Saint Mary's University of Minnesota Information Security Program
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Saint Mary’s University of Minnesota Information Security Program 2020-2021 This document contains confidential information for Saint Mary’s University of Minnesota Official Use Only. It shall not be disclosed in whole or in part without consent from the Executive Vice President and CFO.
Contents Executive Summary 2 1. Program Scope and Details 4 1.1 Department Overview ................................................................................................................... 4 1.2 IT Staff Responsibilities and Contact Information ......................................................................... 4 2. Hardware Info 4 2.1 Overall Network Configuration ...................................................................................................... 4 2.2 Physical and Environmental Protection ........................................................................................ 5 2.3 Hardware ....................................................................................................................................... 7 3. Data and Software 7 3.1 Software ........................................................................................................................................ 7 3.2 Data Flow/Integrations .................................................................................................................. 8 3.3 Data Categorization ...................................................................................................................... 8 3.4 Report Requests ........................................................................................................................... 8 4. System Security Controls 8 4.1 Onboarding process ...................................................................................................................... 8 4.2 Offboarding process ...................................................................................................................... 8 4.3 Password Policies ......................................................................................................................... 9 4.4 Access Control .............................................................................................................................. 9 4.5 Badge Access ............................................................................................................................... 9 4.6 Surveillance ................................................................................................................................. 10 4.7 Third Party Access ...................................................................................................................... 10 4.8 Consent to do Business (Electronic) ........................................................................................... 10 4.9 IT Change Control ....................................................................................................................... 10 5. Maintenance 10 5.1 System and Information Integrity and Uptime ............................................................................. 11 5. 2 Backup Process .......................................................................................................................... 11 5.3 Audit ............................................................................................................................................ 11 5.4 Donation Process ........................................................................................................................ 11 5.5 E-Waste Disposal ........................................................................................................................ 11 6. Awareness and Training 11 7. Risk Assessment/Security Assessments 12 7.1 Cybersecurity Insurance ............................................................................................................. 12 8. Incident Response 12 8.1 Incident Response Plan .............................................................................................................. 12 1
Executive Summary The Saint Mary’s University of Minnesota (SMUMN) Information Security Program is a roadmap to help move our university to a more secure environment and to ensure proper processes and policies are in place to meet regulated guidelines and standards. In today’s world, it is not a matter of “if” a security breach happens, but rather “when”. Therefore, it’s essential that we continue to be proactive so we are prepared to analyze, secure, document, and report, if necessary, any incidents within an appropriate time frame. The program is coordinated by the Director of IT and reviewed and updated annually by the IT Leadership Team. SMUMN is dedicated to protecting the private information of its students, faculty, staff and alumni and data security is a top priority for the IT Department. High availability, with minimal downtime, is a must to help our students achieve their goals. Our network continues to grow and the needs of our students are constantly changing. Utilizing the InfoTech Research group for many best practice templates, this document summarizes SMUMN’s approach to data security. It discusses current safeguards in place, identifies internal and external risks, and provides a framework for future efforts to secure our data. This program addresses the guidelines documented in: ● National Institute of Standards and Technology (NIST) ● General Data Protection Regulation (GDPR) ● Payment Card Industry (PCI) ● Family Education Rights and Privacy Act (FERPA) ● Health Insurance Portability and Accountability Act (HIPAA) ● Department of Energy (DOE) ● Title IV ● California Consumer Privacy Act (CCPA) SMUMN uses InfoTech’s Governance and Management Assessment to track our security preparedness. Overall maturity has moved from 36% to 57% to 61% between March 2017 to February 2020. As with any performance improvement project, some issues were quickly identified and addressed providing a larger increase in maturity between our first 2 assessments. This past year, all 7 categories stayed the same or increased slightly and the Auditing category made it into the green for the first time. It was again identified that our Security Culture is our biggest risk. This past summer, we partnered with KnowBe4, a well- known leader in security awareness training. A baseline phishing test was sent to staff and faculty in late July 2020 and resulted in 26.1% phish-prone rate meaning one quarter of our staff failed. 82 of our employees, actually entered their credentials. Future phish tests and training will be provided to staff and faculty on a regular, but random, basis. Those who fail, will receive additional training. This new software will greatly increase the Security Culture category which is currently at 19%. 2
Security is a moving target and we must proactively and intentionally focus time and money to protect our data. As noted above, part of this program is an annual review by the IT Leadership Team to assess the security program and associated processes and policies. During this review, IT Leadership also discusses and documents the upcoming security initiatives for the year. The last review was in July 2020. 2020-2021 Security Initiatives 1. *Move servers to internal IP addresses 2. *Create data classification documents 3. *Account cleanup (onboarding and off boarding) 4. *Security Awareness Training for staff and faculty 5. *Implement 2 Factor Authentication for GSuite University wide 6. *Add card access on the TC campus server room 7. Install TC security cameras 8. Additional UPS for the TC Campus Server Room and Elevators 9. Revise backup scheme/DR 10. Update VMware and replace hosts 11. Physically secure data closets in SLC Recap of the completed 2019-2020 Security Initiatives 1. Install firewall for Apple Valley and Rochester campuses-Completed 2. *Move desktops and servers to internal IP addresses-80% 3. *Document data integration between applications-Completed 4. *Add a backup internet connection for the Winona Campus-Completed 5. Replace the private data line from the Winona Campus to the TC Campus-Completed 6. Update end of life server operating systems (24 needed)-Completed 7. Upgrade security camera server and software on Winona Campus-Completed 8. Upgrade card access software and server on Winona Campus-Complete * Indicates the initiative was started in a previous year and has carried over either because it was not completed or because it is a multi-year project. These topics and others are discussed in greater depth throughout this document. Specific updates and timelines regarding this year’s initiatives are documented here and documentation of previous security initiatives are linked as an Appendix at the end of this document. If you have any questions about the Information Security Program, please contact the Director of IT. 3
2019-2020 Security Initiatives What section of the plan Anticipated Date does this Initiative Completion Completed Owner apply too? Notes Firewalls were purchased and installed in both Apple Valley and Rochester. Apple Valley Install firewall for Apple Valley and Rochester campuses 9-1-19 7-2019 Mike Ziegler 2.2 has since closed. 80% complete. Desktops and wireless complete. Need to finish some servers. Moved to Move IP addresses out of public ip ranges for desktops and servers 6-1-20 In progress Mike Ziegler 2.2 2020-2021 security initiatives. A list of applications has been created and integrations marked with descriptions. Need to Document data integration between applications 12-31-19 12-2019 Amanda Schock 3.2 document the fields that are transferred between apps. Delayed due to Covid and Strategic Iniaitive #5 progress. Moved to 2020-2021 security Create data classification documents 12-31-19 In progress Amanda Schock 3.3 iniatives. 30,000 email accounts were deleted brining us to about 15,000 left. A policy/process is being brought forward with hopes for January 1, 2021 implementation to complete gmail cleanup. User accounts will follow. Directory cleanup in progress with goal for October Account cleanup (onboarding and offboarding) 12-31-19 In progress IT Leadership 4 31st, 2020. Adjuncts are now termed out of Great Plains after 1 year vs 2. Security Awareness Training for staff and faculty 6-1-20 In progress Tianna Johnson/Chad Lang 6 KnowBe4 was purchased and baseline test complete. More training to come. Add a backup internet connection for Winona Campus 12-31-19 6-2020 Mike Ziegler Backup line with CenturyTel implemented early summer 2020. Replace the private line from the Winona Campus to the TC Campus 5-1-20 6-2020 Mike Ziegler 2.2 Move to HBC with 1 GB line Update EOL Server OS (25 needed) 12-1-19 4-2020 Mike Ziegler 2.2 Windows and linux servers have been updated and or replaced. The IT dept is setup. Cabinet and Dept managers will be next to implement. Moved to Implement 2 Factor Authentication for GSuite University wide 12-31-19 In progress Tianna Johnson 4.3 2020-2021 security initiatives. Upgrade security camera server and software on Winona Campus 9-1-19 12-2019 Mike Ziegler/Chad Lang Server is purchased. Need to install software. Upgrade card access software and server (RS2) on Winona Campus 9-1-19 7-2019 Mike Ziegler 4.5 Completed in July 2019. Add card access on the TC campus server room 12-1-19 Tianna Johnson 2.2 Moved to 2020-2021 security initiatives.
2020-2021 Security Initiatives What section of Anticipated Date the plan does Initiative Completion Completed Owner this apply too? Notes This goal is carried over from previous years however has been updated to reflect the fact that desktops, wireless, and other devices have already been moved. Once complete, we can look to schedule a Move servers to internal IP addresses 6-1-21 In progress Mike Ziegler 2.2 penetration test. Create data classification documents 6-1-21 Amanda Schock 3.3 Will be completed in coordination with Strategic Initiative #5. 30,000 email accounts were deleted brining us to about 15,000 left. A policy/process is being brought forward with hopes for January 1, 2021 implementation to complete gmail cleanup. User accounts will follow. Phone directory cleanup is in progress with a goal for October 31st, 2020. Adjuncts are now termed out of Great Plains after 1 year Account cleanup (onboarding and offboarding) 3-1-21 In progress IT Leadership 4 vs 2 years. KnowBe4 was purchased and baseline test complete. More training Security Awareness Training for staff and faculty 1-1-21 In progress Tianna Johnson 6 to come. The IT dept is setup. Cabinet and Dept managers will be next to Implement 2 Factor Authentication for GSuite University wide 1-1-21 In progress Tianna Johnson 4.3 implement. Add card access on the TC campus server room 1-1-21 Tianna Johnson 2.2 Install TC security cameras 11-1-20 In progress Tianna Johnson/Chad Lang 4.6 Getting quotes and meetings with vendor are scheduled Additional UPS for the TC Campus Server Room and Elevators 7/1/2020 7/1/2020 Mike Ziegler 2.2 UPSs were purchased and installed. Revise backup scheme/DR 5/1/2021 Mike Ziegler 5.2 Update vmware and replace hosts 6/1/2021 Mike Ziegler 2.1 Secure more data closets in SLC 6/1/2021 Mike Ziegler 2.2
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