Policies Security Plan for Confidential Information

This security plan describes Westmont’s safeguards to protect confidential information belonging to students, staff, alumni, donors and to visitors and users of its websites and servers.  In accordance with the Family Educational Rights and Privacy Act of 1974, the Gramm Leach Bliley Act, the Health Insurance Portability Accountability Act, and the European Union General Data Protection Regulations, Westmont implements the following policies and procedural safeguards to insure the security and privacy of confidential information.

Scope of Confidential Information Covered

The Family Educational Rights and Privacy Act

The Family Educational Rights and Privacy Act (“FERPA”) vests students with certain rights, and the college with certain responsibilities regarding educational records. The college maintains the privacy of student educational records and generally, unless permitted by specific legal exception, will not disclose information from those records without the student’s consent.  The college publicizes annual notice to students of their rights under FERPA.^[1]

Gramm Leach Bliley Act

The Gramm Leach Bliley Act (“GLB”) is aimed at ensuring the safeguarding and confidentiality of “nonpublic personal information”, handled or maintained by or on behalf of the college; whether in paper, electronic or other form, in the course of offering a financial product or service, such as a student loan.^[2]   

Health Insurance Portability Accountability Act

The Health Insurance Portability and Accountability Act (HIPAA) requires Westmont College to adhere to policies regarding employee’s private health information.  HIPAA requires Westmont to maintain the privacy of your Protected Health Information (PHI).  We protect your PHI from inappropriate use or disclosure. Our employees, and those companies that help us service employee benefits, are required to comply with our requirements that protect the confidentiality of PHI. They may look at PHI only when there is an appropriate reason to do so, such as to administer the plans.  We will not disclose PHI to any other company for their use in marketing their products. However, we will use and disclose PHI for business purposes relating to employee benefits.^[3]

European Union General Data Protection Regulations

The European Union General Data Protection Regulations (GDPR) requires Westmont to establish and maintain certain safeguards to protect the confidentiality of “personal data” processed and collected in connection with the offering of services and goods to individuals located in the European Union and will provide for certain rights for affected individuals consistent with the GDPR’s requirements.^[4]

This Information Security Plan provides mechanisms to:

• Ensure the security and confidentiality of covered data and information;
• Protect against anticipated threats or hazards to the security or integrity of such information;
• Protect against unauthorized access to or use of covered data and information that could result in substantial harm or inconvenience to any customer or student;
• Identify and assess the risks that may threaten covered data and information maintained by the College;
• Train employees on maintaining the privacy of covered data;
• Implement and review the plan; and
• Adjust the plan to reflect changes in technology, the sensitivity of covered data and information and internal or external threats to information security.

Identification and Assessment of Risks to Confidential Information

Westmont recognizes that it has both internal and external risks to the security of information covered under this policy. These risks include, but are not limited to:

• Unauthorized access to covered data and information and educational records by someone other than the owner of the covered data and information;
• Compromised system security as a result of system access by unauthorized persons;
• Interception of data during transmission;
• Loss of data integrity;
• Physical loss of data in a disaster;
• Errors introduced into the system;
• Corruption of data or systems;
• Unauthorized access of covered data and information by employees;
• Unauthorized requests for covered data and information;
• Unauthorized access through hardcopy files or reports; and
• Unauthorized transfer of covered data and information through third parties. 

The College recognizes that this may not be a complete list of the risks associated with the protection of covered data and information. Since technology growth is not static, new risks are created regularly. Accordingly, the Chief Information Officer, in consultation with College Counsel, and the Vice President for Administration will actively monitor advisory groups such as the Educause Security Institute, for identification of new risks. 

The College believes that IT’s current safeguards are reasonable and, in light of current risk assessments and the College’s compliance with procedural safeguards under the laws covered under this policy and any applicable state privacy laws, are sufficient to provide security and confidentiality to covered data and information maintained by the College. Additionally, these safeguards protect against currently anticipated threats or hazards to the integrity of such information.

Design and Implementation of Safeguards Program

Security Plan Coordinators

The Vice President for Administration, in consultation with the Chief Information Offier and College Counsel, will serve as the coordinator of this Plan. Together, they will assess the risks associated with unauthorized transfers of covered data and information and educational records and implement procedures to minimize those risks to the College.

Employee Management and Training

The College checks references of new employees working in areas that regularly work with covered data and information and educational records (e.g. Business Office, Registrar, Development and Financial Aid).

During employee orientation, each new employee in these departments will receive proper training on the importance of confidentiality of student records, student financial information, and other types of covered data and information. Each new employee is also/will also be trained in the proper use of computer information and passwords. Training also includes controls and procedures to prevent employees from providing confidential information to an unauthorized individual, including “pretext calling”^[5] and how to properly dispose of documents that contain covered data and information. Each department responsible for maintaining covered data and information will be instructed to take steps to protect the information from destruction, loss or damage due to environmental hazards, such as fire and water damage or technical failures. Further, each department responsible for maintaining covered data and information will work with the Vice President for Administration and College Counsel on an annual basis to coordinate and review additional privacy training appropriate to the department. These training efforts should help minimize risk and safeguard covered data and information security.

Physical Security

The College has addressed the physical security of educational records and covered data and information by limiting access to only those employees who have a business reason to know such information or a legitimate educational interest in the information as defined by the Family Educational Rights and Privacy Act.  Loan files, account information and other paper documents are kept in file cabinets, rooms or vaults that are locked each night. Only authorized employees know combinations and the location of keys.  Paper documents that contain covered data and information are shredded at time of disposal.

Information Systems

Access to educational records and covered data and information via the College’s computer information system is limited to those employees who have a business reason to know or a legitimate educational interest in the information.  Each employee is assigned a user name and password. Databases containing personal covered data and information, including, but not limited to, accounts, balances, and transactional information, are available only to College employees in appropriate departments and positions.

A computer on campus has access to the network.  Access to the College network from the modem pool is validated before getting network access.  Any gaining access from the Internet passes through a fire wall to limit the resources they can access.  Most users from the Internet are restricted to the public information available on the web site.

Services such as email are protected by requiring a potential user to provide a valid user identification and password.  If a user does not have a valid combination of user identification and password, they are not given access.  This method is used for services and information which are not considered public.  This is the case for all data stored on our administrative server where financial data is stored.   In addition, administrative data is further protected in that once a user provides a valid user identification and password combination, they are only shown data which is relevant to their function. 

When commercially reasonable, encryption technology will be utilized for both storage and transmission. All covered data and information will be maintained on servers that are behind the College’s firewall. All firewall software and hardware maintained by IT will be kept current.

Selection of Appropriate Service Providers

Due to the specialized expertise needed to design, implement, and service new technologies, vendors may be needed to provide resources that the College determines not to provide on its own. In the process of choosing a service provider that will maintain or regularly access covered data and information, the evaluation process shall include the ability of the service provider to safeguard confidential financial information. Contracts with service providers will include one or more the following provisions:

• An explicit acknowledgement that the contract allows the contract partner access to confidential information;
• A specific definition or description of the confidential information being provided;
• A stipulation that the confidential information will be held in strict confidence and accessed only for the explicit business purpose of the contract;
• An assurance from the contract partner that the partner will protect the confidential information it receives according to commercially acceptable standards and no less rigorously than it protects its own confidential information;
• A provision for the return or destruction of all confidential information received by the contract provider upon completion or termination of the contract;
• An agreement that any violation of the contract’s confidentiality conditions may constitute a material breach of the contract and entitles the College to terminate the contract without penalty; and
• A provision ensuring that the contract’s confidentiality requirements shall survive any termination agreement.

Notification of Security Incidents

Westmont shall notify the owner or licensee of confidential information of any breach of the security of covered data and information immediately following discovery, if the information, was, or is reasonably believed to have been, acquired by an unauthorized person. 

Continuing Evaluation and Adjustment

This Information Security Plan will be subject to periodic review and adjustment.  Continued administration of the development, implementation and maintenance of the program will be the responsibility of the Vice President for Administration in consultation with College Counsel who will review the standards set forth in this policy and recommend updates and revisions as necessary.  It may be necessary to adjust the plan to reflect changes in technology or law, the sensitivity of student/customer data and internal or external threats to information security.