Unused Teams and Groups can accumulate and become a burden to resources over time. To prevent this from happening, Fairleigh Dickinson University has implemented an expiration policy for Teams and Groups. This article will explain the expiration policy and provide you with information regarding renewal.

What is the FDU expiration policy for Teams and Groups

1. Any Team or Group inactive for 365 days or more will expire
2. Team and Group owners will be notified 30 days, 15 days, and 1 day before the team’s expiration date. If the Team or Group is not renewed before expiration, it will be deleted.

3. The expiration period of 365 days begins at the creation of the Team or Group, or the date it was last renewed

How to renew a Team or Group

There are two methods to prevent the Microsoft 365 group from being deleted.

1. The group owner can manually renew the group by clicking the button in the warning message

2. A member of the group can perform a monitored user activity:
   • SharePoint: view, edit, download, move, share, or upload files (viewing a SharePoint page does not count as an action for automatic renewal)
   • Outlook: join or edit group, read or write group messages from the group, and like a message (Outlook on the web)
   • Teams: visit a teams channel
   • Yammer: view a post within a Yammer community or an interactive email in Outlook
   • Forms: view, create, or edit forms, or submit a response to a form
3. When the team owner receives the expiration notification, go to the Team’s group “Manage team” option and click on Renew now as shown below

Whenever the Microsoft 365 group is renewed by any of the methods mentioned, the group’s lifetime will be extended for another period of 365 days.

What are Microsoft 365 Groups

Microsoft 365 groups are created from a variety of tools including Outlook, SharePoint, Planner, and Teams. Microsoft 365 groups allow you to choose a set of people to collaborate with. You can use Microsoft 365 groups to communicate with others, share files, and apply permissions to shared resources.

Who are Group Owners

When a Microsoft 365 group is created, the person creating the group is designated as the owner. After adding members to the group, the primary owner can also promote other members to owner status. We suggest that when practical, Microsoft 365 groups have at least 2 owners. This can be important as only the group owner will receive the warning messages. In some cases, the group owner may have removed themselves from the group or left the university entirely. If you find yourself a member of a Microsoft 365 group without an owner, please contact support by creating a SAMI Support Request.

Groups without Owners

Ownerless or orphaned Groups may be deleted by USAN. USAN will notify Group members prior to deletion, but if they receive no response, the Group will be deleted. If USAN deletes a Group, all the records associated with the Group’s shared space will be deleted as well

Automatic Renewal

Groups that are actively in use are renewed automatically setting the days to zero. Any of the following actions will auto-renew a group:

• SharePoint – view, edit, download, move, share, or upload files. (Viewing a SharePoint page does not count as an action for automatic renewal.)
• Outlook – join the group, read or write group messages from the group, and like a message (Outlook on the web).
• Teams – visiting the Teams channel.

Recover Deleted Teams or Groups

When the 365 days limit hits, the Microsoft 365 group will expire and be put into a “Soft-deleted” state. Which means it can still be recovered for up to 30 days. To have the Microsoft 365 group recovered please contact support by creating a SAMI Support Request and include the Microsoft 365 group or Team name to be recovered.

Where to Get Help

For assistance with Microsoft 365 groups, please contact support by creating a SAMI Support Request. We can answer questions about the expiration policy, renewing groups, and updating group owners.

Spam Quarantined Email

Microsoft 365 email has filters to protect users from spam and malicious emails like phishing scams.

Messages caught by the filters are placed in quarantine for Fairleigh Dickinson University and its users’ protection. Users will receive a Spam Notification message once a day, notifying them of any messages placed in quarantine. Any legitimate mail caught by mistake can be released directly from this message or from the quarantine portal.

Handling Quarantined Email

Legitimate messages placed in quarantine may be released into your inbox in one of two ways:

1. From the daily spam notification email message

If you receive mail that has been placed in quarantine, you’ll receive an email message from quarantine@messaging.microsoft.com. The message will look like the one below:

The following options will be available to you by clicking the respective links in the email notification or you can choose to do nothing.

• Review Message – go to the Microsoft 365 Security & Compliance Center to review it
• Release – the message is removed from quarantine and placed in your inbox
• Block Sender – add the sender to the Blocked Senders list in your mailbox

2. From the Microsoft 365 Security & Compliance Center

Quarantined email can also be handled in the Microsoft 365 Security & Compliance Center.

1. Go to Microsoft 365 Security & Compliance Center >
   
   • A list of your emails in quarantine will be displayed
     
2. Click on any message to select it, then choose from the options given:
   
   • Release message
   • Preview message
   • View message header
   • Block Sender

For more details, use this link:

Eligible FDU employees may receive reimbursement for business related expenses incurred on personally owned mobile communications devices, or, be issued a FDU owned and managed mobile communications device for business and reasonable personal use.

To view the policy in full, please visit:

As a member of our community, your FDU NetID is your passport to accessing many of Fairleigh Dickinson University’s IT services. Most important is your student, employee, or alumni FDU Email account. When using FDU Email, you are an ambassador for our institution and our expectation is that you will conduct yourself in an efficient, effective, ethical and lawful manner. Please review our Policy for Acceptable Use of Email to ensure that you are adhering to all security and decorum requirements.

Effective Date: 01/01/2018

1.0 Introduction

The purpose of this policy is to ensure the proper use of e-mail by all those assigned a Fairleigh Dickinson University (FDU) e-mail account. This policy applies to any e-mail system that FDU has or may install in the future. It also applies to employee use of personal e-mail accounts via browsers, as directed below. All users of FDU e-mail systems have the responsibility to use their e-mail in an efficient, effective, ethical and lawful manner. E-mail users must follow the same code of conduct expected in any other form of written or face-to-face business communication. FDU may supplement or modify this policy for specific employees in certain roles. This policy complements similar FDU policies such as the Acceptable Use Policy and the Written Information Security Program (WISP). Please read and follow those policies as well.

The University subscribes to the 1940 Statement of Principles on Academic Freedom and Tenure and the 1940 and 1970 Interpretive Comments issued thereon, formulated jointly by the Association of American Colleges and the American Association of University Professors. Nothing in this policy is intended to supersede those statements and principles.

2.0 Ownership of Email Data

The University owns all University email accounts in the fdu.edu domain, or any subsequent domains it may create (University Email Accounts). Subject to underlying copyright and other intellectual property rights under applicable laws and University policies , the University also owns data transmitted or stored using the University Email Accounts.

3.0 Employee Responsibilities

FDU only supports the installation and usage of approved e-mail clients.

Usernames will be assigned as part of the University’s e-mail registration process and reflect internally mandated e-mail naming conventions.

3.1 Acceptable Uses

• Communicating in a professional manner with other FDU associates about work-related matters.
• Communicating in a professional manner with parties outside FDU for business purposes.
• Personal communications that are brief and do not interfere with work responsibilities.
• Users are allowed to access personal e-mail accounts on a limited basis, without disrupting business responsibilities. Access can be gained only by using a browser. Use of e-mail-specific protocols, such as POP3 and IMAP4, is prohibited, since they require specific firewall ports to be open.
• Electronic messages are frequently inadequate in conveying mood and context. Users should carefully consider how the recipient might interpret a message before composing or sending the message.

3.2 Unacceptable Uses

• Creating and exchanging messages that can be interpreted as harassing, obscene, racist, sexist, ageist, pornographic or threatening, as defined by University policies.
• Creating and exchanging information that is in violation of copyright or any other law. FDU is not responsible for an associate’s use of e-mail that breaks laws.
• Personal communication that interferes with work responsibilities.
• Opening file attachments from an unknown or untrustworthy source, or with a suspicious or unexpected subject line.
• Sending unprotected healthcare data and personally identifiable consumer data or other confidential information to unauthorized people or in violation of FDU’s Acceptable Use Policy, or the Written Information Security Program (WISP). , Health Insurance Portability and Accountability Act and/or Gramm-Leach-Bliley Act regulations. Exceptions may be authorized by the University Chief Information Security Officer working with the employee’s supervisor. Communications that strain FDU’s network or other systems unduly, such as sending large files to large distribution lists.
• Communications to distribution lists of only marginal interest to members, and replying to the entire distribution list when a personal reply is effective.
• Communications with non-specific subject lines, inarticulate language, and without clear purpose.
• Auto-forwarding e-mail messages from your University e-mail account.
• Using any e-mail system, other than FDU’s e-mail system, for FDU-related communications.
• Circulating chain letters and/or commercial offerings.
• Circulating unprotected healthcare data and personally identifiable consumer data that would violate U.S. Federal HIPAA and GLB regulations. Exceptions may be authorized by the employee’s supervisor and in conjunction with use of a University-approved e-mail encryption service.
• Altering or forging the “From” line or any other attribution of origin contained in electronic mail or postings.
• Using any of the University systems for sending what is commonly referred to as “SPAM” mail (unsolicited bulk email)

4.0 Privacy Guidelines

The University typically does not review the content of electronic messages or other data, files, or records generated, stored, or maintained on its electronic information resources; however, it retains the right to inspect, review, or retain the content of such messages, data, files, and records at any time without prior notification. Any such action will be taken for reasons the University, within its discretion, deems to be legitimate. These legitimate reasons may include, but are not limited to,

• responding to lawful subpoenas or court orders;
• investigating misconduct (including research misconduct);
• determining compliance with University policies and the law; and
• locating electronic messages, data, files, or other records related to these purposes.

FDU maintains the right to monitor and review e-mail activity to ensure compliance with this policy, as well as to fulfill FDU’s responsibilities under the laws and regulations of the jurisdictions in which it operates. Users should have no expectation of privacy.

• Except as otherwise stipulated in this policy, on termination or separation from FDU, FDU will immediately deny access to e-mail, including the ability to download, forward, print or retrieve any message stored in the system, regardless of sender or recipient.
• Except as otherwise stipulated in this policy, employees who leave FDU will have their mailbox deleted within six months of their termination date. The employee’s manager may request that access be given to another employee who may remove any needed information within the same six month time frame.
• FDU reserves the right to intercept, monitor, review and/or disclose any and all messages composed, sent or received on the University e-mail system. Intercepting, monitoring and reviewing of messages may be performed with the assistance of content filtering software, or by designated FDU employees and/or designated external entities. Employees designated to review messages may include, but are not limited to, an employee’s supervisor or manager and/or representatives from the HR, legal or compliance departments.
• FDU reserves the right to alter, modify, re-route or block the delivery of messages as appropriate. This includes but is not limited to:
  • Rejecting, quarantining or removing attachments and/or malicious code from messages that may pose a threat to FDU resources.
  • Rejecting or quarantining messages with suspicious content.
  • Rejecting or quarantining messages containing offensive language or topics.
  • Re-routing messages with suspicious content to designated FDU employees for manual review.
  • Appending legal disclaimers to messages.
• Electronic messages are legally discoverable and permissible as evidence in a court of law.
• Users of the University’s computing and electronic communications resources must understand that electronic messages, data, files, and other records generated, stored, or maintained on University electronic information resources may be electronically accessed, reconstructed, or retrieved by the University even after they have been deleted.

5.0 Security

As with any other type of software that runs over a network, e-mail users have the responsibility to follow sound security practices.

• Users should not use the e-mail system to transfer sensitive data, except in accordance with FDU data protection policies. Refer to the Written Information Security Program (WISP). Sensitive data passed via e-mail over the Internet could be read by parties other than the intended recipients, particularly if it is clear text. Malicious third parties could potentially intercept and manipulate e-mail traffic.
• In an effort to combat propagation of e-mail viruses, certain attachment types may be stripped at the University e-mail gateway. Recipients will be notified via e-mail when this occurs. Should this create a business hardship, users should contact the University Technical Assistance Center (UTAC).
• Attachments can contain viruses and other malware. User should only open attachments from known and trusted correspondents. Suspicious attachments should be reported to the University Technical Assistance Center (UTAC).
• Spam is automatically filtered at the University gateway in a highly efficient manner. Errors, whereby legitimate e-mail can be filtered as spam, while rare, can occur. If business-related mail messages are not delivered, users should check their local spam folder or the daily spam digest. If the message is not there, users should contact University Technical Assistance Center (UTAC).
• Users will not be asked by OIRT or any other FDU group by e-mail for personal information such as usernames or passwords. Any such requests should not be responded to and should be referred to the University Technical Assistance Center (UTAC). Such approaches – known as phishing – are fraudulent approaches carried out for the purpose of unlawful exploitation.

6.0 Operational Guidelines

FDU employs certain practices and procedures in order to maintain the health and efficiency of electronic messaging resources, to achieve FDU objectives and/or to meet various regulations. These practices and procedures are subject to change, as appropriate or required under the circumstances.

• For ongoing operations, audits, legal actions, or any other known purpose, FDU saves a copy of every e-mail message and attachment(s) to a secure location, where it can be protected and stored for three years. Recovery of messages from this store is prohibited for all but legal reasons.
• To deliver mail in a timely and efficient manner, message size must be less than 25MB. Messages larger than 25MB will be automatically blocked and users will be notified of non-delivery. Should this create a business hardship, users should contact the University Technical Assistance Center (UTAC).

Access to the content of electronic mail, data, files, or other records generated, stored, or maintained by any user may be requested from the University’s Associate Vice President of Technology Infrastructure for the reasons set forth below and shall be authorized as follows:

1. by the Associate Vice President of Human Resources for all University employees;
2. by either Dean of Students for students; or
3. by the General Counsel for the purposes of complying with legal process and requirements or to preserve user electronic information for possible subsequent access in accordance with this policy.

In all cases, the Office of the General Counsel must be consulted prior to making a decision on whether to grant access. In the case of a time-critical matter, if the authorizing official is unavailable for a timely response, the General Counsel may authorize access.

All full-time faculty who retire from the University may keep their email address for life if they request to do so.

All full-time faculty who leave the University for reasons other than termination for cause, may request email forwarding for up to six months.

7.0 Governance and Enforcement

This policy was created with input from the University’s Data Security Incidence Response Team (DSIRT). At the request of the University’s Chief Information Security Officer (CISO), the DSIRT will review this policy annually to ensure that FDU is in compliance with internal or external requirements. FDU faces liability if users violate the terms of this policy. Therefore, willful or repeated violations of this Acceptable Use Policy for E-mail can result in informal or formal warnings, the loss of e-mail privileges, and other sanctions including termination. Any such discipline shall be in accordance with processes and procedures of Human Resources and subject to any protections afforded under the University’s agreement with “Office & Professional Employees International Union”, the “Faculty Handbook”, and similar documents. Third parties who violate this Policy may have their relationship with the University terminated and their access to campus restricted.

For assistance with this policy, please contact the University’s Chief Information Security Officer (CISO).

Exceptions to this policy may be authorized by the University Chief Information Security Officer working with the employee’s supervisor.

Policy violations should be reported immediately to the University’s Associate Vice President of Technology Infrastructure

The University reserves the right to suspend an e-mail account while investigating a complaint or troubleshooting a system or network problem.

This document will be reviewed semi-annually and is available both electronically and in printed form at each of the Campus Computing Centers.

It is the user’s responsibility to remain informed about the contents of this document.

Other Related and Applicable Policies

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1. Purpose: This Policy sets the standards for developing, implementing, and maintaining reasonable administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of information covered by applicable provisions of the Gramm-Leach-Bliley Act (“GLBA”) and associated regulations. In particular, this document describes various measures being taken by FDU to (i) ensure the security and confidentiality of covered information, (ii) protect against any anticipated threats or hazards to the security of these records, and (iii) protect against the unauthorized access or use of such records or information in ways that could result in substantial harm or inconvenience (collectively, the “Program”). The practices described in this Policy are in addition to any institutional policies and procedures that may be required pursuant to other federal and state laws and regulations, including, without limitation, the Family Educational Rights and Privacy Act (“FERPA”).

2. Scope of Program: The Program applies to any record containing “nonpublic personal information” about a student or other individual who has a continuing relationship with the University, whether the record is in paper, electronic, or other form, and which is handled or maintained by or on behalf of the University (“covered information”).(1) This includes any information that a student or other individual provides to FDU in connection with financial aid and tuition/fee collection efforts.

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(1) Nonpublic personal information means: (i) personally identifiable financial information; and (ii) any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available. “Personally identifiable financial information” means any information that a consumer provides to FDU to obtain a financial product or service, any information about a consumer resulting from a transaction involving a financial product or service between FDU and that consumer, or information that FDU otherwise obtains about a consumer in connection with the provision of a financial product or service to that consumer. A “consumer” is an individual, including a student, who obtains or has obtained a financial product or service from FDU that is to be used primarily for personal, family, or household purposes, or that individual’s legal representative. Examples include information an individual provides to FDU on an application for financial aid, account balance information and payment history, the fact that a student has received financial aid from FDU, and any information that FDU collects through an internet “cookie” in connection with a financial product or service.

3. Roles and Responsibilities: Compliance and cooperation with this Policy is the responsibility of every employee at all levels within FDU. FDU’s Vice President and Chief Information Officer (CIO), assisted by the Chief Information Security Officer (the “CISO”), has the overall responsibility for coordinating information security pursuant to this Policy. The CIO or CISO may designate other representatives of FDU to help oversee and coordinate particular elements of the Program. The team will work closely with other members of the Office of Information Resources and Technology (OIRT), the Data Security & Incident Response Team (“DSIRT”), the University Risk Manager, the Vice President for Human Resources, and the General Counsel, as well as relevant academic and administrative units throughout the University to implement the Program.

4. Risk Assessment: The CIO and CISO will help the relevant offices of FDU to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of covered information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of the information; and to assess the sufficiency of the safeguards in place to controls these risks. This effort will be embodied in a risk assessment document.
   
   The risk assessment is a written document that includes:
   
   (i) Criteria for the evaluation and categorization of identified security risks or threats that FDU faces;
   
   (ii) Criteria for the assessment of the confidentiality, integrity, and availability of FDU’s information systems and covered information, including the adequacy of the existing controls in the context of the identified risks or threats that FDU faces; and
   
   (iii) Requirements describing how identified risks will be mitigated or accepted based on the risk assessment and how the information security program will address the risks.

5. Access Controls: The Program includes implementing and periodically reviewing access controls, including technical and, as appropriate, physical controls to:
   
   (i) Authenticate and permit access only to authorized users to protect against the unauthorized acquisition of covered information; and
   
   (ii) Limit authorized users’ access only to covered information that they need to perform their duties and functions, or, in the case of third parties, to access their own information.

The Program is designed to identify and help manage safeguards for the data, personnel, devices, systems, and facilities that enable FDU to achieve its mission – efforts are prioritized in accordance with our objectives and risk strategy.

FDU has adopted authentication and access controls as needed to implement the “principle of least privilege” around accessing covered data, meaning that no user should have access greater than is necessary for legitimate FDU purposes Data owners within each applicable University unit approve and periodically review access. This includes a periodic review by the Office of Enrollment Services of all users who have access to Enrollment Services security tracks in the Colleague System and a periodic review by other administrative departments that maintain students’ financial aid information regarding user access to the information.

These efforts also include employee training regarding these controls. The OIRT will coordinate with representatives in FDU’s Office of Finance, Office of Financial Aid, Enrollment Services and other offices to evaluate on a regular basis the effectiveness of the University’s training, procedures, and practices relating to access to and use of student records, including financial aid information as well as financial information. This evaluation will include assessing the effectiveness of the University’s current policies and procedures in this area. All employees are required to train in FDU’s Written Information Security Program (WISP) (training.fdu.edu), which program is incorporated by reference into this Policy.

6. Monitoring Unauthorized Users and Use: FDU has implemented policies, procedures, and controls designed to monitor and log the activity of authorized users and detect unauthorized access or use of, tampering with, covered information. Various specific measures are identified in Appendix 1.
   
   These measures will include assessing the University’s current policies and procedures relating to FDU’s Acceptable Use Policy for Computer Usage, Confidentiality Agreement and Security Policy, FDU Procedure on Handling Data on Separating Employees, Password Policy, Policy for Acceptable Use of Email, Software Compliance & Distribution Policy, and Written Information Security Program. The CISO will also coordinate with the CIO and the OIRT to 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.

7. Monitoring the Effectiveness of Safeguards: FDU periodically conducts penetration tests and vulnerability assessments on its network and key information systems. These measures are designed to test and monitor the effectiveness of the safeguards’ key controls, systems, and procedures, including those to detect actual and attempted attacks on, or intrusions into, FDU’s information systems.
   
   For those systems where continuous monitoring (or other methods to detect, on an ongoing basis, changes in information systems that may create vulnerabilities), is not practical, FDU will conduct:
   
   (i) Annual penetration testing on FDU’s information systems identified by OIRT based on relevant identified risks under the risk assessment; and
   
   (ii) Vulnerability assessments of FDU’s information systems, including systemic scans or reviews of information systems designed to identify publicly known security vulnerabilities in FDU’s information systems based on the risk assessment, at least every six months; and whenever there are material changes to FDU’s operations or business arrangements; and whenever there are circumstances that OIRT knows (or has reason to know) may have a material impact on FDU’s information security program.

8. Detecting, Preventing and Responding to Attacks: The OIRT and University Risk Manager will on a regular basis 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. The FDU Data Security Incident & Response Team implements all aspects of, oversees other Departments’ adherence to, and documents all incident response activities. Upon determination by the CISO and General Counsel that a Security Incident triggers breach notification laws, the University will report the breach to relevant federal or state regulatory authorities by their designated methods; and, where applicable, the U.S. Department of Education, including details about date of breach (suspected or known); impact of breach (e.g. number of records); method of breach (e.g. hack, accidental disclosure); information security program point of contact – email and phone details; remediation status (e.g. complete, in process); and next steps (as needed).
   
   These measures will be documented in a comprehensive incident response plan that addresses:
   
   (i) The goals of the incident response plan;
   
   (ii) The internal processes for responding to a security event;
   
   (iii) The definition of clear roles, responsibilities, and levels of decision-making authority;
   
   (iv) External and internal communications and information sharing;
   
   (v) Identification of requirements for the remediation of any identified weaknesses in information systems and associated controls;
   
   (vi) Documentation and reporting regarding security events and related incident response activities; and
   
   (vii) The evaluation and revision as necessary of the incident response plan following a security event.

9. Overseeing In-House Developed Applications and External Service Providers: The OIRT leadership working in collaboration with the CISO will help ensure that software applications and solutions developed in-house by FDU, including modifications to third-party programs, meet the safeguard standards of this Policy. The CIO, CISO and other appropriate OIRT leaders will also coordinate with FDU’s contract review teams to raise awareness of, and to institute methods for, selecting and retaining only those service providers that can maintain appropriate safeguards for nonpublic financial information of students and other third parties to which they will have access. In addition, the CIO and CISO will work with the General Counsel and the University Risk Manager to develop and incorporate standard, contractual protections applicable to third-party service providers, which will require the providers to implement and maintain appropriate safeguards.
   
   Utilizing a variety of automated risk assessment tools such as Bitsight, OIRT periodically assesses FDU’s service providers on the risk they present and the continued adequacy of their safeguards.

10. Encryption: FDU adopts methods to protect by encryption covered information held or transmitted by the University by encrypting both in transit over external networks and at rest. To the extent that encryption of covered information, either in transit over external networks or at rest, is infeasible, FDU secures the covered information using effective alternative compensating controls reviewed and approved by the CISO.

11. Multifactor authentication: FDU has implemented multi-factor authentication for any individual accessing the University’s information systems, except where the CISO has approved in writing the use of reasonably equivalent or more secure access controls.
    
    Multi-factor authentication is defined as authentication through verification of at least two of the following types of authentication factors:
    
    (1) Knowledge factors, such as a password;
    
    (2) Possession factors, such as a token; or
    
    (3) Inherence factors, such as biometric characteristics.

12. Data Retention and Disposal Controls: FDU has in place procedures for the secure disposal of covered information in any format, consistent with the University’s operations and other legitimate business purposes, except where required to be retained by law or regulation, or where targeted disposal is not reasonably feasible due to the manner in which the information is maintained. Where information is not needed to be retained, the University will take reasonable measures to include processes for disposal of covered information no later than two years after the last date the information is used for legitimate University purposes. The Program includes periodic review of our data retention policy to minimize the unnecessary retention of data.

13. Adjustments to Program: Risk assessment activities will be periodically performed to reexamine the reasonably foreseeable internal and external 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, and to reassess the sufficiency of any safeguards in place to control these risks. The CISO is responsible for evaluating and recommending adjustments to the program based on the undertaken risk identification and assessment activities, as well as any material changes to FDU’s operations or other circumstances that may have a material impact on the Program.

14. Reports to the Board: The Vice President of OIRT will submit written reports to the Board of Trustees at least once each calendar year. The report will include the following information:
    
    (1) The overall status of the Program and FDU’s compliance with the safeguard requirements under the GLBA;
    
    (2) Material matters related to the Program, addressing issues such as risk assessment, risk management and control decisions, service provider arrangements, results of testing, security events or violations and management’s responses thereto, and recommendations for changes in the information security program.

The CIO may approve deviations to the processes set forth in this Policy to meet changing conditions at the University, so long as such deviations are designed to achieve the safeguard goals set forth in this Policy and do not violate the GLBA and other applicable laws.

Appendix 1
Certain Additional Specific Safeguards

Periodically (generally at least once each year), leaders from applicable University departments and units are surveyed regarding their processes for safeguarding covered information, using a standard template. Results are compiled and conveyed to the CIO for review and follow-up, including adopting and incorporating results in the University-wide Risk Assessment.

The CIO will determine which departments and units should receive the assessment survey, based on their handling of covered information. Currently, the units are: OIRT, Office of Enrollment Services, Credits and Collections, Admissions, International Admissions, Financial Aid, Veteran Services, Accounts Payable, Management Information Systems, Conference & Summer Programs, School of Pharmacy, and the Controller’s Office.

The standard assessment template is as follows.

1. Designate an employee or employees to coordinate the unit’s information security program.
   
2. Identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including:

• Unauthorized disclosure of sensitive information by employees through intentional or unintentional methods.
  
• Unauthorized access, disclosure, misuse, alteration or destruction of information on hosts.
  
• Detection and prevention of attacks on the systems.
  
• Unsecured transmission of data.
  
• Physical security of computer systems, network equipment, backups and paper materials.
  
• Managing data integrity and system failures.

3. Design and implement information safeguards to control the risks you identify through risk assessment, and regularly test or otherwise monitor the effectiveness of the safeguards’ key controls, systems, and procedures.

1. Unauthorized disclosure of sensitive information by employees through intentional or unintentional methods:
   
2. Unauthorized access, disclosure, misuse, alteration or destruction of information on hosts:
   
3. Detection and prevention of attacks on the systems:
   
4. Unsecured transmission of data:
   
5. Physical security of computer systems, network equipment, backups and paper materials:
   
6. Managing data integrity and system failures:

4. Oversee service providers, by: (1) Taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards for the customer information at issue; and (2) Requiring FDU’s service providers by contract to implement and maintain such safeguards.

5. Evaluate and adjust FDU’s information security program in light of the results of the testing and monitoring required by this Policy; any material changes to FDU’s operations or business arrangements; or any other circumstances that are known or have reason to be known as having a material impact on FDU’s information security program.

The following is an example of a completed assessment survey, from OIRT:

Gramm Leach Bliley Security Program
Office of Information Resources Technology
Standards for Safeguarding Customer Information

(a) Designate an employee or employees to assist the CIO in the coordination of the Program.

In addition to the CISO, the Director of Systems and the Director of Networking are the designated employees for the Office of Information Resources Technology

(b) Identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including:

• Unauthorized disclosure of sensitive information by employees through intentional or unintentional methods.
• Unauthorized access, disclosure, misuse, alteration or destruction of information on hosts.
• Detection and prevention of attacks on the systems.
• Unsecured transmission of data.
• Physical security of computer systems, network equipment, backups and paper materials.
• Managing data integrity and system failures.

(c) Design and implement information safeguards to control the risks you identify through risk assessment, and regularly test or otherwise monitor the effectiveness of the safeguards’ key controls, systems, and procedures.

1. Unauthorized disclosure of sensitive information by employees through intentional or unintentional methods:

• Employees go through mandatory Written Information Security Program (WISP) Training
• Prior to any IT requests, User Information Is checked against WISP to ensure they are current with training
• Employees are provided training and are closely observed by managers before being given access to sensitive information. Training includes password policy and management, physical security of cabinets, storage, and equipment rooms, and recognizing fraudulent attempts to obtain sensitive information.
  • Policy, social engineering, keystrokes loggers, etc.
• All employees must sign and accept the University’s “Acceptable Use Policy” and the “Confidentiality Agreement” if applicable.
• Requests for sensitive information are directed to individuals with proper training and authority to review the request.
• Potential employees are subjected to a background check before being hired by the University.
• Updated IT Informational website that includes documentation of all policies and procedures specific to securing data.
• Use of Data Loss Prevention tool to proactively monitor and correct non-compliance issues
• Access to information is granted only to the extent required for the employee to perform their job functions.

2) Unauthorized access, disclosure, misuse, alteration or destruction of information on hosts:

• Passwords are required for access to any system with sensitive information.
• Strong password policies are in place where possible.
• Multi-factor authentication to access sensitive systems for all faculty, adjuncts, staff and students.
• Multi-factor authentication for all admin accounts.
• Auditing systems (e.g. Change Management Process, Netwrix, Microsoft ATP) are used to track and report on changes to critical files.
• Notifications of employee terminations are received prior to or on date of termination. Immediate notification is received when circumstances warrant instant suspension of access to systems.

3) Detection and prevention of attacks on the systems:

• Auditing systems (e.g., Netwrix) are used to detect attempts to breach systems or alter system configurations.
• System logs are reviewed daily for evidence of attacks.
• Policies are in place to regularly apply patches to systems.
• A firewall is in place for perimeter protection.
• Obsolete systems are being replaced by newer systems that are better supported by hardware and software vendors. Most systems include host-based firewalls.
• The wired portion of the university network is entirely switched to minimize the possibility of packet sniffing and other similar attacks.
• WPA2 Enterprise is deployed and available for wireless accessible locations.
• Endpoint protection software is in place, which automatically updates servers & clients.

4) Unsecured transmission of data:

• Connections to all systems are using modern cryptographic techniques.
• University standard practice is to use HTTPS for web services; all publicly accessible web traffic is proxied through load balancers.
• SFTP is used to transmit data to various vendors securely.
• EFax services deployed, ensuring fax transmission are encrypted both in transit and at rest.
• Virtru software for encrypted email communication of sensitive and Personally Identifiable Information
• 7-Zip is used to encrypt files being sent to and from vendors.

5) Physical security of computer systems, network equipment, backups and paper materials:

• All computer systems and core network equipment are physically secured in locked rooms or cabinets.
• Essential services are monitored for availability and alerts are sent when a system or service becomes unavailable.
• Printed material with personal information is shredded when no longer needed.
• The main datacenters and several ancillary MDF’s have heat and humidity detection systems as well as a fire suppression system.
• Alarms with motion detectors are in place in all data centers. The university department of Public Safety monitors the alarms.
• Security cameras are set and on 24 hour recording on both main data centers
• A card access system controls access to the data centers and IT administrative offices.

6) Managing data integrity and system failures:

• Daily backups of host systems are performed.
• Network hardware configurations are backed up weekly.
• Out of band capabilities exist to support network management and large-scale outages.
• Continual off-site backup of all FDU owned workstations.
• Mirroring of networked file services across campuses is occurring.
• UPS systems provide backup power to central data centers.
• Extending backup capabilities to include off-site backup of all University systems
• A backup generator is in place for the main data centers.
• A disaster recovery plan has been developed.

(d) Oversee service providers, by: (1) Taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards for the customer information at issue; and (2) Requiring FDU’s service providers by contract to implement and maintain such safeguards.

Contracts require appropriate safeguarding measures be taken by the vendor. Third Party Assessment evaluation using Industry best practice tools prior to executing contracts.

(e) Evaluate and adjust FDU’s information security program in light of the results of the testing and monitoring required by this Policy; any material changes to FDU’s operations or business arrangements; or any other circumstances that are known or have reason to be known as having a material impact on FDU’s information security program.

OIRT continually performs extensive reviews of applicable written policies and has a continuous program in place to review applicable policies and procedures.

OIRT periodically (generally annually) performs an eMail Phishing test to all full-time faculty and staff. FDU uses a third party as the tool for performing the test. Individuals who fail the Phishing test are required to complete remedial training with a passing score. Supervisors are made aware of those who fail the test and are encouraged to speak with their employees.

OIRT conducts comprehensive vulnerability assessments aligned to the NIST Risk Management Framework (RMF) that included external vulnerability scanning, penetration testing, netflow analysis of our IP ranges, review of IT and cybersecurity-specific and FDU-wide documentation, and dark web footprinting.

OIRT takes action to increase the cadence of monitoring and reacting to server, desktop and mobile device alerts, ensure compliance of website configurations and deploy security measures to ensure security of email system and reduce spoofing of emails.

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In accordance with FDU’s Acceptable Use Policy for Computer Usage, no employee shall copy or distribute software that violates copyright laws. All employees shall be aware that software and the accompanying documentation is generally owned by the manufacturer and the license only grants the user the right to use the software. Unlicensed software installations, also known as software piracy, are unacceptable at FDU.

The primary user of each computer shall take responsibility of keeping records of licenses for which software is installed. The University’s Computing Services Department shall also track licenses for software installed by the Computing Services Department though the purchase of high volume or site licenses. Users are advised that the software installed on University-owned computers may be audited internally (by the University) or externally (by software manufacturers or other anti-piracy software firms) at any time. Software found not to be in compliance with copyright laws will be removed and replaced with a licensed copy.

Computing Services will provide certain software that is commonly used by the majority of the University’s employees, including but not limited to word processing, spreadsheet, and anti-virus software. Some software manufacturers allow for non-concurrent use of a license on an office computer and an employee’s home computer. Computing Services will not provide non-concurrent licenses at off premise sites due to the inability to track these licenses.

In order to provide the best possible service and support, and to reduce the cost of software site licenses, Computing Services, in conjunction with the Center for Learning and Teaching with Technology, has standardized on Microsoft Office Professional and Symantec Endpoint Protection.

Popular Software Titles and Guidelines for Faculty and Staff to Obtain:

• Microsoft Office for Windows or Macintosh: Available through standard deployment of leased or owned equipment or by request for any University-owned PC or Mac.
• Microsoft Visual Studio: Installed in Labs. Available by request for staff and faculty machines.
• Adobe Acrobat: Available by request for staff and faculty machines.
• SAS: Installed in Labs. Available by request for staff, faculty and student machines.
• SPSS (Base): Installed in Labs. Available by request for staff and faculty machines.
• SPSS Advanced Modules: Available by request for staff and faculty machines.
• Adobe Products: Faculty and staff may purchase Adobe products at level three pricing with the University’s CLP Membership No. 4400062846.
• Symantec Endpoint Protection: Available through standard deployment of leased or owned equipment or by request for any University-owned PC or Mac.
• Other products: Faculty and staff may obtain pricing and submit orders to Purchasing. If assistance is needed, contact Computing Services.
  

Software Quality Assurance and Compliance Policy for Network Server & Lab Installations

It is no longer possible for individuals to install software on staff or faculty desktops or lab computers. Laptops or Macintosh users have administrative rights and individuals can install additional licensed software to laptops.

Instructors wishing to have a software application installed in a lab for use by 20 or more people simultaneously must provide Computing Services the original installation media, installation guide, and the appropriate proof of license. Note that the licenses for some software may limit our ability to install it on the network. These materials must be provided a minimum of sixty days before the software is needed. Because it is impossible to predict how the software will interact with our network and other software already installed, we cannot guarantee that a program will work on our system.

For programs that will be used by less than 20 people, the instructor may install the application on up to 5 machines in a lab not normally used for classroom instruction, plus an “instructor’s machine” in one of the teaching labs. If fewer licenses are owned, then only that many licenses may be installed. The instructor will be told which machines to install the program on and will be given a password which can be used to disable the security on the machine for the duration of the installation procedure. Software installed in this way will only be available on those designated machines. Computing Services will make a reasonable attempt to keep these designated systems functioning with the additional software, but in the event that the machine needs to have it’s base configuration and software restored from backup, the instructor will be contacted and will need to reinstall the application.

In all cases, software must be owned or licensed by the University, even if the application is only to be used for demonstration purposes. No software owned by an individual will be installed on the systems.

Below is the policy for departments at the University regarding the return of Cisco Desk phones that are no longer in use. This process is known as the “Phone True-Up Process.” It begins with a request from the department to Voice Services at voiceservices@fdu.edu to remove currently active phones from service.

Voice Services will coordinate the collection, inventory, and eventual shipping of the phone(s) to our vendor.

Leave these phones in place and mark them with a Post-It Note that provides the HOST/MAC address of the phone. This ensures easy identification when a technician arrives to retrieve the device.

There are two methods to find the HOST/MAC address:

1. Press the gear button on the phone and use the central navigation key to scroll to “Phone Information.”
2. Alternatively, this information is also listed on the back of the phone.

The True-Up process is carried out annually, around June, coinciding with the end of the University’s Fiscal Year. The new True-Up cycle begins on July 1st with the commencement of the new Fiscal Year. Phones can be removed at any point during the year and stored until the next True-Up. However, billing for these phones continues until the end of the Fiscal Year.

As the demand for access by on-site vendors increases, Fairleigh Dickinson University has created a Vendor Access Policy for Networking and Computing. The intent of the policy is to define the categories of non-employees that are on our campuses and provide rules and guidelines around their networking & computing needs. All business units should utilize the Contract Review Process which has been instituted by the Office of the General Counsel prior to initiating any of the below processes. Fully executed contracts that have been reviewed and approved may be requested by members of OIRT prior to providing any access for the non-employees below.

Effective Date: 3/1/2023
Last Revision: 1/14/2024

Contractors/Consultants

The University employs individuals from companies that perform work on behalf of the University and expressly for the University. Examples could be an employee from a staffing agency working within IT to augment the staff in assisting with a series of projects, or an individual hired from an agency to work within Human Resources to assist in processing forms. These individuals are hired under contracts and are held tothe terms and conditions of those contracts. In most cases, working as part of the University, these individuals need computing functionality identical to those of university hired staff, as they are acting on behalf of the University & fulfilling a role specific to the University. All work done by these individuals is part of the university’s data property, and therefore, these individuals should be provided with University issued devices such as desktop/laptop computers, landline phone extensions, etc.

Individuals hired from companies outside of the University to conduct business on behalf of the University must meet the following guidelines and are provided with the following access:

1. The hiring manager or department head must complete an HR Personal Information Notice (PIN) to begin the process.
   
2. Contractors/Consultants will always be issued a University NetID in the format of Firstinitial.Lastname@v.fdu.edu.
   
3. Once the NetID has been created & communicated to the hiring manager, a Vendor Employee Technology Form must be completed if the contractor/consultant needs access to certain FDU systems. The form to be found in the Staff and Faculty Forms tile of SAMISupport.

SAMI Support

4. All Contractors/Consultants are required to complete the Written Information Security Program (WISP) training immediately after an account is provisioned. Validation of completion is needed within the first 30 days.
   
   1. WISP training reminder on day 15
   2. WISP training daily reminder every day after day 15
   3. Disable account day 30 with an email sent to the manager
      
5. All contractors/consultants must read and accept the following additional policies:
   1. Policy for the acceptable use of email
   2. Acceptable use policy for computer usage
   3. FDU alert policy
   4. Password policy
      
6. Contractors/Consultants will be able to sign up for FDU Alert through Colleague Self-Service. Instructions can be found here:

7. Contractors/consultants issued a university managed laptop/desktop are entitled to an email address without the vendor designation at the request of the hiring manager. This would be requested by the manager through the Vendor Employee Technology Form by clicking the “Convert Vendor NetID” box.

8. Contractors/consultants must be terminated at the end of their contract using the same methodology utilized for current faculty and staff. It is the unshared responsibility of the managing department to submit termination paperwork per the HR process for any contractor/consultant who had been issued a NetID.

Volunteers

The University utilizes volunteers in non-paying positions during the school year. Examples of these roles include but are not limited to preceptors & chaplains. These individuals do not need access to any University systems with the exception of email. As such, they need access to Internet services & email but they do not require an FDU managed laptop/desktop.

Volunteers must meet the following guidelines and are provided the following access:

1. Volunteers will be issued a NetID in the format of Firstinitial.Lastname@v.fdu.edu to be able to authenticate to FDU’s wireless network (and wired network in the future).
   
2. Volunteers are required to complete the Written Information Security Program (WISP) training immediately after an account is provisioned. Validation of completion is needed within the first 30 days.
   
   1. WISP training reminder on day 15
   2. WISP training daily reminder every day after day 15
   3. Disable account day 30 with an email sent to the manager
      
3. All volunteers must read and accept the following additional policies:
   
   1. Policy for the acceptable use of email
   2. Acceptable use policy for computer usage
   3. FDU alert policy
   4. Password policy
      
4. Volunteers will be able to sign up for FDU Alert through Colleague Self-service. Instructions can be found here:

5. All volunteer accounts will expire at the end of the fiscal year and must be renewed by their FDU manager by completing a PIN form.
   
6. Volunteers must be terminated at the end of their contract using the same methodology utilized for current faculty and staff. It is the unshared responsibility of the managing department to submit termination paperwork per the HR process for any contractor/consultant who had been issued a NetID.

On-Campus Vendors

The University outsources various functions to entities (Vendors) that operate independently but work exclusively on our campuses and provide services for our faculty, staff & students. These employees are individually managed by their corporate entities and are largely held accountable by their corporate management.

While on campus, employees of these vendors might need access to the Internet to interact with their corporate websites or communicate with their corporate managers. In many cases today and in most all cases in the future, these employees will need to authenticate through the University’s network in order to conduct their business. The University has established a process whereby the Fairleigh Dickinson University department responsible for that vendor completes the Human Resource forms necessary in order to create a non-employee record within our Colleague system.

Employees of on-campus vendors must meet the following guidelines and are provided the following access:

1. Vendor employees will be issued a NetID in the format of Firstinitial.Lastname@v.fdu.edu to be able to authenticate to FDU’s wireless network (and wired network in the future).

2. Vendor employees will be able to add their contact information to FDU Alert by sending an email to fdunotify@fdu.edu
   
3. All vendor employee accounts will expire at the end of the fiscal year and must be renewed by their FDU manager by completing a PIN form.
   
4. Vendor employees must be terminated through FDU’s systems when they either are removed from their assignment at Fairleigh Dickinson University or are terminated by their employer using the same methodology utilized for current faculty and staff. It is the unshared responsibility of the managing department to submit termination paperwork per the HR process for any contractor/consultant who had been issued a NetID.

Elevated Vendor Privileges

From time to time, the employee of an on-campus vendor might have justification for having access to FDU email or a need to access systems and/or applications that reside behind FDU’s firewalls. If such a case is identified, the FDU department responsible for that vendor would need to contact the Director of Systems with a formal request for additional vendor access. The FDU department must present solid business justification for the elevated access. The Director of Systems will review each request and either approve or reject the request based on business needs and security posture. The Director of Systems might consult with the Data Security & Incident Response Team before providing an answer.

Employees of on-campus vendors approved for elevated access must meet the following guidelines and are provided the following access:

1. Vendor employees will be issued a NetID in the format of Firstinitial.Lastname@v.fdu.edu to be able to access FDU’s wireless network (and wired network in the future).
   
2. All vendor employees are required to complete the Written Information Security Program (WISP) training immediately after an account is provisioned. Validation of completion is needed within the first 30 days.
   
   1. WISP training reminder on day 15
   2. WISP training daily reminder every day after day 15
   3. Disable account day 30 with an email sent to the manager.
      
3. Vendor employees will be able to sign up for FDU Alert through self-service. Instructions can be found here:

4. All vendor employees with elevated access must read the following additional policies:
   
   1. Policy for the acceptable use of email
   2. Acceptable use policy for computer usage
   3. FDU alert policy
   4. Password policy
      
5. If the vendor employee needs to access FDU systems and/or applications, issuance of a University managed laptop/desktop may be required. This would be at the expense of the requesting department.
   
6. Upon departmental request, vendor employees will only be provided access to the specific University Systems and applications approved by the Director of Systems.
   
7. All vendor employee accounts will expire at the end of the fiscal year and must be renewed by their FDU manager by completing a PIN form.
   
8. Vendor employees must be terminated through FDU’s systems when they either are removed from their assignment at Fairleigh Dickinson University or are terminated by their employer using the same methodology utilized for current faculty and staff. It is the unshared responsibility of the managing department to submit termination paperwork per the HR process for any contractor/consultant who had been issued a NetID.

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All employees of Fairleigh Dickinson University are responsible for conducting business in a safe and secure way. Select employees may be required to view Personal Information (PI) and Personal Health Information (PHI) as part of their daily responsibilities, while others may handle sensitive information of another nature. All employees receive correspondence from outside the University. Ensuring that our community remains safe and diligent in the face of today’s cyber landscape is vital. The policy below will provide a baseline understanding of the data security protocols in place and the expectations on FDU employees to uphold them.

Effective Date: 12/01/2022
Last Revision: 03/15/2021
Last Review: 11/28/2022

I. OBJECTIVE

The objective of Fairleigh Dickinson University (“University”) in the development and implementation of this comprehensive Written Information Security Program (“WISP”) is to create effective administrative, technical and physical safeguards for the protection of Personal Information (“PI”) and Protected Health Information (“PHI”). The WISP sets forth the University’s procedure for evaluating its electronic and physical methods of accessing, collecting, storing, using, transmitting, and protecting PI and PHI.

For purposes of this WISP, PI means:

1. User name, email address, or any other account holder identifying information, in combination with any password or security question and answer that would permit access to an online account.

2. Someone’s name and any one of the following data elements:
   
   • Social Security number, Social Insurance number, National Insurance number, or equivalent;
     
   • Date of birth (MM/DD/YYYY),
     
   • Driver’s license number, state-issued identification card number, or provincially-issued identification card number;
     
   • Financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password, that would permit access to an individual’s financial account;
     
   • Passport number;
     
   • Medical history, mental or physical condition, or medical treatment or diagnosis by a health care professional or health insurance information; or
     
   • Student/Employee (i.e., Datatel) ID number coupled with a password or security question and answer or any portion of any item in the list above that would permit access to an online account.

For purposes of this WISP, PHI includes information that is created, received, and/or maintained by the University that is related to an individual’s health care (or payment related to health care) that directly or indirectly identifies the individual.

PI or PHI shall not include information that is lawfully obtained from publicly available information, or from federal, state, provincial or local government records lawfully made available to the general public.

Notwithstanding the above and irrespective of whether or not it’s considered PII or PHI, one should always take care and caution to use the minimum data elements necessary to perform the business function at hand.

II. PURPOSE

The purpose of the WISP is to better:

1. Ensure the security and confidentiality of PI and PHI;
   
2. Protect against any anticipated threats or hazards to the security or integrity of such information; and
   
3. Protect against unauthorized access to or use of such information in a manner that creates a substantial risk of identity theft or fraud.

III. SCOPE

In formulating and implementing this WISP, the University has addressed and incorporated the following protocols:

1. identified reasonably foreseeable internal and external risks to the security, confidentiality, and/or integrity of any electronic, paper or other records containing PI and PHI;

2. assessed the likelihood and potential damage of these threats, taking into consideration the sensitivity of the PI and PHI;

3. evaluated the sufficiency of existing policies, procedures, information systems, and other safeguards in place to control risks;

4. designed and implemented a WISP that puts safeguards in place to minimize those risks, consistent with the requirements of the regulations in this document; and

5. implemented regular monitoring of the effectiveness of those safeguards.

IV. DATA SECURITY COORDINATOR

The University has designated the Chief Information Security Officer (CISO), working together with the Data Security Information Response Team (DSIRT), to implement, supervise and maintain the WISP. See Appendix II for contact information for the CISO and DSIRT. Together, they will be responsible for:

1. Initial implementation of the WISP;
   
2. Regular testing of the WISP’s safeguards;
   
3. Evaluating the ability of each of the University’s third party service providers to implement and maintain appropriate security measures for the PI and PHI to which the University has permitted them access, consistent with the regulations outlined in this document; and requiring such third party service providers by contract to implement and maintain appropriate security measures;
   
4. Reviewing the scope of the security measures in the WISP at appropriate intervals, including the review of any material change in the University’s business practices that may implicate the security or integrity of records containing PI and PHI; and
   
5. Conducting training sessions for all University employees, and independent contractors, including temporary and contract employees, who have access to PI and PHI on the elements of the WISP. All attendees at such training sessions are required to certify their attendance at the training, and their familiarity with University requirements for ensuring the protection of PI and PHI.

V. INTERNAL RISKS

To combat internal risks to the security, confidentiality, and/or integrity of any electronic, paper or other records containing PI and PHI, and evaluating and improving, where necessary, the effectiveness of the current safeguards for limiting such risks, the following measures are mandatory and effective immediately:

Internal Threats

1. The University shall only collect PI and PHI of students, their parents, alumni, donors, suppliers, vendors, independent contractors or employees that is necessary to accomplish the University’s legitimate need to access said records, and for a legitimate job-related purpose, or necessary for University to comply with state, provincial, or federal regulations.
   
2. Access to records containing PI and PHI shall be limited to those persons who are reasonably required to know such information in order to accomplish a University legitimate business purpose or to enable the University to comply with state, provincial or federal regulations.
   
3. All persons who fail to comply with this WISP shall be subject to disciplinary measures, up to and including termination, irrespective of whether PI and PHI was actually accessed or used without authorization. Any such discipline shall be in accordance with processes and procedures of Human Resources and subject to any protections afforded under the University’s agreement with “Office & Professional Employees International Union”, the “Faculty Handbook”, and similar documents.
   
4. Access to PI and PHI shall be restricted to authorized University personnel only.
   
5. Any PI and PHI stored shall be disposed of when no longer needed for business purposes or required by law for storage. Paper or electronic records (including records stored on hard drives or other electronic media) containing PI and PHI shall be disposed of only in a manner that complies with the regulations outlined in this document and as follows:
   
   • Paper documents containing PI and PHI shall be shredded upon disposal so that PI and PHI cannot be practicably read or reconstructed; and
     
   • Electronic media and other non-paper media containing PI and PHI shall be destroyed or erased upon disposal so that PI and PHI cannot be practicably read or reconstructed.

6. A copy of this WISP must be distributed to each current University employee and to each new University employee at the commencement of their employment.

7. Procedures for Terminated Employees (whether voluntary or involuntary)
   
   • Terminated employees must return all records containing PI and PHI, in any form that may at the time of such termination be in the former employee’s possession (including all such information stored on laptops or other portable devices or media, and in files, records, work papers, etc.)
     
   • A terminated employee’s physical and electronic access to PI and PHI must be immediately blocked. Such terminated employee shall be required to surrender all keys, IDs or access codes or badges, business cards, and the like, that permit access to the firm’s premises or information. Moreover, such terminated employee’s remote electronic access to personal information must be disabled.

8. Physical Assets Protocol
   
   • All assets must be secured from theft by locking up and maintaining a secure workplace, whether that work takes place in University stores, offices, at a client site, in a car, hotel or in a home.
     
     • All University laptops shall be deployed with encryption capabilities enabled. End users may not disable such encryption. Exceptions to this policy are as follows:
       
       • With the explicit written authorization of the CISO;
         
       • May be disabled by OIRT personnel for temporary maintenance purposes only;
         
       • Loaner laptops temporarily assigned with the understanding they will not be used to store or access any information that is considered to be protected under this policy.
         
     • All laptops should be placed in the trunk of vehicle when and wherever they are parked. If no secure trunk or other storage is available, employees should, whenever possible, keep their laptops in their possession or find a way to secure and conceal it.
       
     • Laptops, PDAs, phones and other portable devices that may contain or have access to PI and/or PHI left in the office or at home over night should be kept in a locked and secure location.
       
     • Employees must have assets secured or within their physical possession while on public or private transportation, including air travel.
       
   • Files containing PI and/or PHI are not to be stored on local computer hard drives, shared drives or other external media (which include externally hosted services such as, but not limited to OneDrive, Google, and Drop Box) without prior written authorization from the CISO. If approved, the method of storage and access to the data will be determined by the CISO during the discussion and placed in writing. (See Appendix I for more detail).

9. Access Control Protocol
   
   • Access to electronically stored PI and PHI shall be electronically limited to those University employees having a unique log-in ID.
     
   • Employees must ensure that all computer systems under their control are locked when leaving their respective workspaces. Employees must not disable any logon access.
     
   • Employees must log off of the VPN or Virtual Desktop (VDI) when they are not directly using those resources.
     
   • All Ellucian (Datatel) sessions that have been inactive for 60 or more minutes shall require re-log-in.
     
   • After 5 unsuccessful log-in attempts by any Ellucian (Datatel) or MS Active Directory NetID, that user ID will be blocked from accessing those systems until access privileges are re-established by University Systems and Networking.
     
   • Employees must maintain the confidentiality of passwords and access controls:
     
     • All Ellucian (Datatel) or MS Active Directory NetID passwords are required to adhere to strong password rules.
       
     • All Ellucian (Datatel) or MS Active Directory NetID passwords are required to be changed every 3 months.
       
     • Employees must not share accounts or passwords with anyone.
       
     • Employees should not record passwords on paper or in a document or in a place where someone other than the employee might have access to it. Tip: The University has identified a password vault application (Keepass); those interested should open a ticket with the Fairleigh Dickinson University Technical Assistance Center (UTAC) requesting assistance on setting it up.
       
   • Where practical, all external or internal visitors to a department are restricted from areas where files containing PI and PHI are stored. Alternatively, visitors must be escorted or accompanied by an approved employee in any area where files containing PI and PHI are stored.

VI. EXTERNAL RISKS

To combat external risks to the security, confidentiality, and/or integrity of any electronic, paper or other records containing PI and PHI, and evaluating and improving, where necessary, the effectiveness of the current safeguards for limiting such risks, the following measures are mandatory and effective immediately:

External Threats

1. Firewall protection, operating system security patches, and all software products shall be reasonably up-to-date and installed on any computer that stores or processes PI and PHI.
   
2. All system security software including, anti-virus, anti-malware, and internet security shall be reasonably up-to-date and installed on any computer that stores or processes PI and PHI.
   
3. To protect against external threats, all PI and PHI shall be handled in accordance with the protocols set forth above under “Internal Threats”.
   
4. In the event an individual inadvertently discovers he/she received PI or PHI from an external party, such PI or PHI shall be handled in accordance with the protocols set forth under “Internal Threats”.
   
5. There shall be secure user authentication protocols in place that:
   
   • Control user ID and other identifiers;
     
   • Assigns passwords in a manner that conforms to accepted security standards, or applies the use of unique identifier technologies;
     
   • Control passwords to ensure that password information is secure.
     
6. PI and PHI shall not be removed from the business premises in electronic or written form absent a legitimate business need and use of reasonable security measures, as described in this WISP.
   
   • PI and/or PHI that MUST be transmitted in electronic form shall not be sent without encryption.
     
   • PI and/or PHI in paper form must be secured.
     
7. All computer systems shall be monitored for unauthorized use or access to PI and PHI.

VII. IN CASE OF LOSS/THEFT OR SUSPECTED LOSS/THEFT

If you have reason to believe that any PI or PHI has been lost or stolen or may have been compromised or there is the potential for identity theft, regardless of the media or method, you must report the incident immediately by contacting the Fairleigh Dickinson University Technical Assistance Center (UTAC). The UTAC is available 24 x 7.

VIII. OTHER APPLICABLE POLICIES

Data Security Information Response Plan (September 15, 2019, not published on Web)

IX. EXCEPTIONS

Requests for exceptions to this policy should be directed in writing to the Chief Information Security Officer. Only the Chief Information Security Officer in consultation with the DSIRT may grant such exceptions and will do so only after careful review and in writing.

X. REVIEW

This policy shall be reviewed annually by the Data Security Incident Response Team (DSIRT) at the first meeting in April.

Appendix I

Technical requirements for the storage of files containing PI or PHI regardless of where the storage occurs will include but not be limited to the following:

1. All file(s) should be secured with AES 256bit encryption unless actively open for review or modification.
   
2. It is the responsibility of the person handling the PI or PHI file to securely delete any files created as a product of the manipulation of those files. As an example, temporary files created by Microsoft Office programs or any other programs would need to be securely deleted as well as the clear text versions of the original file after the encrypted version is properly created and verified.
   
3. Programs used for Encryption/Decryption and secure file deletion must be approved by the CISO including the methods in which they are to be used.
   
4. If the complete or partial PI or PHI containing file(s) are inadvertently written to a local hard drive, it is the user’s responsibility to diligently make sure the contents are securely deleted.

Appendix II

DATA SECURITY INCIDENT RESPONSE TEAM (ROLES AND RESPONSIBILITIES)

The Data Security Incident Response Team membership includes the Chief Operating Officer, the Chief Information Officer, the Chief Information Security Officer, the Chief Academic Officer, the University General Counsel and the University Risk Manager. Each member of the Data Security Incident Response Team (DSIRT) has responsibilities related to the security of all the organization’s sensitive information. The DSIRT members listed below have specific responsibilities with regard to the reporting and handling of data security incidents. Note that one person may serve in multiple roles.

Senior Vice President for Finance & Administration: Hania Ferrara
Daytime telephones: office: 201-692-2381; Email: ferrara@fdu.edu

Chief Information Officer (CIO): Neal Sturm
Daytime telephones: office: 201-692-8689; Email: sturm@fdu.edu

Chief Information Security Officer (CISO): Kimberley Dawn Dunkerley
Daytime telephones: office: 201-692-7672; Email: ddunkerley@fdu.edu

Privacy Officer: Kimberley Dawn Dunkerley
Daytime telephones: office: 201-692-7672; Email: ddunkerley@fdu.edu

Chief Academic Officer (CAO): Michael Avaltroni
Daytime telephones: Office: 201-692-7093; Email: mavaltroni@fdu.edu

University General Counsel: Edward Silver
Daytime telephones: office: 201-692-7071; Email: esilver@fdu.edu

University Risk Manager: Gail Lemaire
Daytime telephones: office: 201-692-7083; Email: lemaire@fdu.edu

Vancouver Campus Executive: Wilfred Zebre
Daytime telephone: office: 604-648-4462; Email: wilfred_zerbe@fdu.edu

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