The purpose of this policy statement is to establish the requirements necessary to prevent or minimize accidental or intentional unauthorized access or damage to university information resources. This policy balances the responsibility for information security with the need to foster an open and information-sharing atmosphere among members of the academic community.
This policy applies to all university students, faculty and staff, affiliates, third-party support contractors, and all others granted access to NIU information resources. All users of information resources bear responsibility for the protection of those assets. Based on system and information classification categories defined in this policy, some categories of users have a greater burden of responsibility and accountability than others.
This policy pertains to all university information resources, whether the resources are individually or departmentally controlled, enterprise managed, stand-alone or networked. It applies to all computer and communication facilities owned, leased, operated or contracted by the university, networking devices, personal digital assistants, telephones, wireless devices, workstations, mainframes, minicomputers, portable storage devices and any associated peripherals and software, whether used for administrative, research, teaching or other purposes. It applies to personal computers that are used to access, store or maintain university information. This policy also pertains to hard-copy documents that are classified under these guidelines.
Section headings are:
The purpose of information security is to protect the information resources of the university from unauthorized access or damage. The underlying principles followed to achieve this objective are:
All university information, including electronic and hard-copy records, is assigned to stewards, who classify it by the level of sensitivity and risk. These classifications take into account the legal protections (by statute or regulation), contractual agreements, ethical considerations and proprietary worth. Information can also be classified as a result of the application of “prudent stewardship,” where a legal mandate to protect such information is lacking, but reasonable discretion may be required in its disclosure, as in the Sensitive Information classification described below.
The classification level assigned to information guides information stewards, end users, business and technical project teams, and others who may obtain or store information, in the security protections and access authorization mechanisms appropriate for that information.
Information classifications are as follows:
Relationship to Personal Information Security
Data that contains personally identifiable information (PII), mandates that a higher level of security must be applied for its protection. As information becomes more anonymous and there is less personally identifiable information, then less rigorous measures are required.
Relationship to Other Information Assets
When the appropriate level of protection is determined, that same level of protection shall be applied to all other related information in whatever format, wherever retained (e.g., servers, network segments, desktop computers, mobile devices and storage devices such as jump drives, CD or DVD, and physical storage units such as rooms/spaces, desk drawers and file cabinets).
The retention and destruction of information and records are governed by federal and state legal standards (such as, the Illinois State Records Act). To determine specific security safeguards for each information classification, consult the NIU Information Security Procedures.
Adherence to the principles of information security set forth in this policy requires the participation and involvement of the entire university community. In particular, state law mandates that the university notify individuals when there is a breach of the security of system information or written material which contains their “personally identifiable information,” as defined by the law. Because of the legal requirement to protect this information, such personal information should be treated as Restricted Information. NIU employees who are aware of any attempted or actual breach are required to report the incident to the Information Security Office at 815-753-8100 for investigation and potential breach notification.
Within the framework of these principles, the responsibilities of those in key positions, as well as other members of the campus community, are as follows:
University systems, both hardware and software, are classified by scope and level of support and by impact on university operations. The classification of systems takes into account legal protections (by statute or regulation), contractual agreements, ethical considerations, and strategic or proprietary worth of information maintained in such systems. The classification level assigned to systems will guide system and data stewards, and business and technical project teams in the security protections and access authorization mechanisms appropriate for those systems. Such categorization provides the basis for planning, allocation of resources, support, and security/ access controls appropriate for those systems.
The system classifications are as follows:
Information and records, whether maintained in electronic files or on paper, must be stored and disposed of securely, in accordance with the State Records Act and the Electronic Commerce Security Act, ref. 5 ILCS 160/17; and P.A. 90-759, sect. 5-135(a)(1).
NOTE: Pursuant to applicable State and/or Federal requirements (e.g. Federal Rules of Civil Procedure, etc.) ALL information and records subject to a litigation hold must be retained in whatever format the information is in and in whatever classifications notwithstanding other general policies on retention.
Violations of this policy include, but are not limited to: accessing information to which the individual has no authorization or business purpose; enabling unauthorized individuals to access information; disclosing information in a way that violates applicable restricted access or confidentiality procedures, or handling or using information contrary to any other relevant regulations or laws; inappropriately modifying or destroying information or university business records; inadequately protecting Restricted Information or Sensitive Information; or ignoring the explicit requirements of information stewards for the proper management, use and protection of information resources. In coordination with divisional authorities, violations may result in network removal, access revocation, corrective action, university disciplinary action and/or civil or criminal prosecution, if applicable. Should disciplinary action be implemented, up to and including dismissal, suspension or expulsion, such actions will be taken pursuant to applicable university policies and procedures.
Divisional authorities will be notified in the event that a university office or department is found to have generally violated this policy (beyond actions taken by an individual employee). Corrective actions and possible financial costs associated with an information security incident will be coordinated at the division level.
Third-party vendors and/or consultants found to have breached their respective agreements with the university may be subject to consequences, including but not limited to, the loss of third-party vendor/consultant access to university information technology resources, removal of the vendor/consultant from university facilities, termination/cancellation of the agreement, payment of damages, and criminal or civil charges based on the nature of the violation.
The university is sometimes required to transmit information by state or federal forms and formats. When using such forms and formats, university employees should transmit such information following university policy and utilize appropriate safeguarding and security measures in the transmission of that information. It is important to work with state and federal officials in striving to meet industry best practices in the transmission of information.
In some instances the university is mandated to disclose, or authorized to release information that would normally be protected under this policy. Examples include, but are not limited to, disclosures pursuant to state or federal reporting requirements, legal process (such as subpoenas, court orders, warrants, etc.), disclosures pursuant to the Illinois Freedom of Information Act (FOIA), and certain authorized releases of information about particular individuals (students, employees or customers).
Any employee or affiliate of the university who is served with a legal document (for example, a subpoena, summons, court order, warrant, etc.) that refers to university records or data shall notify University Legal Services immediately and prior to the release of any requested information. University Legal Services will review the legal document to determine the validity and enforceability of the document, and to provide guidance and assistance in properly responding.
Legal documents that are addressed to a particular person should be accepted only by that person. If an unintended recipient is served with the legal document, it should not be accepted. The process server or deliverer should be referred to the person identified on the document, by name, title or job description, or should be directed to University Legal Services.
All requests for access to or release of records or data under the Illinois Freedom of Information Act (FOIA) should be referred to the Freedom of Information Officer within University Legal Services for appropriate review of the request. FOIA requests must be in writing. University Legal Services will coordinate the collection of information that is properly responsive to the request, especially when information from multiple university offices is requested.
Requests from External Entities and Persons, including Law Enforcement and Attorneys
The university receives numerous requests for information and records maintained by the university from persons and entities that are external to the university. The release of information about a particular person may require authorization by that person. Publicly available information about individuals and other types of information that can be released are available at the university’s web pages: http://www.niu.edu. University Legal Services and the Office of Public Affairs are available to assist with evaluating the validity and scope of any authorization provided for the release of information, as well as providing guidance for appropriately responding to information requests pursuant to an authorization.
External law enforcement agencies sometimes request information. Before responding to these requests, University Legal Services and the Department of Public Safety should be contacted to determine the authenticity of the request and the requestor. In addition, any request for information from an attorney, whether by legal process or not, should be immediately referred to University Legal Services.
All other requests for information from outside entities or persons should be evaluated on a case-by-case basis. University Legal Services and the Office of Public Affairs are available for assistance in this area. For identifying information or data stored in an electronic format at NIU, the Information Security Office is available for assistance.
The duties and responsibilities of university employees with regards to information protection and safeguarding are defined by numerous documents, including but not limited to, state and federal laws and regulations, university policies and procedures, and industry standards and best practices. Since information security is a growing and evolving area, the Information Security Office, with cooperation from University Legal Services, will constantly monitor for new developments and maintain a listing of relevant resources on this topic.
Northern Illinois University (NIU) Information Security Policy