Wittenberg University Information Security Plan

I. The designated employees for the coordination and execution of the Information Security Plan are the Controller and the Director of Computing Services of Wittenberg University. All correspondence and inquiries should be directed to the Controller's Office or the Computing Center.

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

Employee Management and Training
Information Systems
Student Loans
Student Accounts
Student Employment
Admissions
Registrar's Office
Financial Aid Office
Student Center-Meal Plans
Residence Life
Student Health Center
Continuing Education
International Education
Athletics
Physical Plant/Purchasing

III. The Controller will coordinate with the Director of the Computing Center to maintain the information security program. These two offices will provide guidance in complying with all privacy regulations. Each of the above relevant areas is responsible to secure customer information in accordance with all privacy guidelines. A written security policy that details the information security policies and processes will be maintained by each relevant area and will be made available to the Controller's and Director of Computing Center's office upon request. In addition the Computing Center 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. Wittenberg 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 acknowledgement 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 customer's 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 Wittenberg University to immediately terminate the contract without penalty.
• A provision allowing auditing of the contract partners' compliance with the contract safeguard requirements.
• A provision ensuring that the contracts' 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 per the Controller's Office and Computing Center's internal auditing schedule. Risk assessment will be performed annually by each area and submitted to the Controller's office and the Computing Center. Evaluation of risk of new or changed business arrangements will be done through the Office of Business and Finance.