Data Security Procedures, Roles and Responsibilities

The Chief Information Security Officer (CISO) shall identify and assess reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of College data. This identification and risk assessment shall include adopting means for detecting security system failures and monitoring the effectiveness of the Computer System Security Requirements.

The CISO shall oversee the implementation of the Computer System Security Requirements and recommend changes to address risks, failures, or changes to business practices. The CISO shall work with other College administrators to investigate any violation of this policy and any incident in which the security or integrity of College data may have been compromised, including taking the steps set forth below in response to a security breach. The CISO shall work with other College administrators to develop and review training materials to be used for employee training under this policy.

The President, College Vice Presidents, and Deans are responsible for promoting the institutional awareness of this policy and for ensuring overall compliance by their staff.

In particular, Vice Presidents and Deans are responsible for:

• Ensuring that all staff have the training and support necessary to protect data in accordance with this policy, all Data Security Directives, and any Specific Security Procedures applicable to such data;
• Designating and managing the efforts of one or more Sponsors and Data Security Officers for all Information Resources maintained in their area of responsibility;
• Approving access authorization of all Users of Information Resources maintained in their area of responsibility having a data classification of Confidential;
• Promulgating Specific Security Procedures;
• Ensuring that Confidential or Internal Use Only data sponsored within their area of responsibility are not provided or accessible to, or created or maintained by College vendors or other third-parties without assistance from the Chief Information Security Officer and the College Risk Manager:
  • verifying that the third party has the capability of adequately protecting such data;
  • review and approval of the relevant contract and the underlying terms and specifications by the College Risk Manager and Chief Information Security Officer unless approved otherwise by the Assistant Attorney General;
  • verifying that the third party has executed the College’s standard form of Privacy and Security Addendum.

• A Sponsor or Data Steward has primary responsibility for overseeing the collection, storage, use and security of a particular Information Resource;
• In cases where a Sponsor is not identified for any Information Resource, the cognizant Vice President or Dean shall be deemed the Sponsor;
• A Sponsor is responsible for the following specific tasks associated with the security of the information:
  • Ensuring that the Information Resource is assigned a security classification and that such data is marked where appropriate;
  • Identifying authorized Users of the Information Resource, whether by individual identification or by job title, and obtaining approval for such access from their Vice President or Dean;
  • Proposing to their Vice President or Dean Specific Security Procedures for the handling of data under their sponsorship, consistent with this policy and other applicable College policies and procedures.

Users are responsible for complying with all security-related procedures pertaining to any Information Resource to which they have authorized access.

Specifically, a User is responsible for:

• Becoming familiar with and complying with all relevant College policies, including, without limitation, this policy, and all Data Security Directives contemplated hereby, the policy on Professional Standards and Business Conduct, and other policies related to data protection, technology use and privacy rights (including the College Student Education Records);
• Providing appropriate physical security for information technology equipment, storage media, and physical data. Such equipment and files shall not be left unattended without being locked or otherwise protected such that unauthorized Users cannot obtain physical access to the data or the device(s) storing the data;
• Ensuring that Confidential or Internal Use Only information is not distributed or accessible to unauthorized persons. Users must not share their authorization passwords under any circumstances. Users must avail themselves of any security measures, such as encryption technology, security updates or patches, provided by Data Security Officers. Users must log off from all applications, computers and networks, and physically secure printed material, when not in use;
• To the extent possible, making sure that any Massachusetts PI accessed by the User is stored only on secure servers maintained by the College and not on local machines, unsecure servers, or portable devices;
• SPSCC Confidential or Internal Use Only data, when removed from the campus or when accessed from off-campus, is subject to the same rules as would apply were the data on campus. Sponsors and Users will comply with this Policy and all relevant Data Security Directives irrespective of where the College data might be located, including, for example, on home devices, mobile devices, on the Internet, or other third-party service providers;
• When access to information is no longer required by a User, disposing of it in a manner to insure against unauthorized interception of any Confidential or Internal Use Only information. Generally, paper-based duplicate copies of Confidential documents should be properly shredded, and electronic data taken from Confidential databases should be destroyed;
• Immediately notifying his or her cognizant Data Security Officer of any incident that may cause a security breach or violation of this policy.

The Chief Human Resources Officer shall be responsible for:
 

• Educating incoming employees (including temporary and contract employees) regarding their obligations under this policy and to provide on-going employee training regarding data security;
• Ensuring that terminated employees no longer have access to College systems that permit access to Confidential or Internal Use Only information;
• Carrying out any disciplinary measures against an employee taken in response to a violation of this policy as required by the Data Security Committee.