Security

Introduction

This document outlines the university approved process for securely deleting Personal Information (PI) and Protected Health Information (PHI) after the PI or PHI has been encrypted.

Prerequisite

Eraser Portable® Secure Data Remove software needs to be installed on your computer. Please contact the Fairleigh Dickinson University Technical Assistance Center (UTAC) to request the installation of this software. A member of USAN will assist with the installation and setup of the software.

Document Deletion Process

To securely delete an unencrypted version of a document that contain PI and/or PHI that has been encrypted, complete the following steps:

1. Find the “Secure Deletion” shortcut folder on your computer desktop screen
2. Cut and paste the unencrypted version of the file to be deleted into this folder
3. Find the “Eraser Portable” shortcut folder on your computer desktop screen and click to open the folder
4. Double Click on “EraserPortable.exe“. The screen below will appear
5. Click on the Green Run arrow to erase the file securely

6. A dialogue box will appear

7. Click “Yes“
8. When the deletion process completes, you will see a report appear

9. You may check your “Secure Deletion” folder to see if all documents have been erased

Outlook E-mail Deletion Process

To securely remove emails which contain PI and PHI from your Outlook client, complete the following steps:

1. Delete the email from your Inbox and/or Sent items folder
2. Delete the email from your Deleted Items
3. Go to “Recover Deleted Items“
4. Highlight Deleted Items Folder

5. Then go to Folder > Recover Deleted Items

6. Highlight email which requires permanent deleting and select “Purge Selected Items” and then click “OK“. Now message is permanently out of your email system

7. Finally, click “OK” on the following screen

This document outlines the University approved process for securely encrypting Personally Identifiable Information (PII).

Prerequisite

7Zip software needs to be installed on the end user’s computer. Please contact the Fairleigh Dickinson University Technical Assistance Center (UTAC) to request the installation of this software. If justification is needed, notify UTAC that 7Zip is needed to encrypt documents containing PII.

Process

Encrypting Files and Folders

To encrypt a single file, find the file in your directory (or where you have it saved).

1. Right click on the document (do not open the document)
2. On the drop down menu, Find 7zip
3. Click “Add to archive…“
4. When 7zip opens, there are three (3) settings which need to be changed:
   • Archive Format = Select zip from drop down
   • Encryption Method = select AES-256 from drop down
   • Check “show password” and type in a password that the user creates
   • Click “OK“
   • A 7Zip Archive with the encrypted document will now appear in your directory

NOTE: Do not utilize any password that you use to access internal systems. The password cannot be recovered if forgotten.

Editing Encrypted Files and Folders

When editing an encrypted file or folder, you must make sure that you leave the 7zip archive open. If you close the archive, you will be able to work on the document, but it will not save.

Opening an Encrypted File or Folder

To open an encrypted file or folder:

1. Right click on the 7Zip archive
2. On the drop down menu, find 7Zip
3. Click on the first “Open archive”
4. Click to open your document

Saving an Encrypted File or Folder

To save an encrypted file or folder:

1. Save the document as normal
2. Upon closing document, the 7Zip archive will prompt the user to save the changes

What is a phishing scam?

Phishing refers to the act of using a fraudulent identity and scenario to extract personal information or something else of value. Although phishing scams can occur over various mediums including text messages, phone calls, and social media, they are most frequently carried out via email.

Scammers have many means of acquiring bulk email addresses. Receiving a phishing attempt does not mean that your account has been singled out or has been compromised in any way.

Fairleigh Dickinson University’s email accounts employ Microsoft’s Advanced Threat Protection (ATP) which, in addition to traditional spam filtering, removes malware infected attachments and utilizes Safelinks to scan messages for malicious links. Additionally, we have appended the subject line of messages coming from outside of the FDU domain with the “[External]” tag. Although phishing can occasionally come from inside of our domain, messages with the external tag demand extra scrutiny.

Despite all of these efforts, keeping up with the latest scams is always a cat and mouse game. It is best practice to have a solid foundational knowledge of how these scams work.

Detecting a Phishing Scam

Although each phishing scam is unique, there are certain common traits which can serve as red flags. The most common “tell” is a sense of urgency. Generally, phishers would like for you to act promptly and without careful consideration. As a result, they will pepper their email with phrases such as “immediate action required” and “to avoid the immediate suspension of your account”.

Although an urgent tone is likely to be your first clue, there are plenty of other red flags that you will begin to notice over time. Many phishing attempts are poorly constructed emails. Incorrect spelling and grammatical errors are common. The message could contain a blank subject line and the sender’s signature may only list their title instead of their name. Be wary of messages in which the quality of writing does not meet your expectations for the purported institution.

The goal of many scams is to make a request for your personal information. This can take the form of bluntly asking for your social security number. However, it may also take a subtler approach. Many phishing attempts will create a mock version of a University, banking institution, or commerce website and ask you to log in. Once you enter your account information, the scammers have acquired your password.

Although most phishing scams cast a wide net, some recent attacks have specifically targeted individual members of the University. If someone is claiming to be your colleague or supervisor, check to confirm that the message is coming from their FDU account. Do not trust messages claiming to be from FDU employees which originate from external accounts such as Gmail and Yahoo.

Many of these personalized scams also have a very specific common thread. After a bit of conversation, the scammer will request that you purchase gift cards for common services such as iTunes, Google Play, or Amazon. No, your boss does not urgently require you to purchase gift cards out of pocket.

Also, beware of solicitations coming to your FDU email address from businesses offering deals or asking you to click on a banner to receive a promotion. Make sure that the email is coming from the domain of the company offering the sale or promotion.

What does a phishing scam look like?

Now that you know what to look for, let’s look at a sample phishing attempt:

Reporting a Phishing Scam

You can use your newfound expertise to assist the FDU community. When you see a message that you believe to be a phishing scam, please report it to us. Via Outlook this can be accomplished via our reporting tool. Please see Reporting Phishing or Junk Emails for more information. If you are using an alternative mail client such as Apple Mail, you can forward the suspected scam to phishing@fdu.edu.

How should I proceed if I have already replied to a Phishing Scam?

Please change any passwords that you have provided to the scammer. Once this is completed, please contact the Fairleigh Dickinson University Technical Assistance Center (UTAC) for further instructions.

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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This Vendor Cybersecurity Assessment Form is designed to evaluate and assure the strength and comprehensiveness of the cybersecurity practices followed by our vendors. By completing this form, the FDU Point of Contact will help us to understand the existing cybersecurity measures better, identify potential areas of vulnerability, and maintain a reliable, secure network within our FDU ecosystem. This rigorous assessment is crucial in our broader cybersecurity strategy, minimizing risks and fortifying data security.

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: 05/28/2024
Last Revision: 12/01/2022
Last Review: 05/13/2024

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. Biometric data that can uniquely identify a person based on their physical, behavioral, or physiological characteristics. These characteristics can include:
   1. Fingerprints
   2. Palmprints
   3. Voiceprints
   4. Facial, retinal, or iris measurements
   5. Handwriting and signature
   6. Facial geometry (the shape of a person’s face)

3. Someone’s name and any one of the following data elements:
   
   1. Social Security number, Social Insurance number, National Insurance number, or equivalent;
      
   2. Date of birth (MM/DD/YYYY),
      
   3. Driver’s license number, state-issued identification card number, or provincially-issued identification card number;
      
   4. 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;
      
   5. Passport number;
      
   6. Medical history, mental or physical condition, or medical treatment or diagnosis by a health care professional or health insurance information; or
      
   7. 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.

All University employees except those listed under section IX must complete online or in-person WISP training and test with a passing score of at least 80% every 24 calendar months.

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 Chief Information Officer (CIO) and the Data Security Information Response Team (DSIRT), to implement, supervise and maintain the WISP. See Appendix II for contact information for the CISO, CIO 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 in-person or online, synchronous or asynchronous, training sessions for all University employees, and independent contractors, including temporary and contract employees 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:
   
   1. Paper documents containing PI and PHI shall be shredded upon disposal so that PI and PHI cannot be practicably read or reconstructed; and
      
   2. 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)
   
   1. 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.)
      
   2. 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
   
   1. 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.
      
      1. All University laptops shall be deployed with encryption capabilities enabled. End users may not disable such encryption. Exceptions to this policy are as follows:
         
         1. With the explicit written authorization of the CISO;
            
         2. May be disabled by OIRT personnel for temporary maintenance purposes only;
            
         3. 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.
            
      2. 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.
         
      3. 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.
         
      4. Employees must have assets secured or within their physical possession while on public or private transportation, including air travel.
         
      5. 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
   
   1. Access to electronically stored PI and PHI shall be electronically limited to those University employees having a unique log-in ID.
      
   2. Employees must ensure that all computer systems under their control are locked when leaving their respective workspaces. Employees must not disable any logon access.
      
   3. Employees must log off of the VPN or Virtual Desktop (VDI) when they are not directly using those resources.
      
   4. All Ellucian (Datatel) sessions that have been inactive for 60 or more minutes shall require re-log-in.
      
   5. 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.
      
   6. Employees must maintain the confidentiality of passwords and access controls:
      
      1. All Ellucian (Datatel) or MS Active Directory NetID passwords are required to adhere to strong password rules.
         
      2. All Ellucian (Datatel) or MS Active Directory NetID passwords are required to be changed every 3 months.
         
      3. Employees must not share accounts or passwords with anyone.
         
      4. 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, Dashlane or Lastpass); those interested should open a ticket with the UTAC requesting assistance on setting it up.
         
   7. 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.
      
10. Educational Records
    
    1. The Family Educational Rights and Privacy Act (FERPA) of 1974 prohibits educational institutions from disclosing education records without the written consent of an eligible student.
    2. Limited exceptions to non-disclosure include directory information and specific school officials with a legitimate educational interest.
    3. The transmition of education records covered under FERPA must follow the same PI/PHI guidelines as depicted in Appendix I of this policy.

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:
   
   1. Control user ID and other identifiers;
      
   2. Assigns passwords in a manner that conforms to accepted security standards, or applies the use of unique identifier technologies;
      
   3. 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.
   
   1. PI and/or PHI that MUST be transmitted in electronic form shall not be sent without encryption.
      
   2. 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) at (973)-443-8822. 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

The following groups are exempt from taking the mandated bi-annual WISP training as described in section I of this policy:

1. Those currently not employed by the University but who are granted Net ID’s with only email access (no other access to FDU IT resources or services).
   
2. Retired full-time faculty not employed by the University but who are granted email access for life as a retired tenured full-time faculty member.
   
3. Retired full-time executive emeritus not employed by the University but granted email access for life as a retired full-time executive emeriti.

Requests for other 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 and Chief Financial Officer: Frank Barra
Daytime telephones: office: (201)-692-2237; Email: fbarra@@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

Senior Vice President and University Provost: Benjamin Rifkin
Daytime telephones: Office: (201)-692-7093; Email: brifkin@fdu.edu

Office of the General Counsel: Steve Nelson
Daytime telephones: office: (201)-692-2466; Email: snelson@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

Associate Vice President for MIS: Saul Kleinman
Daytime telephone: Office: (201)-692-2065; Email: saul@fdu.edu

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