each member of the University community shares a measure of responsibility for the implementation and effectiveness of this program.

Scope

This is a University-wide policy and includes those entities and affiliates that rely on the University’s IT infrastructure or data for their operations.

Roles and Responsibilities

Oversight

The Office of the Chief Information Officer (OCIO) is primarily responsible for assuring an effective Information Security program.

Responsibility for developing, deploying, and managing the Information Security Program lies with the Information Security Officer (ISO) who will work in conjunction with the Internal Control Officer, the Office of University Counsel, and Internal Audit.

Governance

The ISO will work with the relevant stakeholders to formulate specific standards, procedures and guidelines in support of various risk management strategies. The OCIO may further establish advisory or working groups to assist in implementing this policy.

Operations

Campus information technology service providers are primarily responsible for the implementation of operational controls. Members of the University community at-large are responsible for implementing and adhering to relevant standards, procedures, and guidelines.

Compliance

The OCIO is primarily responsible for enforcement. This responsibility may be delegated.

Vice Presidents are responsible for the compliance of their divisions with this policy, related policies, and their applicable standards, guidelines and procedures.

Compliance is determined via periodic audits, scans, and reviews and is measured against this policy and all published, related documents. The frequency and nature of these reviews are based on the risk and criticality of the resource, major changes, or new State or Federal regulations.

Instances of non-compliance will be addressed on a case-by-case basis. All cases will be documented and written notifications sent to responsible parties. These notices will include recommendations for corrective action. A reasonable period of time, depending on the level of exposure and criticality of the resource, will be stipulated for implementing corrective action. Follow up review(s) will determine the subsequent degree of compliance. Failure to meet compliance requirements may result in sanctions.

Nothing in this section will be construed as an impediment to responding to a security breach incident.

Review

This policy will be reviewed no less than once every five years. Standards, guidelines and procedures will be reviewed no less than every two years to determine the topicality of the campus’s top level security domains.

Related Documents

SUNY Information Security Guidelines, Part 1: Campus Programs & Preserving Confidentiality, Document #6608
Federal Educational Rights and Privacy Act
Health Insurance Portability and Accountability Act
Gramm Leach Bliley Act
NYS Information Security Breach & Notification Law
NYS Business Law and Technology Law
NYS Governmental Accountability, Audit & Internal Control Act
NYS Information Security Policy P03-003
Other State and Federal regulations governing the acquisition, retention, and dissemination of protected data
SUNY system-wide information security policies and requirements
SUNY Policies of the Board of Trustees
Community Rights & Responsibilities
Other University IT and Information policies

Updated: February 2013