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Passaic County Community College is committed to collecting, handling, storing, and using critical information and data properly and securely. The use of any Passaic County Community College data or information, in any format, for any purpose other than conducting College business is strictly forbidden. This policy directs the establishment of an Information Security Program to create administrative, technical and physical safeguards for the protection of the College's information assets including those covered by applicable federal and state regulations. This Program must comply with The Financial Services Modernization Act of 1999 (also known as Gramm Leach Bliley) 15 U.S.C. §6801 and the regulations thereunder at 16 C.F.R. Part 314 which Program shall:
Identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of the College's information assets that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information; it must then assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of the College's operations, including
employee training and management;
information systems, including network and software design, information processing, storage, transmission, and disposal; and
detection and prevention of and response to attacks, intrusions, or other systems failures.
Design and implement information safeguards to control the risks that the College identifies through risk assessment and regularity test or otherwise monitor the effectiveness of the safeguards' key controls, systems, and procedures
Oversee service providers by:
taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards for the College's information assets at issue, and
requiring that service providers, by contract, implement and maintain such safeguards.
Evaluate and adjust the College's Information Security Program in high of the results of the testing and monitoring required by law; of any material changes of the College's operations or business arrangements; or of any other circumstances that the College knows (or has reason to know) may materially impact the Information Security Program.
In addition, the Program shall:
Reduce the risk of cyber incidents through proactive improvements in personnel, processes, and technology;
Implement measures to identify cyber incidents quickly when they do occur to minimize exposure;
Fix issues efficiently and effectively to minimize financial and operational impacts;
Advance the program to improve iteratively, keeping up with emerging threats and vulnerabilities
Ensure that the Program is updated periodically to reflect changes in risks to the College.
The Vice President for Information Technology (VP-IT) shall be responsible for developing, maintaining, disseminating, implementing, updating and measuring the compliance of the Information Security Program. The VP-IT shall cause those College faculty, staff, part-time and temporary workers who have access to the College's information assets to receive appropriate training in the Program.
Primary accountability for protection the institution's information assets rests with the academic and administrative owners of the information assets.
The College will take appropriate action in response to misuse of College information assets. Any violation of this policy may result in legal action and/or College disciplinary action under applicable College and administrative policies and procedures up to and including termination.
After the end of every academic year, the VP-IT shall review the Program and submit a written report on the status of the Program to the President of the College.
The Board of Trustees will provide support to the Information Security Program and Guidance for the ongoing direction of the program.
PCCC Board of Trustees Policy C207
Approved: January 19, 2021
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