Draft Information Security Plan July 1, 2023

This plan is subject to review and approval by the University Leadership Team.

I.   The designated employee for the coordination and execution of the

information security plan is the Director of Information Technology.  All correspondence and inquiries should be directed to Information Technology.

II.  The following have been identified as relevant areas to be considered when assessing the risks to customer information:

Information Technology

ID Card Office

Finance Office

Human Resources

Bursar’s Office

Admissions

Registrar's Office

Financial Aid Office

Residence Life

Eagle Care

Employees of each area will be required to undergo regular information security training.

III.  The Director of Information Technology will coordinate with the Chief Financial Officer and Legal Counsel to maintain the information security program.  The Director of Information Technology will provide guidance in complying with all privacy regulations. Each relevant area is responsible to secure customer information in accordance with all privacy guidelines.  The information technology department will maintain and provide access to policies and procedures that protect against any anticipated threats to the security or integrity of electronic customer information and that guard against the unauthorized use of such information.

IV.  Spalding University will select appropriate service providers that are given access to customer information in the normal course of business and will contract with them to provide adequate safeguards.  In the process of choosing a service provider that will have access to customer information, the evaluation process shall include the ability of the service provider to safeguard customer information.  Contracts with service providers shall include the following provisions:

an explicit acknowledgment that the contract allows the contract partner access to confidential information;

a specific definition 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;

a guarantee from the contract partner that it will ensure compliance with the protective conditions outlined in the contract;

a guarantee from the contract partner that it will protect the confidential information it accesses according to commercially acceptable standards and no less rigorously than it protects its own customers’ confidential information;

a provision allowing for the return or destruction of all confidential information received by the contract partner upon completion of the contract;

a stipulation allowing the entry of injunctive relief without posting bond in order to prevent or remedy breach of the confidentiality obligations of the contract;

a stipulation that any violation of the contract's protective conditions amounts to a material breach of contract and entitles Spalding University to immediately terminate the contract without penalty;

a provision allowing auditing of the contract partners' compliance with the contract safeguard requirements; and

a provision ensuring that the contract’s protective requirements shall survive any termination agreement.

V.  This information security plan shall be evaluated and adjusted in light of relevant circumstances, including changes in the university's business arrangements or operations, or as a result of testing and monitoring the safeguards.  Periodic auditing of each relevant area's compliance shall be done annually.  Annual risk assessment will be done through the Information Technology Department.  Evaluation of the risk of new or changed business arrangements will be done through the legal counsel's office.