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Information Security Program Policy

Policy Information

PDF version
Effective Date: 
May 7, 2019
Last Revised Date: 
May, 2019
Policy Number: 
ISO-100
Responsible Unit: 
Information Security Office
Phone: 
(520) 621-6700

Purpose and Summary

This document establishes the Information Security Program Policy for the University of Arizona. This policy provides an outline to ensure ongoing compliance with policy and regulations related to the Program and positions the University to address future changes in the information security landscape, including new or amended regulations.

Scope

This policy applies to all Information Systems and Information Resources owned or operated by or on behalf of the University. All University-Related Persons with access to University Information or computers and systems operated or maintained on behalf of the University are responsible for adhering to this policy.

Definitions

CISO: The senior-level University employee with the title of Chief Information Security Officer.

Information Resources: University Information and related resources, such as equipment, devices, software, and other information technology.

Information Security Incident: An occurrence that actually or potentially jeopardizes the confidentiality, integrity, or availability of an Information System or the information the system processes, stores, or transmits or that constitutes a violation or imminent threat of violation of information security policies, information security procedures, or acceptable use policies.

Information Security Risk Manager: An individual designated by the supervisor of a Unit (e.g., a Vice President, Dean, Director, Department Head, or Head of a center or other office) to be responsible for managing an organization's information security risks and minimizing the adverse impact of losses on the achievement of organizational objectives.

Information System: A major application or general support system for storing, processing, or transmitting University Information. An Information System may contain multiple subsystems. Subsystems typically fall under the same management authority as the parent Information System. Additionally, an Information System and its constituent subsystems generally have the same function or mission objective, essentially the same operating characteristics, the same security needs, and reside in the same general operating environment.

ISO: The University's Information Security Office, responsible for coordinating the development and dissemination of information security policies, standards, and guidelines for the University.

IT Security Manager: An individual designated by the supervisor of a Unit (e.g., a Vice President, Dean, Director, Department Head, or Head of a center or other office) to serve as the primary contact between the respective Unit and the ISO for all matters relating to information security.

Unit: A college, department, school, program, research center, business service center, or other operating Unit of the University.

University Information: Any communication or representation of knowledge, such as facts, data, or opinions, recorded in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual, owned or controlled by or on behalf of the University.

University-Related Persons: University students and applicants for admission, University employees and applicants for employment, Designated Campus Colleagues (DCCs), alumni, retirees, temporary employees of agencies who are assigned to work for the University, and third-party contractors engaged by the University and their agents and employees.

Policy

The CISO, on behalf of the University shall, taking a University-wide approach, develop and maintain an Information Security Program to preserve the confidentiality, integrity, and availability of University Information Resources.

As part of this program, ISO shall, at the direction of the CISO:

  • define information security policies, standards, processes, and procedures designed to provide insight into, and assurance of, the security posture of the University;
  • support the University‚Äôs mission through appropriate information security governance and reporting;
  • coordinate and oversee regular risk management and security planning activities for existing and planned Information Resources;
  • implement Information Security Incident response planning, execution, and notification procedures; and
  • enforce information security policy and regulatory compliance through a risk-informed, compliance validation program.

Each Unit shall protect University Information Resources by adhering to, adopting, and implementing information security policies, standards, processes, and procedures as defined and developed by the CISO. All Units must meet the minimum standards appropriate to the information security risk of the Unit, including but not limited to:

  • identifying the Information Owners and Information System Owners for each Information Resource for which the Unit has any responsibility;
  • designating one or more Information Security Risk Manager(s) and IT Security Manager(s) within the Unit to work in collaboration with ISO and on behalf of Information Owners and Information System Owners;
  • empowering and enabling the Information Owners and Information System Owner to make risk tolerance decisions and risk handling decisions that are appropriate given the information security risk to the owned Information Resources; and
  • ensuring Information Owners, Information System Owners, Information Security Risk Managers, and IT Security Managers, designated by the Unit, fulfill their respective obligations defined by ISO policy, standards, processes, and procedures.

Units are encouraged to adopt standards that exceed the minimum requirements for the protection of University Information Resources.

Compliance and Responsibilities

Compliance

Tracking, Measuring, and Reporting

ISO shall initiate mechanisms for tracking compliance with this policy and shall produce reports representing these measures to support University decision making.

Recourse for Noncompliance

ISO is authorized to limit network access for individuals or Units not in compliance with information security policies (including this one) and related procedures. In cases where University resources are actively threatened, the CISO shall act in the best interest of the University by securing the resources in a manner consistent with the Information Security Incident Response Plan. In an urgent situation requiring immediate action, the CISO is authorized to disconnect affected individuals or Units from the network. In cases of noncompliance with this policy, the University may apply appropriate employee sanctions or administrative actions, in accordance with relevant administrative, academic, and employment policies. 

Exceptions

Requests for exceptions to information security policies (including this one) may be granted for Information Systems with compensating controls in place to mitigate risk. Any requests must be submitted to the CISO for review and approval pursuant to the exception procedures published by the CISO.

Frequency of Policy Review

The CISO shall review information security policies and procedures annually, at minimum. This policy is subject to revision based upon findings of these reviews.

Responsibilities

University-Related Persons

All University-Related Persons are responsible for complying with this policy and, where appropriate, supporting and participating in processes related to compliance with this policy.

Information Owners and Information System Owners

Information Owners and Information System Owners are responsible for implementing processes and procedures designed to provide assurance of compliance with the minimum standards, as defined by ISO, and for enabling and participating in validation efforts, as appropriate.

Chief Information Security Officer

ISO shall, at the direction of the CISO:

  • identify solutions that enable consistency in compliance and aggregate and report on available compliance metrics;
  • develop, establish, maintain, and enforce information security policy and relevant standards and processes;
  • provide oversight of information security governance processes;
  • educate the University community about individual and organizational information security responsibilities;
  • measure and report on the effectiveness of University information security efforts; and
  • delegate individual responsibilities and authorities specified in this policy or associated standards and procedures, as necessary.

Vice Presidents, Deans, Directors, Department Heads, and Heads of Centers

All Vice Presidents, Deans, Directors, Department Heads, and Heads of Centers shall take appropriate actions to comply with information technology and security policies. These individuals have ultimate responsibility for University resources, for the support and implementation of this policy within their respective Units, and, when requested, for reporting on policy compliance to ISO. While specific responsibilities and authorities noted herein may be delegated, this overall responsibility may not be delegated.

Revision History*

Replaces Interim policy of 3/19/19

* Please note that sections titled Frequently Asked Questions, Related Information, and Revision History are provided solely for the convenience of users and are not part of the official University policy.

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