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In
this document:
University Information and Policy
Individual
Responsibilities
Protect Personal
Information
Managing
Systems in Your Care
Computing Resources Acceptable Use Guidelines
Electronic
Communications
Copyright: Your Rights and Responsibilities
For
More Information
Related Policies
Other documents:
Protecting Personal Non-Public
Information
Security Breach
Procedures
Faculty Handbook
Computer
Security Home
University Policy Manual
IT
Help Center
UD
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University Information and Policy
The information of any organization is one of its most valuable assets. As an employee of the University of
Delaware, you have a responsibility for securing these assets. Information Security
Policy (No. 1-15) establishes employee responsibility for protecting University information from unauthorized access, modification, destruction or
disclosure. The Policy for Responsible Computing (No. 1-14) requires University students, faculty and staff to
make responsible use of computing and information resources and to guard against abuse. Together these policies form the cornerstone of responsible
computing at the University of Delaware. This manual, along with other related University
information policies, provides implementation guidelines for complying with these
requirements. If you haven't already, you need to become familiar with these policies and indicate your
understanding and compliance with them at Understanding of Employee Computing
Responsibilities and Notice of Monitoring.
Read and understand these policies and take time to see how they apply to your work
responsibilities. Ask questions if you are unsure of what is expected of you. Ask your supervisor or send
e-mail to the Help
Center.
Remember that these policies apply to you just as they apply to all other employees.
Individual
Responsibilities
When you power up the
PC on your desktop each morning, or login to work from home, you have opened
a window to University information. Responsibility for the security of that
information is not delegated to a few select departments and administrators.
If you have access to University information, you are also responsible for
securing it. You could be a weak link
in the security chain, potentially exposing the University's information system
to those who would misuse it.
At the end of the day,
when you log off from the network and then shut down your PC, you close the
window. But, a lot of the information you worked with is still in your care.
It may reside on your home or office PC, USB flash drives, CDs, or on an
office file server.
The following guidelines should be used by you to set specific practices for
your department, office or when working from home; they are not exhaustive,
but are intended to serve as a guide.
Disclosing
personally identifiable, non-public academic, financial or health information
without permission is prohibited by the University's
Information
Security Policy (No. 1-15), Personal Non-Public
Information Policy (No.1-22), and Federal laws including the Family Educational Rights and
Privacy Act (FERPA), the Gramm-Leach-Bliley Act (GLBA), the Health Insurance Portability and Accountability
Act (HIPAA), and the Disposal Rule, a part of the Fair and Accurate
Credit
Transactions Act of 2003 (FACTA). Safeguarding personal non-public
information -
especially Social Security numbers (SSNs), is also
critically important because these data pose a high risk of identity
theft or financial loss to the individual if improperly disclosed.
According to the Social Security
Administration, the SSN is
confidential and a key piece of personal information for
perpetrators of identity theft. Identity theft was the most-reported
complaint to the Federal Trade Commission in 2006, accounting for 36% of
the 675,000 complaints filed. Credit card fraud was the most common form
of reported identity theft, followed by phone or utilities fraud, bank
fraud, and employment fraud.
A spreadsheet, web site or other posting with grades, financial or medical information linked to
social security numbers or any other personally identifiable information
would violate one or more of the aforementioned laws and University
policy. The Department of Education has even ruled that using the last four digits of SSN for grade
postings violates FERPA, so no portion of the SSN can be used as an
identifier. Contact the University Registrar for more information on secure ways to post grades.
Unless required by law, or needed to
perform core departmental activities which
cannot be immediately facilitated by other means, SSNs or other high
risk personal non-public information must not be collected or stored.
Personal non-public information should not be stored on systems in your
unit. Whenever possible, centrally administered systems must be used to
retrieve, process or store personal non-public information. University
departments must re-evaluate their acquisition, use and safeguarding of
personal, non-public information for conformance to these
guidelines at least annually.
If you have personal non-public
information on your system or portable storage media it must be encrypted
and you must safeguard it
from unauthorized disclosure, alteration and destruction as outlined in
the system management section below. You are required to
notify all persons whose information may be disclosed if your system
is compromised and you have unencrypted high risk personal
non-public information stored on it. Be wary of, and verify all
requests for personal non-public information from unfamiliar persons.
Social engineering is the use of subterfuge to gain access to confidential
data. Never send or confirm personal non-public information over the
phone or by e-mail, even if the requesting party provides
it.
Managing Systems in Your Care
Unless your department has designated someone else to manage your personal computer/workstation, you are its system
administrator. As a system administrator, you are responsible for safeguarding your computer’s
stored information and for keeping it safe from unauthorized users and
processes (e.g., worms, bots, viruses, etc). You may also be responsible for a
departmental server, computing site or subnet. System administrator responsibilities
can range from a single laptop or office pc to a multi-processor server.
Each system you administer is most likely
connected directly to the internet via the University’s network. The University does not selectively
monitor, filter or block information passing over its network to maintain the
highest support for free and unimpeded exchange of scholarly
information. With that freedom comes the responsibility to protect confidential University information against the inherent
risks of being connected to a high-speed, open network.
Security Management
Basics
- Learn how to properly secure your system and its
stored data (permanently attached and removable media) from
unauthorized modification, destruction or disclosure.
An insecure system is vulnerable to being compromised, and then used
remotely to attack other machines. By keeping your system free from
hackers, you are also preventing possible accusations against yourself
and the University.
- Keep your operating system up to date
by configuring your system to automatically download and install patches.
As the administrator of your personal computer or server, you are
responsible for protecting it by keeping it up to date. Vendors,
including Microsoft, routinely release security and other critical
patches free of charge when vulnerabilities are discovered. Microsoft
NEVER sends patches by e-mail. Beware of e-mail claiming to be from
Microsoft with attached Windows patches (See
How
to Tell if a Microsoft Security-Related Message is Genuine).
Microsoft does provide an e-mail
alert service informing subscribers when security update
announcements are released.
- Use current anti-virus
software at all times, especially to scan e-mail attachments.
Information Technologies requires McAfee anti-virus software for
PCs and Macintoshes. The University has a site license for McAfee anti-virus
software that can be downloaded free of charge.
- Use a
firewall to protect your computer from unwanted, malicious probes by
other systems. It’s
like locking your doors at night to keep someone from just walking into
your home. A new,
unprotected computer can be infected within seconds of being connected
to the internet, but turning on a firewall first can protect it while
updates and current virus protection are obtained over the
internet. Windows XP has a
built-in firewall that is easily activated.
- Electronic communications
(e.g., POP or IMAP e-mail, web files, login sessions and wireless) are not routinely encrypted over the University network or when working from home.
The University's recommended web mail service is encrypted automatically. Although the
probability of an Internet e-communication being intercepted (and
falling into the wrong hands) is small, sensitive communications and
documents -e.g., those containing personal non-public
information - like Social Security numbers, credit card numbers, academic records and especially your passwords - should not be sent over the Internet
without being encrypted. Recommended encryption protocols are described in more detail in Security 101. Contact the Help Desk at 831-6000 for more
information about using encrypted protocols to secure electronic communications.
- Encrypt files
containing personal non-public information. If
the computer or removable media is compromised or stolen, the
encrypted information will be unusable
in the perpetrator’s hands. Contact the IT Help Center at x6000 for more
information on encryption software.
- The risk to sensitive
information stored on a computer increases as its exposure to people,
other computers, and the range of duties assigned to it increases. The number of users, both inside
and outside the University, connections to other computers including web surfing,
and types of applications running (e.g., database and web surfing) all
must be considered when assessing whether a system is configured to
adequately safeguard the information it contains. Be cautious of
freeware and shareware as these
programs can introduce processes that compromise your system’s
security. Peer to peer applications can be especially
dangerous if personal or confidential information resides on the
system. These applications can inadvertently disclose sensitive,
personal or confidential information residing on the host system to
anyone who finds it via a simple query. Peer to peer applications
should not be installed on any system containing PNPI. Read more...
- Choose passwords for your
computer accounts, including the administrator accounts on your PC that
are not easily guessed. Sound passwords are combinations of
letters and numbers or special characters – the longer the better.
Commit them to memory and never write them down or tell them to
anyone. If you tell someone your password or PIN, you are potentially giving that person access to
information that was entrusted specifically to you. If you write down
your password or PIN, choose a password that is easy to guess, or
transmit it in clear text when you log on from the office or from home
you run the same risk. To encrypt your password or PIN and all other
information sent to, or received from University systems, you should use
a SSH terminal
client. Contact the Help Desk at 831-6000 for more information about
using SSH to encrypt your computing sessions.
- E-mail messages may be
stored as files on centrally administered storage. The e-mail messages
you send become the possession of the receiver and can easily be
re-distributed or seen by others. In this sense, they are not private.
They are unlike face-to-face or unrecorded telephone conversations in
this regard. When the confidentiality of a message is of the utmost
importance, only a person-to-person conversation may be sufficiently
secure.
- Log off your computer when
you leave your desk, or set it up to require a password after a pre-set
amount of inactivity. Keep information displayed on your screen
confidential, just as you would keep confidential printed material on
your desk or in your files away from wandering glances.
Other
Best Practices
- Destroy sensitive, confidential or non-public
information before disposing of the media on which it is stored.
Otherwise, you subject the information on hard drives, USB flash
drives, CDs, paper forms
and reports, etc., to unauthorized disclosure. Shred paper reports and
forms that contain confidential or sensitive information and render CDs
you no longer need unreadable before disposing of them. Also be sure to
zero-fill or scrub the internal disk drive(s) of obsolete computers before
you send them to surplus Simply deleting the files does note
completely remove them from the hard drive. Deleted files can be easily
recovered with common utilities. For advanced users, the DBAN Disk Wipe Utility can be
used. Call the IT-Help Center at x6000 for assistance if you are unsure of
how to completely remove data from your hard drive before you surplus your
computer.
The Disposal
Rule of the Fair and Accurate Credit Transactions Act of 2003 (FACTA)
requires businesses and individuals to take appropriate measures to
dispose of sensitive information derived from consumer reports to protect
against "unauthorized access to or use of the information." For example,
if consumer information about students or their parents is used as part of the financial aid
process, the rule would apply. It would also apply to consumer information used in the
applicant hiring process. Similarly, if your department uses consumer information to
establish accounts for any service, this rule would apply. There are many
other instances where this information may be obtained and used on our campus, and it is
important for each department to be aware of these rules and to be in compliance.
- As an aid to better understanding responsible computing
practices,
all departments that own or lease computing equipment are encouraged to
develop "Conditions of Use" or "Guidelines for Responsible Computing"
documentation for all systems that they operate and to make these
documents available to users. These documents should be consistent with
the Policy for
Responsible Computing at the University of Delaware and should be
approved by the department's administrative officer or other individual
designated by that administrative officer.
- Back up your data regularly and know how to restore it. Several
generations of backups are recommended. Backups must be available, so
store them where others know where they are and can access them.
University Archives can offer
assistance.
- Lock copies of your data on
removable media or printed reports in your desk or a fire-resistant
cabinet. Portable USB flash drives and other compact storage
technologies have enough capacity to back up enormous amounts of
institutional data. Highly sensitive or confidential institutional data
stored on removable media must be encrypted.
- Your electronic data files
are subject to the same records retention requirements as paper records.
Consult with University
Archives to make certain your electronic records are included in
your Records Retention program.
- Routinely delete e-mail
messages that do not need to be saved.
- Ensure that all software
license agreements are in place.
- Grant access to users on a need-to-know
basis, and remove access and user profiles when they are no longer
needed.
For additional assistance with
managing your system, contact your department's CITA or call the IT-Help Center at 831-6000.
Computing Resources Acceptable Use Guidelines
Employees are expected
to be responsible in their use of computing resources in accordance with the University of Delaware mission and in compliance with
its policies and all applicable laws and regulations. This principle is the
basis for the following general acceptable use guidelines:
- Be considerate of other
users. Do not run processes or engage in network activity which denies
others the use of shared resources.
- Respect the integrity of
the University network. Improperly configured or inappropriate processes
running on your system can have a destabilizing effect on the network.
The University reserves the right to constrain and remove applications,
services or improperly configured systems which may be negatively
impacting network performance.
- Respect the intellectual
property rights of others. See Copyright: Your Rights and
Responsibilities for more information.
- Abide by the principles of
decency, fairness and respect for the rights of others – e.g., the
right to privacy and confidentiality.
University policies
prohibit certain activities:
- Using University computing
resources for non-University commercial activities, fund-raising,
partisan political purposes, or on behalf of organizations not
affiliated with the University. The State-created University Charter prohibits the
Management of the University to benefit any party, sect or denomination.
Employees may choose to participate in any of the above activities but
cannot use University resources to support their personal activities.
- Using any University
computer, facility, equipment, software, network or other resource
including e-mail without authorization or for any activity other than
that for which access or use was assigned or authorized.
- Sending chain letters, pyramid
scheme messages, spam or engaging in any behavior which wastes resources
or is disruptive to the network.
- Sending sexually explicit,
offensive, demeaning, insulting or intimidating e-communications, ethnic
or racial slurs or anything that harasses or disparages others. Sending
such messages is grounds for disciplinary actions, including
termination.
- Violating copyright, trademark, or
other laws or regulations in sending e-communications, publishing web
pages or posting to newsgroups and discussion lists.
- Using University of Delaware institutional mail lists
without appropriate authorization.
- Intentional, unauthorized access to or
interception of information or e-communications. The ability to access
information or intercept e-communications does not inherently include
authorization to do so.
- Altering, destroying or forging
e-communications or intentionally compromising the integrity of the
network.
The University's Policy for
Employees' Use of Electronic Communications (No.1-19) establishes the applicability
of existing University policies and federal, state and local law to
electronic communications, including requirements for good electronic
citizenship and expectations for privacy. Generally, the University will not
make any efforts to monitor e-communications except when required by law or
to investigate any policy infraction. If you haven't already, you need to
become familiar with these current policies and indicate your understanding
and compliance with them at Understanding
of Employee Computing Responsibilities and Notice of
Monitoring.
Electronic
Communications
At the University of Delaware, electronic mail (e-mail) and
the University's web sites offer efficient, cost-effective communication
between members of the University community. In fact, e-mail is
- An official communication
channel for University departments and employees;
- An official communication
channel between the University (departments, faculty, and staff) and its
students.
As a result, every
employee must
- Have an account on the University's central mail server (udel.edu);
- Be responsible for receiving
and reading any official communication sent to his or her
"udel.edu" account.
Therefore, every
employee must do the following:
- Read your e-mail in a
timely fashion.
- If you choose to use
software to sort your incoming e-mail into folders or to filter out
unsolicited advertising e-mail (SPAM), you are responsible for making
sure that your filter rules do not accidentally delete official
University correspondence.
- If you choose to forward
your e-mail from udel.edu to another e-mail server--either to a
departmental server or to an off-campus ISP's server--you are
responsible for making sure that your e-mail forwarding is working so
that you can continue to receive and read your University e-mail in a
timely fashion.
Commercial E-mail
If your department
sends e-mail that might be construed as commercial - i.e., a commercial
advertisement or promotion of a commercial product or service, you might be
subject to the 2003
CAN-SPAM Act. Any commercial e-mail must include the following
information:
- Identification of the e-mail as an
advertisement from your University department or group. Make it clear
that it is coming from a sub-part of the University and not the
University as a whole;
- A valid postal address for
your department;
- Accurate identification of
the sender in the "From" line of the e-mail;
- A subject line that is
consistent with the e-mail's message;
- Instructions to opt-out of future
e-mails from your University department or group.
This information can appear
anywhere in the e-mail. An easy way to meet these requirements without
re-writing your communication is to attach a standard signature block at the
bottom of the e-mail.
Additionally, opt-out
requests must be handled in the following manner:
- Can be a return e-mail
address or web site;
- Must be able to process
opt-outs for 30 days after the commercial e-mail was transmitted;
- Must be honored within 10
days after receipt and are effective indefinitely;
- Cannot disclose recipients e-mail
address to a third party.
For more information
see the FTC
web site.
Commercial
Facsimiles
The Federal Communications Commission (FCC) is responsible for enforcing the Junk Fax Prevention Act, which was signed into law July 9, 2005 (S. 714).
Effective August 1, 2006, the FCC's rules take effect that bar unsolicited advertisements subject to certain exemptions.
Facsimiles that advertise the availability or quality of any property, goods or services cannot be legally sent without prior
express invitation or permission of the recipient, or if there is an established business relationship (EBR) between the sender
and recipient. An EBR customer can receive facsimile advertisements if one or more conditions are met - e.g.,
if the customer provides it on an application or other form, or if it is published in a directory without noting
that unsolicited facsimiles are not accepted.
Also, the FCC's rules require that facsimile advertisements include contact information that allows recipients
to op-out of future faxes from the sender. Valid opt-out requests must be honored within the shortest reasonable
time from receipt - not to exceed 30 days.
These commercial communication rules may apply to activities in your department.
Consider the types of communications you send outside the University and determine if they are governed by these two laws.
Examples include
- Alumni or student membership renewals,
- Ticket sales for athletic or performing arts events,
- Solicitations for printed advertising space,
- Advertisements for courses, seminars and conferences.
For more information see the FCC web
site.
Copyright: Your Rights and
Responsibilities
From the 1987 EDUCOM
Code for Software and Intellectual Rights:
Respect for
intellectual labor and creativity is vital to academic discourse and
enterprise. This principle applies to works of all authors and publishers in
all media. It encompasses respect for the right to acknowledgment, right to
privacy and right to determine the form, manner and terms of publication and
distribution.
Because electronic
information is volatile and easily reproduced, respect for the work and
personal expression of others is especially critical in computer
environments. Violations of authorial integrity, including plagiarism,
invasion of privacy, unauthorized access, and trade secret and copyright
violations, may be grounds for sanctions against members of the academic
community.
These principles still
hold true. However, in today’s rapidly changing technological
environment, higher education institutions increasingly find themselves at
the center of the ongoing digital copyright debate which seeks to balance the
rights of copyright holders with users of creative works. Copyright law
sets the rules for who can make copies of creative works (versus facts and
ideas), and how they can be used. Examples of intellectual property include
books, movies, manuscripts, audio recordings, pictures and software.
It is essential that
all members of the University community understand their rights and
responsibilities regarding copyright laws. University policy and copyright
laws prohibit the unauthorized use, transmission, copying and storing of copyrighted
works. However, the University encourages the use of electronically
transmitted information within the "Fair Use" guidelines of the
copyright law or with the permission of the author.
The 1998 Digital
Millennium Copyright Act (DMCA) amended Title 17 United States Code, in
anticipation of the World Intellectual Property Organization (WIPO) Copyright
Treaty. The DMCA set forth legal provisions for fair use in a digital
environment, circumvention of technical protection measures, and other
copyright issues pertinent to digital environments. The 2001 Technology
Education, and Copyright Harmonization (TEACH) act extended digital fair use
provisions by allowing accredited non-profit educational institutions to
provide copyrighted materials to students enrolled in “mediated
instructional activities”, e.g., distance education, under limited
circumstances via the Internet without obtaining permissions from copyright
holders. The rights embodied in the TEACH act are contingent upon
“reasonable” technological protection measures (e.g., restriction
to enrolled class roster via passwords, availability for a limited duration,
notice to students that the materials are subject to copyright restrictions,
etc.) to prevent the unauthorized re-distribution and /or retention of
copyrighted materials, and other requirements.
Resources for learning
more about copyright law and how it affects you can be found at the following
locations:
The University of Delaware Library
Copyright Subject Guide contains an extensive
list of copyright resources.
How to use MyCourses
to incorporate copyrighted materials into coursework. Also, in order to take UD
Online courses students are required to agree to a copyright
license agreement. This agreement outlines the obligations of the student
(user) and the limitations of liability.
The Center for Teaching Effectiveness can
assist with navigating digital copyright issues in curriculum.
For More Information
Faculty Handbook
Computer Security at UD
University Policy Manual
Related Policies
The following
University policies define your role in, and responsibilities for protecting
University information.
- The Information Security
Policy (No. 1-15) establishes employee responsibility for protecting
University information from unauthorized access, modification,
destruction or disclosure. This includes all University information and
media types, from printed reports to e-mail saved on your PC to
published web pages.
The policy states that all employees are responsible for protecting University
information and that each department is required to make protection of this
information a part of its overall business plan.
The Policy for
Responsible Computing (No. 1-14) requires University students,
faculty and staff to make responsible use of computing and information
resources and to guard against abuse.
The Electronic Record
Keeping Policy (No. 1-13) makes it the responsibility of each
department to establish standards for electronic file organization,
measures for protecting sensitive information stored electronically and
procedures for file backup.
This
policy extends to electronic records the requirements of the University Archives and
Records Management Program (No. 1-10), which governs records retention,
vital records protection and filing practices and techniques as they pertain
to paper files.
The Policy for
Employees' Use of Computing Resources for Web Pages (No. 1-16)
governs the use of University computing resources by employees for home
pages. This policy applies to all University full-time, part-time and miscellaneous
wage employees.
The Policy for
Electronic Mail Management and Retention (No. 1-18) advises
University employees and departmental managers of their responsibilities
regarding the creation of e-mail messages, the routine deletion of
e-mail and the retention of e-mail messages that are official University of Delaware records.
The Policy for
Employees' Use of Electronic Communications (No. 1-19) establishes
the applicability of existing University policies and federal, state and
local law to electronic communications (e-communications), including
expectations for privacy and requirements for good electronic community
citizenship.
The Policy for Wireless
Computing at the University of Delaware (No. 1-20) regulates campus
wireless airspace to ensure its fair and efficient allocation and to
prevent collision, interference, and failure.
The Policy for Use of
University Owned Mailing Lists (No. 1-21) regulates the use of
University owned mailing lists for those purposes determined to be in
the best interest of the University.
The Personal Non-Public
Information Policy (No. 1-22) expands on the Information Security
Policy #1-15 to
establish requirements for protecting personal, non-public information and
notifying individuals whose personal, non-public information may have been
disclosed by computer security breaches.
The Credit Card
Policy (No.
3-26) defines the minimum technical criteria that must be met for
University departments to receive credit card information over the web.
The Family Educational
Rights and Privacy Act (No. 4-20), or FERPA, requires the University
protect the confidentiality of student educational records. These
include academic, financial, disciplinary, medical and counseling office
records.
To be in compliance, the University must obtain the written consent of a student
before disclosing information. A student’s right to see his or her
records does not extend to parents or guardians.
The
University may not release directories, rosters, lists
or address labels of students to parties not affiliated with the University. University policy prohibits posting grades and test scores
publicly using any personally identifiable information, including the last 4
digits of the social security number.
The Policy for
Copyrightable Material (No. 6-07) defines the general principles and
administrative responsibilities and procedures for establishing and
safeguarding intellectual property developed by University faculty and
staff.
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