Wisp business plan

wisp business plan

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If an account or password is suspected to have been compromised, all passwords should be changed immediately and the incident reported to the wellesley college help Desk. 4.6 Third-Party vendor Agreements Concerning Protection of Personal Information Wellesley college exercises appropriate diligence in selecting service providers capable of maintaining appropriate security safeguards for pi provided by the college to them. . The primary budget holder for each department is responsible for identifying those third parties providing services to the college that have access. All relevant contracts with these third parties are reviewed and approved by the wellesley college purchasing Department to ensure the contracts contain the necessary language regarding safeguarding. It is the responsibility of the primary budget holders to confirm that the third parties are required to maintain appropriate security measures to protect pi consistent with this Program and Massachusetts laws and regulations. 4.7 Computer system safeguards Technology support Services staff monitor and assess safeguards on an ongoing basis to determine when enhancements are required.  The college has implemented the following to combat external risk and secure the college network and systems containing Confidential Data: Secure user authentication protocols: Unique passwords are required for all user accounts; each employee receives an individual user account.

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In extreme circumstances involving travel to a remote location where access to technology would be limited and would prohibit retrieval of a lost passport, a program director may request an exemption to this policy allowing for him or her to retain copies of the students. This request will be made to the Chief Information mother Officer for approval. If the request is approved, the program director will sign the faculty/Staff Agreement for Traveling with Secure data to acknowledge their understanding of the wisp and their responsibilities in protecting the passports. The program director also agrees to alert lts immediately if the copies of passport are lost. 4.4 Policies for Safeguarding Restricted Data Access to restricted Data should be limited to members of the community who have a legitimate business need for the data. Restricted Data can be stored on google Apps, sakai, ntm and vault. Restricted data may be stored on cloud-based storage solutions that are unsupported by the college as assessment long as they are in compliance with the requirements of any laws governing the protection of such data (e.g., ferpa). Documents containing Restricted Data should not be posted publicly. 4.5 Password Requirements In order to protect College data, all members of the community must select unique passwords following these guidelines: Has at least 8 characters Contains a combination of at least three of the four character types: uppercase and lowercase letters, numbers, and special. Passwords must not be shared with others.

Traveling Abroad with Students Personal Information In the event that transmission of student passport information is required by the hotel or program abroad in advance of the travel, only the relevant information requested (e.g., name, passport Number, date of Expiry, and Date of Birth) will. This information should first be transmitted via fax or through efax Secure website (SSL), provided that the wellesley college resumes department arranging the travel confirms the accuracy of the fax number by sending an initial confirmation message before the actual data. If faxing is unavailable, the data may be sent via wellesley email, provided that the same confirmation of transmission takes place. Faculty/staff who need to retain these passport numbers for arranging travel will store this data in spreadsheets that are saved on the colleges secure vault server. Any spreadsheets containing student passport information should be routinely deleted by the spreadsheet owner when no longer needed. Faculty/staff who are traveling with the students abroad that need student passport and visa information for hotel check-in will keep a paper record on their person that contains relevant information (such as the passport and visa numbers and their expiry dates) and the last names. Faculty/staff must not retain or travel with copies of student passports.

wisp business plan

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(see the Stewardship of Electronic Content Policy for more information.) Transporting Confidential Data members of the community are strongly discouraged from removing records containing Confidential data off campus. In rare cases where it is necessary to do so, the user must take all reasonable precautions to safeguard the data. Under no circumstances are documents, electronic devices, or digital media containing Confidential data to be left unattended in any unsecure location. When there is a legitimate need to provide records containing Confidential data to a third party outside wellesley college, electronic records shall be password-protected and/or encrypted, and paper records shall be marked confidential and securely sealed. Destruction presentation of Confidential Data records containing Confidential data must be destroyed once they are no longer needed for business purposes, unless state or federal regulations require maintaining these records for a prescribed period of time. Paper and electronic records containing Confidential data must be destroyed in a manner that prevents recovery of the data. Massachusetts General Law 93I specifies the manner in which records containing pi must be destroyed.

Phi may be stored or accessed through the google Apps core suite (including mail, Drive, groups, sites, Chat) as these apps are certified hipaa compliant, provided that access to the phi is appropriately restricted.  This does not apply to google consumer apps such as google, hangouts, etc. Massachusetts pi and nfi must not be stored on any google app. Confidential data must not be stored on cloud-based storage solutions that are unsupported by the college (including DropBox, microsoft OneDrive, apple icloud, etc.). Members of the community are strongly discouraged from storing Confidential data on laptops or on other mobile devices (e.g., flash drives, smart phones, external hard drives).  However, if it is necessary to transport Confidential data electronically, the mobile device containing the data must be encrypted. Paper records containing Confidential data must be kept in locked files or other secured areas when not in use. Upon termination of employment or relationship with Wellesley college, electronic and physical access to documents, systems or other network resources containing Confidential data is immediately terminated.

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wisp business plan

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All members of the community are required to access, store and maintain records containing sensitive data in compliance with this Program. 4.2 Identification and Assessment of Risks to college Information Wellesley college recognizes that it has both internal and external risks to the privacy and integrity of College information. These risks include, but are not limited to: Unauthorized access of Confidential data by summer someone other than the owner of such data compromised system security as a result of system access by an unauthorized person Interception of data during transmission Loss of data integrity Physical. Since technology growth is not static, new risks are created regularly. Accordingly, lts will actively participate and monitor advisory groups such as the Educause security Institute, the Internet2 Security working Group and sans for identification of new risks. Wellesley college believes the colleges current safeguards are reasonable and, in light of current risk assessments made by lts, are sufficient to provide security and confidentiality to confidential data maintained by the college.

Additionally, these safeguards protect against currently anticipated threats or hazards to the integrity of such information. 4.3 Policies for Safeguarding Confidential Data to protect College data classified as Confidential, the following policies and procedures have been developed that relate to access, storage, transportation and destruction of records. For an overview of storage guidelines, see the data Storage guide. Access storage Only those employees or authorized third parties requiring access to confidential data in the regular course of their duties are granted access to this data, including both physical and electronic records. To the extent possible, all electronic records containing Confidential data should only be stored on vault (the colleges on-campus secure network storage) and not on local machines or unsecured servers.

4.0 Policy.1 Responsibilities All data at the college is assigned a data steward according to the constituency it represents.  Data stewards are responsible for approval of all requests for access to such data.  The data steward for each constituency group are designated as follows: Type of Data data Steward* Faculty Provost Staff Vice President for Finance and Administration Student Shared between the registrar, director of Admission and dean of Admission and Financial Aid Alumnae executive director of the. Library and Technology services (LTS) staff serve as the data custodians for all data stored centrally on the colleges servers and administrative systems, and are responsible for the security of such data.  For distributed data stored on departmental servers, the department head or their designee serves as the data custodian, and lts and the department share joint responsibility for securing the data.


Human Resources will inform lts staff about an employees change of status or termination as soon as is practicable but before an employees departure date from the college.  Changes in status may include terminations, leaves of absence, significant changes in position responsibilities, transfer to another department, or any other change that might affect an employees access to college data. For detailed information regarding account terminations, see the Electronic Content Stewardship Policy. Department heads will alert lts at the conclusion of a contract for individuals that are not considered Wellesley college employees in order to terminate access to their Wellesley college accounts. The lts security team is in charge of maintaining, updating, and implementing this Program.  The colleges Chief Information Officer (CIO) has overall responsibility for this Program. All members of the community are responsible for maintaining the privacy and integrity of all sensitive data as defined above, and must protect the data from unauthorized use, access, disclosure or alteration.

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Any non-public data that is not explicitly designated as Confidential should be treated as Restricted data. Restricted data includes data protected by the family Educational Rights and Privacy Act (ferpa referred to as student night education records. This data also includes, but is not limited to, donor information, research data on human subjects, intellectual property (proprietary research, patents, etc. college financial and investment records, employee salary information, or barbing information related to legal or disciplinary matters. Restricted data should be limited to access by individuals who are employed by or matriculate at Wellesley college and who have legitimate reasons for accessing such data, as governed by ferpa, or other applicable law or College policy. A reasonable level of security should be applied to this classification to ensure the privacy and integrity of this data. Public (or Unrestricted) Public data includes any information for which there is no restriction to its distribution, and where the loss or public use of such data would not present any harm to wellesley college or members of the wellesley college community. Any data that is not classified as Confidential or Restricted should be considered Public data.

wisp business plan

Otherwise obtained about a student or other third party in connection with providing a financial product or service to that person. Examples of nfi bear include: Information a consumer provides to you on an application to obtain a loan, credit card, or other financial product or service; Account balance information, payment history, overdraft history, and credit or debit card purchase information; The fact that an individual. Information from a consumer report. 3.2 Data Classification, all data covered by this policy will be classified into one of three categories outlined below, based on the level of security required for each, starting with the highest level. Confidential, confidential data refers to any data where unauthorized access, use, alteration or disclosure of this data could present a significant level of risk to wellesley college or the community. Confidential data should be treated with the highest level of security to ensure the privacy of that data and prevent any unauthorized access, use, alteration or disclosure. Confidential data includes data that is protected by the following federal or state laws or regulations: 201CMR17.00 (Mass Security regs 16 cfr 313 (Privacy of Consumer Financial Information the federal Gramm-leach-Bliley act, health Insurance portability and Accountability Act of 1996 (hipaa and the ftcs Red. Information protected by these laws includes, but is not limited to, pi, nfi and Protected health Information (PHI). Restricted Restricted data refers to all other personal and institutional data where the loss of such data could harm an individuals right to privacy or negatively impact the finances, operations or reputation of Wellesley college.

implementation of the business rules established by the data steward. A data steward is responsible for the data content and development of associated business rules, including authorizing access to the data. Personal Information, personal Information (pi as defined by massachusetts law (201 cmr.00 is the first name and last name or first initial and last name of a person in combination with any one or more of the following: Social Security number; Drivers license number. Financial account number (e.g. Bank account) or credit or debit card number that would permit access to a persons financial account, with or without any required security code, access code, personal identification number, or password. For the purposes of this Program, pi also includes passport number, alien registration number or other government-issued identification number. Nonpublic Financial Information, the glb act (ftc 16 cfr part 313) requires the protection of customer information, that applies to any record containing nonpublic financial information (NFI) about a student or other third party who has a relationship with the college, whether in paper, electronic.  For these purposes, nfi shall include any information: A student or other third party provides in order to obtain a financial product or service from the college; About a student or other third party resulting from any transaction with the college involving a financial product.

Establish administrative, technical and physical safeguards to ensure the security of sensitive data. 3.0 Scope, this Program applies to all Wellesley college employees, whether full- or part-time, including faculty, administrative staff, union staff, contract and temporary parts workers, hired consultants, interns, and student employees, as well as to all other members of the wellesley college community (hereafter referred. This program also applies to certain contracted third-party vendors (see section.6 for further information). The data covered by this Program includes any information stored, accessed or collected at the college or for College operations. The wisp is not intended to supercede any existing Wellesley college policy that contains more specific requirements for safeguarding certain types of data, except in the case of Personal Information and Nonpublic Financial Information, as defined below. If such policy exists and is in conflict with the requirements of the wisp, the other policy takes precedence. 3.1 Definitions, data, for the purposes of this document, data refers to information stored, accessed or collected at the college about members of the college community.

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Wellesley college Written Information Security Program (Note: Italicized text represents significant changes from the most recent revision).0 Policy Statement, the wellesley college Written Information Security Program (wisp) is intended as a set of comprehensive guidelines and policies designed to summary safeguard all confidential and restricted data. 2.0 overview purpose, the wisp was implemented to comply with regulations issued by the commonwealth of Massachusetts entitled Standards For The Protection Of Personal Information Of Residents Of The commonwealth 201 Code mass. 17.00, and by the federal Trade commission 16 cfr part 314, and with our obligations under the financial customer information security provisions of the federal Gramm-leach-Bliley act (GLB) (b) and 6805(b 2). In accordance with these federal and state laws and regulations, wellesley college is required to take measures to safeguard personally identifiable information, including financial information, and to provide notice about security breaches of protected information at the college to affected individuals and appropriate state agencies. Wellesley college is committed to protecting the confidentiality of all sensitive data that it maintains, including information about individuals who work or study at the college. Wellesley college has implemented a number of policies to protect such information, and the wisp should be read in conjunction with these policies that are cross-referenced at the end of this document. The purposes of this document are to: Establish a comprehensive information security program for Wellesley college with policies designed to safeguard sensitive data that is maintained by the college, in compliance with federal and state laws and regulations; Establish employee responsibilities in safeguarding data according.


Wisp business plan
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