Information Technology Security Program

“A strategic plan to ensure confidentiality, integrity, and accessibility of Oneonta’s information assets.”

PURPOSE  SCOPE PROGRAM

• SECTION 1. PREFACE

• SECTION 2. ORGANIZATIONAL AND FUNCTIONAL RESPONSIBILITIES

• SECTION 3. INFORMATION SECURITY

• Individual Accountability

• Confidentiality / Integrity / Availability

• SECTION 4. ASSET CLASSIFICATION AND CONTROL

• Privacy and Handling of Private Information

• SECTION 5. PERSONNEL SECURITY

• Including Security in Job Responsibilities

• User Training

• Responding to Security Incidents and Malfunctions

• Reporting Security Weaknesses

• Reporting Security Software Malfunctions

• Incident Management Process

• SECTION 6. PHYSICAL AND ENVIRONMENTAL SECURITY

• Physical Security Barrier 9 Secure Disposal or Re-use of Equipment

• Clear Screen

• SECTION 7. COMMUNICATIONS AND NETWORK MANAGEMENT

• Network Management

• Host Scanning

• Network Security Checking

• Internet and Electronic Mail Acceptable Use

• External Internet and VPN Connections

• Security of Electronic Mail

• Portable Computers

• Telephones and Fax Equipment

• Wireless Networks

• Modem Usage

• Public Websites

• Electronic Signatures

• SECTION 8. OPERATIONS MANAGEMENT

• Incident Management Procedures

• Segregation of Duties

• Separation of Test and Operational Facilities

• Protection against Malicious Software

• Software Maintenance

• Information Back-up

• System Security Checking

• Disposal of Media

• SECTION 9. ACCESS CONTROL

• User Registration and Management

• Privileged Account Management

• User Password Management

• Network Access Control

• User Authentication for External Connections (Remote Access Control)

• Segregation of Networks

• Operating System Access Control

• Monitoring System Access and Use

• SECTION 10. SYSTEMS DEVELOPMENT AND MAINTENANCE

• Control of Internal Processing

• Cryptographic Controls

• Change Control Procedures

• SECTION 11. COMPLIANCE

• Gramm-Leach-Bliley Act

• Safeguarding of College Records

• Prevention of Misuse of Information Technology Resources

• Compliance

• Enforcement and Violation Handling

• DEFINITIONS PURPOSE

The purpose of this document is to define a set of minimum information technology (IT) security requirements that the College must meet to comply with State and Federal directives. The College may, based on its individual business needs and specific legal requirements such as FERPA or the GLBA, exceed any or all of the information security requirements put forth in this document, but must, at a minimum, achieve the information security levels defined in this document.

The primary objectives of the IT Security Program are:

  • • effectively manage the risk of IT security exposure or compromise within College systems;
  • • communicate within the College community the responsibilities for the protection of College information;
  • • comply with the Family Educational Rights and Privacy Act of 1974 (FERPA - the Buckley Amendment), the Gramm-Leach-Bliley Act (GLBA), the Payment Card
  • Industry Data Security Standard (PCI DSS) and other statutes, policies and  standards protecting the rights of individuals.
  • consistently maintain data integrity and accuracy.
  • assure that authorized individuals have timely and reliable access to necessary data.
  • deny with reasonable assurance unauthorized individuals access to computing resources or other means to retrieve, modify or transfer data.

SCOPE

This program applies to all faculty, staff and students of the College, or others (e.g., Research Foundation employees, OAS employees, vendors, contractors, etc) who may utilize the College’s technology and related facilities.

This program encompasses all computer systems, for which the College has responsibility, including systems managed or hosted by third parties on behalf of the College. It addresses all electronic information, regardless of the form or format, which is created or used in support of the College mission.

IT security refers to the protection of information from unauthorized access, destruction, modification or disclosure. For the purposes of this document, information is defined as the representation of facts, concepts, or instructions in an electronic manner suitable for communication, interpretation, or processing by human or automated means.

Information is relayed in a variety of methods such as in written documentation or through computer networks. Information is also stored and retrieved in several formats.

The formats can include but are not limited to: computer databases or transmissions, tapes, CD ROMS, diskettes, computer generated reports, hard copy documentation, email messages, voice mail, etc.

This program must be communicated to all faculty, staff, students and all others who have access to or manage College information. This IT security program is not specific to any type of hardware, communications method, network topology, or software applications. As such, it is designed to be implemented across campus.

PROGRAM Section 1. Preface

The President’s Cabinet is fully committed to IT security and agrees that every person in the College community has an important responsibility to continuously maintain the security and privacy of College data. This IT Security Program is a statement of the minimum requirements, ethics, responsibilities and accepted behaviors required to establish and maintain a secure environment, and achieve the College’s IT security objectives. This IT Security Program sets the direction, gives broad guidance and defines requirements for IT security related processes and actions across the College.

This program follows the framework of the International Standards Organization’s ISO 27002 - The Information Security Standard.

Section 2. Organizational and Functional Responsibilities

A. The College: The President will designate an Information Security Officer (ISO). The ISO will ensure that an organization structure is in place for:

  • • coordinating and implementing information security policies, standard, and procedures;
  • • assigning information security responsibilities;
  • • implementing an IT security awareness program;
  • • monitoring significant changes in the exposure of IT assets to major threats, legal
  • or regulatory requirements;
  • • responding to IT security incidents;
  • • leading major initiatives to enhance IT Security;
  • • leading disaster preparedness planning to ensure continuity of College business.

B. College Designated Staff: College designated staff will be responsible for the implementation of this and other IT Security policies and the compliance of College employees to this program. The designated staff must educate College employees with regard to IT Security issues, explain the issues, why the policies have been established, and what role(s) individuals have in safeguarding IT assets. Consequences of noncompliance will also be explained.

C. Information Owners: Information owners are responsible for determining who should have access to protected resources within their jurisdiction, and what those access privileges should be (read, update, etc.). These access privileges must be in accordance with the user’s job responsibilities. Information owners also communicate to the College ISO the legal requirements for access and disclosure of their data.

Information owners must be identified for all College information assets and assigned responsibility for the maintenance of appropriate information security measures such as assigning and maintaining asset classification and controls, managing user access to their resources, etc. Responsibility for implementing information security measures may be delegated, though accountability remains with the identified owner of the asset.

D. College Information Security Officer: The College Information Security Officer has overall responsibility for ensuring the implementation, enhancement, monitoring and enforcement of this program. The College Information Security Officer is responsible for providing direction and leadership to the College through the recommendation of IT security policies, standards, processes and education and awareness programs to ensure that appropriate safeguards are implemented, and to facilitate compliance with those policies, standards and processes. The College Information Security Officer is responsible for investigating all alleged IT security violations. In this role, the College Information Security Officer may refer the investigation to other investigatory entities, including law enforcement. The College Information Security Officer will coordinate and oversee IT security program activities and reporting processes in support of this program and other IT security initiatives.

E. IT Security Administrator: This individual will report to the College Information Security Officer and be responsible for administering IT security tools, auditing IT security practices, identifying and analyzing IT security threats and solutions, and responding to IT security violations.

F. Departments or Individuals with Direct Responsibility for Technology Support:

These areas have responsibility for the data processing infrastructure and computing networks which support the information owners. It is their responsibility t to support the IT Security Program and provide resources needed to enhance and maintain a level of IT Security control consistent with the College’s IT Security Program.

These departments have the following responsibilities in relation to the IT security:

  • • ensuring processes, policies and requirements are identified and implemented relative to IT security requirements defined by the College;
  • • ensuring the proper controls of IT are implemented for which the College has assigned ownership responsibility, based on the College’s classification designations;
  • • ensuring the participation of the College Information Security Officer and technical staff in identifying and selecting appropriate and cost-effective IT security controls and procedures, and in protecting IT assets;
  • • ensuring that appropriate IT security requirements for user access to automated information are defined for files, databases, and physical devices assigned to
  • their areas of responsibility;
  • • ensuring that critical data and recovery plans are backed up and kept at a secured off-site storage facility and that recovery of backed-up media will work if and when needed.

G. College Employees: It is the responsibility of all employees to protect College information and resources, including passwords, and to report suspected IT security

incidents to one or more of the following: the information owner, the IT Help Desk, or the Information Security administrator as appropriate.

H. Non-College Employees: Oneonta Auxiliary Services (OAS), Research Foundation (RF), Retirees, Contractors, Consultants, Vendors and other persons including students, to the extent of their present or past access to the College IT assets, are also covered by this IT Security Program.

Section 3. Information Technology Security

All stored or transmitted electronic information which is created, acquired or used in support of the College’s mission, regardless of the form or format, must be used for College business only. This information is an asset and must be protected from its creation, through its useful life, and to its authorized disposal. It must be maintained in a secure, accurate, and reliable manner and be readily available for authorized use.

Information must be classified and protected based on its importance to business activities, risks, and information security best practices as defined in International

Standards Organization’s ISO 27002 - The Information Security Standard.

A. Information is one of the College’s most valuable assets and the College relies upon that information to support our mission. The quality and availability of that information is key to the College's ability to carry out its mission. Therefore, the security of the College’s information, and of the technologies and systems that support it, is the responsibility of everyone concerned. Each authorized user of College information has an obligation to preserve and protect College information assets in a consistent and reliable manner. Information security controls provide the necessary physical, logical and procedural safeguards to accomplish those goals.

B. Information security management enables information to be shared while ensuring protection of that information and its associated computer assets including the networks over which the information travels. College designated staff are responsible for ensuring that appropriate physical, logical and procedural controls are in place on these assets to preserve the information security properties of confidentiality, integrity, availability and privacy of College information.

Individual Accountability

Individual accountability is the cornerstone of any information security program. Without it, there can be no information security. Individual accountability is required when accessing all College resources.

• Access to College computer systems and networks must be provided through the use of individually assigned unique computer identifiers, known as user-IDs.

• Individuals who use College computers must only access information assets to which he or she is authorized.

• Associated with each user-ID is an authentication token, such as a password, which must be used to authenticate the person accessing the data, system or network. Passwords, tokens or similar technology must be treated as confidential information, and must not be disclosed. Transmission of such authentication information must be made only over secure mechanisms.

• Each individual is responsible to reasonably protect against unauthorized activities performed under his or her user-ID.

• For the user’s protection, and for the protection of College resources, user-Ids and passwords (or other tokens or mechanisms used to uniquely identify an individual) must not be shared. In certain circumstances, where there is a clear requirement or system limitation, the use of a shared user-id for a group of users or a specific job can be used. Additional compensatory controls must be implemented to ensure accountability is maintained.

Confidentiality / Integrity / Availability

A. All College information must be protected from unauthorized access to help ensure the information’s confidentiality and maintain its integrity. Information owners will secure information within their jurisdiction based on the information’s value, sensitivity to disclosure, consequences of loss or compromise, and ease of recovery. The College will adopt policies and procedures to guide information owners in securing their information assets.

B. Information will be readily available for authorized use when it is needed by users in the normal performance of their duties. Appropriate processes will be defined and implemented to ensure the reasonable and timely recovery of all the College information, applications and systems, regardless of computing platform, should that information become corrupted, destroyed, or unavailable for a defined period (ref to Section 8 - Operations Management Program, Information Backup section).

Section 4. Asset Classification and Control

A. Information must be properly managed from its creation, through authorized use, to proper disposal and requires different levels of protection. Information will be classified based on its value, sensitivity, consequences of loss or compromise, and/or legal and retention requirements. Criteria for determining the sensitivity of information will include consideration of confidentiality, integrity, availability, privacy, safety, legal and retention compliance requirements.

B. All information will have an information owner established within the College’s lines of business who will be responsible for assigning the initial information classification, and make all decisions regarding controls, access privileges of users, and daily decisions regarding information management.

C. Each classification will have a set or range of controls, designed to provide the appropriate level of protection of the information and its associated application software commensurate with the value of the information in that classification. Protective measures will address the above considerations with control categories that include: identification & authentication, access control, confidentiality, network security, host security, integrity, non-repudiation, monitoring and compliance.

Privacy and Handling of Private Information

Privacy of personally identifiable information must be maintained consistent with laws,rules and regulations. The College’s systems hold personal information (i.e., anyinformation that is unique to any individual) to carry out the mission of the College. Theprotection of the privacy of personal information is of utmost importance and the Collegemust protect the rights of privacy of all members of the College community. All Collegeemployees with access to personal information are required to respect theconfidentiality of that personal information to the full extent of the law. Personal data,including information about employees, students, members of the public, organizations and business partners, collected and maintained by the College must:

  • • be consistent with the provisions of the Internet Security and Privacy Act, the Freedom of Information Law, FERPA, and the Personal Privacy Protection Law;
  • • be used as authorized by law;
  • • be gathered in lawful manner;
  • • be kept in a manner as required by law or regulations;
  • • not be disclosed unless authorized or required by law;
  • • be available for review by authorized individuals;
  • • be corrected if errors are known to exist or if the individual identifies errors;
  • • be erased where appropriate if the individual requests consistent with applicable laws; and
  • • be protected using system access controls.

Section 5. Personnel Security

The intent of this section is to reduce the risk of human error and misuse of College information and facilities.

Including Information Security in Job Responsibilities

Information security roles and responsibilities must be documented. These roles andresponsibilities will include general responsibilities for all College employees, as well asspecific responsibilities for protecting specific information assets and performing tasks related to information security procedures or processes.

User Training

A. All faculty, staff and students must receive general information security awarenesstraining to ensure they are knowledgeable of information security procedures, their rolesand responsibilities regarding the protection of the College information assets, and the proper use of information processing facilities to minimize information security risks.

B. Departments that process or maintain sensitive information are responsible forconducting specific information security awareness training for employees who handlesuch information in the course of their job duties. This training should include physicalhandling and disposition of non electronic documents containing sensitive informationas well as proper procedures to follow in processing and storing electronic informationand documents.

C. Logon banners will be implemented on all systems where that feature exists to informall users that the system is for the College business or other approved use consistent with College mission.

Responding to Information Security Incidents and Malfunctions

A. Incidents affecting information security must be reported as quickly as possible toone or more of the following: the information owner, the Information Technology (IT)Help Desk or the IT Security Administrator as appropriate.

B. Formal incident reporting procedures that define the actions to be taken when anincident occurs must be established. Feedback mechanisms must be implemented toensure that individuals reporting incidents are notified of the results after the incident has been resolved and closed.

Reporting Information Security Weaknesses

Users of information technologies shall report any observed or suspected informationsecurity weaknesses or threats to the appropriate manager and the IT SecurityAdministrator. They must report these weaknesses as soon as possible. Users must notattempt to prove a suspected weakness unless authorized by the College ISO to do so. Testing weaknesses could have unintended consequences.

Reporting Information Security Software Malfunctions

Users are required to report software malfunctions such as a virus not being detected,password change not accepted, etc. Users should report such malfunctions by calling the IT Help Desk. After the IT Help Desk is notified of the problem the following actions

  • will be taken:
  • • the symptoms of the problem and any messages appearing on the screen will be documented;
  • • the computer will be isolated, if possible, and use of it stopped until the problem as been resolved;
  • • the incident will be reported immediately to the appropriate manager and the IT Security Administrator.

Incident Management Process

The logging of information security incidents will be used by the College to identifyrecurring or high impact incidents and to record lessons learned. Review of thisinformation may indicate the need for additional controls to limit the frequency, damage and cost of future incidents.

Section 6. Physical and Environmental Information Security

Physical Security Barriers

A. Breaching physical security can cause a loss of or damage to College informationassets. Physical security will be achieved by creating physical barriers around theassets being protected. These barriers could be in the form of an entry point with cardkey access, a locked door, a staff member, or other physical barrier.

B. College environments where servers are stored or operational, wiring closets fornetworks and telephony, printers where confidential or sensitive information may beprinted, and any other areas that contain and or process critical or sensitive informationmust be secured against unauthorized access.

C. The College will perform periodic threat and risk analysis to determine whereadditional physical security measures are necessary, and implement these measures to mitigate the risks.

Secure Disposal or Re-use of Equipment

There is risk of disclosure of sensitive information through careless disposal or re-use ofequipment. Storage devices such as hard disk drives and other magnetic media such astape, containing sensitive information will be physically destroyed or securely overwritten to prevent the unauthorized disclosure of sensitive College information.

Clear Screen

Desktop, laptop and PDA computers connected to a network and/or containing sensitiveor confidential College information must be automatically logged off or the screen locked within 30 minutes of inactivity.

Inventory Control

All College owned computer equipment will be tagged to identify the College as theowner. An equipment inventory will be conducted annually by the Office of Property Management.

Section 7. Communications and Network Management

Network Management

The College must implement a range of network controls to maintain security in itsinternal networks, and ensure the protection of connected services and networks. Thesecontrols help prevent unauthorized access and use of the College networks. Thefollowing controls, at a minimum, should be implemented:• Operational responsibility for networks will be separate from computer operationswhen possible;• Responsibilities and procedures for remote use must be established (refer toSection 9. Access Control section of this document);• When necessary, special controls will be implemented to safeguard data integrity and confidentiality of data passing over public networks (Internet).

Host Scanning

Any devices connected to a network will be scanned periodically to ensure that no majorvulnerabilities have been introduced into the environment. The frequency of scans will be determined by the College ISO.

Network Security Checking

A. Network vulnerability scanning will be conducted periodically at the discretion of theIT Security Administrator. The output of the scans will be reviewed in a timely manner,and any vulnerability detected will be evaluated for risk and mitigated. The tools used toscan for vulnerabilities will be updated periodically to ensure that recently discoveredvulnerabilities are included in any scans.

B. A process to perform the scanning will be defined by the College, tested and followedat all times to minimize the possibility of disruption to the College networks by suchreviews. Reports of exposures to vulnerabilities will be forwarded to the College ISO and IT Security Administrator.

C. All connections to College networks must be authenticated.

D. The use of any network vulnerability scanning tools, whether internal or external, byindividuals who are not part of the formal test process described above is prohibited.Any vulnerability scanning from the Internet must be conducted exclusively by the College’s authorized, qualified staff or qualified third party.

Internet and Electronic Mail Acceptable Use

When College faculty, staff and students connect to the Internet using any CollegeInternet address designation or send electronic mail using the College designation, itshould be consistent with the College’s mission. College equipment, systems, facilitiesand supplies must be used only for conducting activities consistent with the College’smission. Users are visible representatives of the College and must use the Internet andCollege e-mail system in a legal, professional and responsible manner. The following isnot an all-inclusive list, and provides only examples of behavior that is not acceptable. Specifically, the Internet and electronic mail will not be used:

  • • for personal gain or profit;
  • • to represent yourself as someone else (i.e.“spoofing”);
  • • for spamming;
  • • for unauthorized attempts to break into any computing system whether the College’s or another organization’s (i.e., cracking or hacking);
  • • for theft or unauthorized copying of electronic files;
  • • for posting sensitive College information without authorization from the College and without protective measures such as encryption
  • • for mass distribution without the College’s authorization, such as “chain letters”;
  • • for non-business communication using “instant messaging” or similar technology;
  • • for “sniffing” (i.e., monitoring network traffic), except for those authorized to do so as part of their job responsibilities.

External Internet and VPN Connections

A. A computer that is connected to a College network cannot also be connected to anon-College network via dial-up access using a modem unless specifically authorizedby the College ISO. For example, users that subscribe to third party Internet serviceproviders like AOL cannot connect to AOL via a modem at the same time they areconnected to a College network.

B. Any connection over a public network (i.e. Internet) that involves sensitive informationmust use a Virtual Private Network (VPN) or other equivalent encryption technology to ensure the privacy and integrity of the data passing over the public network.

Portable Computers

A. All portable computing resources and information media must be secured to preventcompromise of confidentiality or integrity. No computer device may store or transmitsensitive information without suitable protective measures being implemented andapproved by the College ISO.

B. When using mobile computing facilities such as notebooks, palmtops, laptops andmobile phones, special care must be taken to ensure that information is notcompromised. Users of mobile computing are responsible for physical protection,access controls, cryptographic techniques, back-ups, virus protection and the rulesassociated with connecting mobile facilities to networks and guidance on the use ofthese facilities in public places. In cases where sensitive information is concerned:• Care must be taken when using mobile computing facilities in public places,meeting rooms and other unprotected areas outside of the College's premises.Protection must be in place to avoid the unauthorized access to or disclosureof the information stored and processed by these facilities, e.g. usingcryptographic techniques.• It is important that when such facilities are used in public places care must betaken to avoid the risk of unauthorized persons viewing information on-screen.• Equipment carrying important and/or sensitive information must not be leftunattended and, where possible, must be physically locked away, or speciallocks must be used to secure the equipment.• Training must be provided to staff using mobile computing resources to raisetheir awareness of the additional risks resulting from this way of working andthe controls that will be implemented.• Employees in the possession of portable, laptop, notebook, palmtop, and othertransportable computers must not check these computers in airline luggagesystems. These computers must remain in the possession of the traveler ashand luggage unless other arrangements are required by Federal or Stateauthorities.• For all portable computers such as laptops, notebooks, etc, the use of a “bootup”or power-on password must be implemented. For those computers containing sensitive information, data encryption techniques may also be employed.

Telephones and Fax Equipment

The use of telephones outside the College for business reasons is sometimes

necessary, but it can create security exposures. Examples of best practices:

  • • take care that they are not overheard when discussing confidential matters;
  • • avoid use of any wireless or cellular phones when discussing sensitive or confidential information;
  • • avoid leaving sensitive or confidential messages on non-College voicemail systems;
  • • if sending sensitive or confidential documents via fax, verify the phone number of the destination fax. Contact the recipient to ensure protection of the fax, either by having it picked up quickly or by ensuring that the fax output is in a secure area;
  • • avoid using Internet fax services to send or receive sensitive or confidential information;
  • • not use third party fax services to send or receive sensitive or confidential information;
  • • not send sensitive or confidential documents via wireless fax devices;
  • • when chairing a sensitive or confidential teleconference, confirm that all participants are authorized to participate, before starting any discussion.

Wireless Networks

A. Wireless technology and pervasive devices create opportunities for new andinnovative uses. College information systems can be exposed to compromise or to a loss of service if security risks are not addressed correctly.

B. Wireless technology is a shared medium. Everything that is transmitted over theradio waves can be intercepted if the interceptor is within the coverage area of the radiotransmitters. This represents a potential security issue in the wireless Local AreaNetworks (LANs). The security exposure is more evident in public areas, such as theLibrary, Residence Halls, and the Student Union.

C. Suitable controls such as authentication and encryption will be implemented byTelecommunications to reduce the possibility that a wireless network or access pointcan be exploited to disrupt College information services or to gain unauthorized access to College information.

D. A Wireless Communications Policy will be established to address these issues.

Modem Usage

A. Using modems to connect to a network can create security risks. When using amodem and a computer that contains sensitive college information the following best practices apply:

1. For Outbound Service (Configured for outgoing calls only):

  • • modems must not be left connected to computers in auto-answer mode, such that they are able to receive incoming dial-up calls;
  • • communications systems must not be established that accept incoming dial-up calls;
  • • under no circumstances will a user attempt to add a remote access server to a college network.

2. For Inbound Service (Configured for modem to accept incoming calls only):

  • • all dial-up modem phone numbers are confidential and must be made available only to authorized users;
  • • only under extreme conditions should a computer have remote control software and dial-in capability;
  • • dial-up modems must be configured to answer calls on the fourth ring;
  • • system configuration will be set to disconnect after three unsuccessful password attempts;
  • • session limits of three hours and inactivity timeouts of 30 minutes will be placed on all sessions.

Public Websites

A. The World Wide Web provides an opportunity for the College both to disseminateinformation and to provide interactive services quickly and effectively. Because anythingposted on a public web server is globally available and each web presence is a potentialconnection path to the College networks, care will be exercised in the deployment ofpublicly accessible servers. There is also potential for an insecure server to be used orexploited to assist in an unauthorized or illegal activity, such as an attack on another web site.

B. Sensitive or confidential information will not be made available through a server thatis available to a public network without appropriate safeguards approved by the CollegeISO. The College ISO will implement safeguards to ensure user authentication, dataconfidentiality and integrity, access control, data protection, and logging mechanisms.

C. The implementation of any web site or software that interacts with the user, requiresregistration, collects or processes information from users is considered to be applicationdevelopment and, therefore, must be audited and approved by the College ISO toensure that the collection and processing of information meets College informationsecurity and privacy requirements. The review will ensure that the information isadequately protected while in transit over public and College networks, while in storage, and while being processed.

D. All official web sites will comply with Federal and state legal requirements.

Electronic Signatures

Electronic signatures including digital signatures provide a means of protecting theauthenticity and integrity of electronic documents. They can be used in electronictransactions where there is a need for a signature. New York State's ElectronicSignatures and Records Act (ESRA) provides that electronic signatures are equivalentto hand-written signatures. The College will comply with the Electronic Signatures andRecords Act (ESRA), FERPA, and any other State or Federal regulations regarding electronic signatures.

Section 8. Operations Management

Incident Management Procedures

A. All users of College information systems must be made aware of the procedure forreporting information security incidents, threats, weaknesses, or malfunctions that mayhave an impact on the security of College information. All College staff and contractorsare required to report any observed or suspected incidents to the appropriate managerand the College ISO as quickly as possible.

B. Incident management responsibilities must be documented and procedures must beclearly defined to ensure a quick, effective and orderly response to information security incidents. At a minimum, these procedures must address:

  • • information system failures and loss of service;
  • • denial of service;
  • • errors resulting from incomplete or inaccurate data;
  • • breaches of confidentiality;
  • • loss of integrity of the software or other system component.

C. In addition to normal contingency plans designed to recover applications, systems orservices, the incident response procedures must also cover:• analysis and identification of the cause of the incident;• planning and implementation of corrective actions to prevent reoccurrence;• collection of audit log information;• communication with those affected by or involved in the recovery from the incident.

D. College management and the College ISO will investigate all information security incidents and implement corrective actions to reduce the risk of reoccurrence.

Segregation of Duties

To reduce the risk of accidental or deliberate system misuse, separation of duties orareas of responsibility must be implemented where practical. Where appropriate,including where the separation of duties is not practical, other compensatory controlssuch as monitoring of activities, audit trails and management supervision must be implemented.

Separation of Test and Operational Facilities

A. Separation of the development, test and operational environments will beimplemented, either logically or physically, when feasible. Processes must bedocumented and implemented to govern the transfer of software from the developmentenvironment to the operational platform.

B. Separation must also be implemented between development and test functions. TheCollege must consider the use of a stable quality assurance environment where usertesting can be conducted and changes cannot be made to the programs being tested.The following controls must be considered:• development and operational software must, where possible, run on differentcomputer processors, or in different domains or directories;• development and testing activities must be separated;• compilers, editors and other system utilities must not be accessible fromoperational systems when not required;• different log-on procedures should be used for operational, test and developmentsystems, to reduce the risk of error. Users will be encouraged to use differentpasswords for these systems, and menus should display appropriateidentification messages;• programming staff will only have access to operational passwords where controls are in place for issuing passwords for the support of operational systems.

Protection Against Malicious Software

Software and associated controls must be implemented across College systems toprevent and detect the introduction of malicious software. The introduction of malicioussoftware such as computer viruses, network worms and Trojan horses can causeserious damage to networks, workstations, and data. Users must be made aware of thedangers of unauthorized or malicious software. Anti-virus software will be installed on allcomputers connected to a College network. At a minimum, the virus signature files forthis software must be updated weekly. On host systems or servers, the signature fileswill be updated daily or when the virus software vendor’s signature files are updated and published.

Software Maintenance

All purchased applications and systems software must be maintained at a vendorsupportedlevel to ensure software accuracy and integrity. Maintenance of Collegedevelopedsoftware will be logged to ensure changes are authorized, tested andaccepted by College management. Also, all known information security patches must bereviewed and applied in a timely manner to reduce the risk of security incidents that could affect the confidentiality, integrity and availability of data or software integrity.

Information Backup

The scope of this program is limited to the IT infrastructure, and the data andapplications of the local College environment. To ensure interruptions to normal Collegeoperations are minimized, and critical College applications and processes are protectedfrom the effects of major failures, each College unit, in cooperation with the College ITorganization, must develop plans that can meet the backup requirements of the College. Backups of critical College data and software must be performed regularly.

System Security Checking

A. Systems and services that process or store sensitive or confidential information orprovide support for critical processes must undergo technical security reviews to ensurecompliance with implementation standards and to assess vulnerabilities to subsequentlydiscovered threats. Reviews of systems and services that are essential to supporting acritical College function must be conducted at least once every year. Reviews of arepresentative sample of all other systems and services must be conducted periodically.

B. Any deviations from expected or required results that are detected by the technicalsecurity review process must be reported to the College ISO and corrected immediately.In addition, the College application owner should be advised of the deviations and mustinitiate investigation of the deviations (including the review of system activity log records if necessary).

Disposal of Media

Sensitive information could be leaked to outside persons through careless disposal ofmedia. Formal processes must be established to minimize this risk. Media such astapes, diskettes, servers, mainframe and PC hard drives, and mobile devices such asphones, PDAs or USB drives containing sensitive College data must be destroyed byincineration, shredding, or electronic erasure of data before disposal, consistent with applicable record retention and disposition laws.

Section 9. Access Control

A. To preserve the properties of integrity, confidentiality and availability, the College’sinformation assets will be protected by logical and physical access control mechanismscommensurate with the value, sensitivity, consequences of loss or compromise, legalrequirements and ease of recovery of these assets.

B. Information owners are responsible for determining who should have access toinformation assets within their jurisdiction, and what those access privileges will be(read, update, etc.). These access privileges will be granted in accordance with the user’s job responsibilities.

User Registration and Management

A. A process shall be established by the College to outline and identify all functions ofuser management, to include the generation, distribution, modification and deletion ofuser accounts for access to resources. The purpose of this process is to ensure thatonly authorized individuals have access to College applications and information and that these users only have access to the resources required for authorized purposes.

B. The User Management Process should include the following sub-processes:

  • • enrolling new users;
  • • removing user-ids;
  • • granting “privileged accounts” to a user;
  • • removing “privileged accounts” from a user;
  • • periodic reviewing “privileged accounts” of users;
  • • periodic reviewing of users enrolled to any system; and
  • • assigning a new authentication token (e.g. password reset processing).

C. In most cases the appropriate information owner or supervisor will make requests forthe registration and granting of access rights for employees. In some cases access canbe automatically granted or taken away based on employment status.

D. For applications that interact with individuals that are not employed by the College,the information owner is responsible for ensuring an appropriate user managementprocess is implemented. Standards for the registration of such external users must bedefined, to include the credentials that must be provided to prove the identity of the userrequesting registration, validation of the request and the scope of access that may be provided.

Privileged Account Management

A. The issuance and use of privileged accounts will be restricted to only thoseindividuals necessary in the normal performance of their job responsibilities. Allindividuals (systems programmers, database administrators, network and informationsecurity administrators, etc.) will have a unique privileged account (user-ID) for theirpersonal and sole use so that activities can be traced to the responsible person. Useridsmust not give any indication of the user’s privilege level, e.g., supervisor, manager,administrator. These individuals should also have a second user-ID when performing normal transactions, such as when accessing the College e-mail system.

B. In certain circumstances, where there is a clear requirement or system limitation, theuse of a shared user-id for a group of users or a specific job can be used. Additional compensatory controls must be implemented to ensure accountability is maintained.

C. Passwords of privileged accounts should be changed at least every 90 days.

User Password Management

A. Passwords are a common means of authenticating a user’s identity to access aninformation system or service. Password standards will be implemented to ensure allauthorized individuals accessing College resources follow proven passwordmanagement practices. These password rules must be mandated by automated system controls whenever possible.

B. To ensure good password management, the following password standards will be implemented where feasible:

  • • Password cannot not be the same as user-id;
  • • password length minimum of 8 characters;
  • • strong passwords including alpha and numeric characters;
  • • maximum password age 180 days;
  • • minimum password age 7 days;
  • • password uniqueness equal to five (5);
  • • lock out account after an appropriate number of failed logon attempts;
  • • password lockout duration – 60 minutes, or until reset by authorized person;
  • • passwords should not be written down;
  • • passwords must be kept confidential – they must not be shared with another
  • user;
  • • temporary passwords must be changed at the first logon;

C. A user who needs a password reset must be authenticated before the request is granted.

Network Access Control

Access to the College’s internal networks must require all authorized users toauthenticate themselves through use of an individually assigned user-id and anauthentication mechanism, e.g., password, token or smart card, or digital certificate.Network controls must be developed and implemented that ensure that an authorizeduser can access only those network resources and services necessary to perform their assigned job responsibilities.

User Authentication for External Connections (Remote Access Control)

A. To maintain information security, the College requires that individual accountabilitybe maintained at all times, including during remote access. For the purposes of thisprogram, “remote access” is defined as any access coming into a College network froma non-College network. This includes, but is not limited to:• dialing in from another location over public lines by an employee or otherauthorized individual for the purpose of telecommuting or working from home;• connecting a third party network via dial or other temporary access technology tothe College networks;

B. Connection to the College’s networks must be done in a secure manner to preservethe integrity of the networks, data transmitted over those networks, and the availabilityof those networks. Security mechanisms must be in place to control access to College systems and networks remotely from fixed or mobile locations.

C. Because of the level of risk inherent with remote access, use of a strong password oranother comparable method is required prior to connecting to a College network.

D. When accessing the College networks remotely, identification and authentication ofthe entity requesting access must be performed in such a manner as to not disclose thepassword or other authentication information that could be intercepted and used by a third party.

E. Use of a common access point is required. This means that all remote connections toa computer must be made through managed central points-of-entry. Using this type ofentry system to access the College computer provides many benefits, includingsimplified and cost effective information security, maintenance, and support.

F. For a vendor to access College computers or software, individual accountability isalso required. For those systems (hardware or software) for which there is a built-inuser-id for the vendor to perform maintenance, the account must be disabled until theuser-id is needed. The activity performed while this vendor user-id is in use must belogged. When the vendor has completed his work, the vendor user-id should bedisabled, or the password changed to prevent unauthorized use of this privileged account. Vendor user-ids will be named to be easily identifiable.

G. In the special case where servers, storage devices or other computer equipment hasthe capability to automatically connect to a vendor to report problems or suspectedproblems, the College Information Security Administrator must review any suchconnection to ensure that connectivity does not compromise the College networks.

H. Employees working from a remote location must ensure that the work environment atthe remote location provides adequate information security for College data andcomputing resources. Appropriate protection mechanisms must be in place at theremote location to protect against theft of the equipment, unauthorized disclosure ofCollege information, misuse of College equipment or unauthorized access to theCollege internal networks or other facilities. To ensure the proper information securitycontrols are in place and all College information security standards are followed, thefollowing must be considered:• the existing physical security of the remote location, considering the physicalsecurity of the building and the local environment;• the communications security requirements, considering the need for remoteaccess to the College's internal systems, the sensitivity of the information thatwill be accessed and transmitted over the communication link and thesensitivity of the internal system;• the threat of unauthorized access to information or resources from other people using the accommodation, e.g. family and friends.

I. The following controls must be considered but are not limited to:

  • • the provision of suitable communication equipment, including methods for securing remote access and authentication tokens;
  • • anti-virus software and method for maintaining current signature files;
  • • implementation of suitable network boundary controls to prevent unauthorized information exchange between College networks connected to remote computers and externally connected networks, such as the Internet. Such measures include firewalls, VPN’s and intrusion detection techniques;
  • • encryption of sensitive information in transit and on the local computer workstation;
  • • physical security;
  • • rules and guidance on family and visitor access to equipment and information;
  • • the provision of hardware and software support and maintenance;
  • • the procedures for back-up;
  • • audit and information security monitoring;
  • • revocation of authority, access rights and the return of equipment when the remote access activities cease.

Segregation of Networks

Routers, Firewalls, VPN’s or other technologies should be implemented to control access to secured resources on the College networks.

Monitoring System Access and Use

Systems and applications must be monitored and analyzed to detect deviation from theaccess control program and record events to provide evidence and to reconstruct lost ordamaged data. Audit logs recording exceptions and other information security-relevantevents must be produced and kept consistent with record retention schedulesdeveloped in cooperation with the State Archives and Records Administration (SARA)and College requirements to assist in future investigations and access control monitoring. Audit logs will include but are not limited to:

  • • user-ids;
  • • dates and times for logon and logoff;
  • • terminal identity or location if possible; and
  • • records of successful and rejected system access attempts.

Section 10. Systems Development and Maintenance

A. Software applications are developed or acquired to provide efficient solutions toCollege problems. These applications generally store, manipulate, retrieve and displayinformation used to conduct College business. The College units become dependent onthese applications, and it is essential the data processed by these applications beaccurate, and readily available for authorized use. It is also critical that the software that performs these activities be protected from unauthorized access or tampering.

B. To ensure that information security is built into all College information systems, allsecurity requirements, including the need for rollback arrangements, must bedocumented.

C. Information security requirements and controls must reflect the value of theinformation assets involved, and the potential damage that might result from a failure orabsence of information security measures. This is especially critical for onlineapplications. The framework for analyzing the information security requirements andidentifying controls to meet them is associated with threat assessment and risk management which must be performed by the College ISO and the information owner.

Control of Internal Processing

Data which have been entered correctly can be corrupted by processing errors orthrough deliberate acts. Application design must ensure that controls are implementedto minimize the risk of processing failures leading to a loss of data or system integrity.Specific areas to consider include:• the use and location in programs of add and delete functions to implementchanges to data;• the procedures to prevent programs running in the wrong order or running afterfailure of prior processing;• the use of correction programs to recover from failures to ensure the correct processing of data.

Cryptographic Controls

Use of cryptography for protection of high-risk information must be considered whenother controls do not provide adequate protection. Encryption is a technique that can beused to protect the confidentiality of information. It must be considered for the protectionof sensitive or critical information. Based on a risk assessment, the required level ofprotection will be identified taking into account the type and quality of the encryption algorithm used and the length of cryptographic keys employed.

Change Control Procedures

A. To minimize the possibility of corruption of information systems, strict controls overchanges to information systems must be implemented. Formal change controlprocedures for applications must be developed, implemented and enforced. They mustensure that information security and control procedures are not compromised, thatsupport programmers are given access only to those parts of a system necessary toperform their jobs, and that formal agreement and approval processes for changes areimplemented. These change control procedures will apply to College applications aswell as systems software used to maintain operating systems, network software,hardware changes, etc.

B. In addition, access to source code libraries for both College applications andoperating systems must be tightly controlled to ensure that only authorized individualshave access to these libraries and that access is logged to ensure all access can be monitored.

Section 11. Compliance

The designs, operation, use and management of information systems are subject to legal and vendor contractual information security requirements.

Gramm-Leach-Bliley Act

A. The Gramm-Leach-Bliley Act (GLBA) requires “financial institutions” as defined bythe Federal Trade Commission (FTC), to protect and secure customer information suchas names, Social Security numbers, addresses, account and credit card information.The GLBA sets forth extensive privacy rules which the College is deemed to be incompliance with because of its adherence to the provisions of the Family EducationRights and Privacy Act (FERPA). The GLBA also establishes a Safeguards Rule, fromwhich the College is not exempt, that requires the College to protect and safeguard customer information.

Payment Card Industry Data Security Standard

A. The Payment Card Industry Data Security Standard (PCI DSS) requires any entitythat collects credit card data to protect customer data and card numbers.throughsecurity management, policies, procedures, network architecture, software design and other critical protective measures. The College will comply with the PCI DSS.

Safeguarding of College Records

A. College records must be protected from loss, destruction or unauthorizedmodification. Some records may need to be retained in a secure manner for extendedperiods to meet state and Federal legal retention requirements, as well as to support essential operations.

B. The General Retention and Disposition Schedule for New York State GovernmentRecords contains guidelines for complying with legal, fiscal, and administrativerequirements for records retention and provides advice on management of records. TheCollege will develop procedures to dispose of any records in accordance with theprovisions of Section 57.05 of Arts and Cultural Affairs Law. New York State Archivesand Records Administration (SARA) issues general schedules to authorize the retentionand disposition of records.

C. Safeguards that will be taken to protect customer information include the following:• Computer access will be limited by user ID’s and passwords• Customer information stored in file cabinets will be accessible only to staff inoffices who need access and will be locked when not in use• Offices that have access to customer information will be locked after hours• Customer data will be backed up routinely• Passwords will expire periodically and employees must then reset them• Passwords will not be posted in publicly viewable places• Intrusion detection systems will monitor the College networks to allow the promptdetection of attacks and intrusions• Vulnerability scanning of systems containing customer information will beconducted periodically• Antivirus protection will be maintained on all computer systems• Designated staff members will supervise the disposal of records containingcustomer information• Erase all data when disposing of computers, diskettes, magnetic tapes, harddrives or any other electronic media that contains customer information• Inventories of all computer systems will be maintained• Reduce paper forms and documents through increased electronic access to thisinformation• Implement measures to ensure unauthorized persons cannot access Collegecomputer systems when left unattended • Avoid using Social Security numbers as a primary identification number

Prevention of Misuse of Information Technology Resources

The information technology resources and the data processed by these resources areprovided for College purposes. Management should authorize their use. Any use of ITfacilities or data for non-College or unauthorized purposes, without management’s consent, should be considered a misuse of College facilities.

Compliance

  1. Compliance with this IT Security program is mandatory. Each user must understandhis/her role and responsibilities regarding information security issues and protecting theCollege’s information assets. The failure to comply with this or any other informationsecurity program that results in the compromise of College information confidentiality,integrity, privacy, and/or availability may result in appropriate action as permitted by law,rule, regulation or negotiated agreement. The College will take every reasonable stepnecessary, including legal and administrative measures, to protect its information assets.
  2. The College Information Security Officer shall review this document annually. Ifsignificant changes are needed the ISO shall propose the changes to the President’sCabinet.
  3. The College managers and supervisors will ensure that all information securityprocesses and procedures within their areas of responsibility are followed. In addition,all units within the College may be subject to regular reviews to ensure compliance withinformation security policies and standards. Areas where compliance with the programrequirements is not met will be documented and reported to the College’s InformationSecurity Officer. For each area of non-compliance, a plan will be developed to address the deficiencies.

DEFINITIONS

Authenticity:

This is the exchange of security information to verify the claimed identity of acommunications partner. In security terms it is particularly to counter attempts to masquerade as an authorized user to enable new connections or associations.

Authorization:

The granting of rights, which includes the granting of access based on an authenticated identity.

Availability:

This is the ‘property’ of being available and usable upon demand by an authorized entity, e.g. a system or user.

Classification:

The designation given to information or a document from a defined category on the basis of its sensitivity to disclosure, modification or destruction.

Computer:

All physical, electronic and other components, types and uses of computers, includingbut not limited to hardware, software, central processing units, electroniccommunications and systems, databases, memory, Internet service, informationsystems, laptops, Personal Digital Assistants and accompanying equipment used tosupport the use of computers, such as printers, fax machines and copiers, and any updates, revisions, upgrades or replacements thereto.

Confidentiality:

The property that information is not made available or disclosed to unauthorized individuals, entities, or processes.

Controls:

Countermeasures or safeguards that are the devices or mechanisms that are needed to meet the requirements of program.

Cracking or Hacking:

Attempting to break into another system in which you have no account, and is treated as malicious intent.

Critical:

A condition, vulnerability or threat that could cause danger to data, a system, network, or a component thereof.

Customer:

Faculty, staff, students and others conducting business with the College.

Data:

The collection of information assets complied, generated or maintained to support the College.

Denial of Service:

An attack that takes up so much of the College’s resources that it results in degradation of performance or loss of access to the company’s business services or resources.

Disaster:

A condition in which an information asset is unavailable, as a result of a natural or manmadeoccurrence, that is of sufficient duration to cause significant disruption in the accomplishment of the College’s objectives as determined by College management.

Encryption:

The cryptographic transformation of data to render it unintelligible through an algorithmic process using a cryptographic key.

Firewall:

A security mechanism that creates a barrier between an internal network and an external network.

GLBA:

The Gramm-Leach-Bliley Act was passed by Congress in 1999 to protect the privacy and security of customer financial information.

Host:

A system or computer that contains business and/or operational software and/or data.Incident Response: The manual and automated procedures used to respond to reportednetwork intrusions (real or suspected); network failures and errors; and other undesirable events.

Information:

Information is defined as the representation of facts, concepts, or instructions in aformalized manner suitable for communication, interpretation, or processing by human or automated means.

Information Assets:

  1. All categories of automated information, including but not limited to: records, files,and databases, and
  2. information technology facilities, equipment (including microcomputer systems), and software owned or leased by the State.

Information Owner:

An individual or organizational unit having responsibility for making classification and control decisions regarding use of information.

Information Security:

The protection of automated information from accidental or intentional unauthorized access, modification, destruction, or disclosure.

Instant Messaging (IM):

The ability to exchange short messages online with co-workers or others. IM solutionscan take several forms. They can use an existing Internet based service, or they can bean Intranet only solution implemented and controlled within an IT department. The latter is significantly more secure than the former, but lacks access to business partners.

Integrity:

The property that data has not been altered or destroyed from its intended form or content in an unintentional or an unauthorized manner.

Internet:

This shall mean a system of linked computer networks, international in scope, thatfacilitate data transmission and exchange, which all use the standard Internet protocol, TCP/IP, to communicate and share data among each other.

Intranet:

The Intranet is an internal (i.e., non-public) network that uses the same technology and protocols as the Internet.

Intrusion Detection:

The monitoring of network activities, primarily through automated measures, to detect,log and report upon actual or suspected authorized access and events for investigation and resolution.

ISO: Information Security Officer

Non-Repudiation: un-forgeable evidence that a specific action occurred. This actioncould be the transmission of an electronic message, the competition of a transaction, orsome other action.PCI DSS:The Payment Card Industry Data Security Standard was adopted to assure the protection of customer data and credit card numbers.

Physical Security:

The protection of information processing equipment from damage, destruction or theft;information processing facilities from damage, destruction or unauthorized entry; and personnel from potentially harmful situations.

Privacy:

The right of individuals and organizations to control the collection, storage, and dissemination of information about themselves.

Privileged Account:

The user-ID or account of an individual whose job responsibilities require specialsystem authorization, such as a network administrator, security administrator, etc.Special authorizations are allocated to this account such as RACF Administrator, auditor, Special or UNIX root.

Procedures:

Specific operational steps that individuals must take to achieve goals stated in this program.

Remote Access Server (RAS):

A server that allows users to gain access to a LAN from a remote location. Once a userhas authenticated he can access network resources as if he were physically connected to the LAN.

Risk:

The likelihood or probability that a loss of information assets or breach of security will occur.

Risk Assessment:

The process of identifying threats to information or information systems, determining thelikelihood of occurrence of the threat, and identifying system vulnerabilities that could be exploited by the threat.

Risk Management:

The process of taking actions to assess risks and avoid or reduce risk to acceptable levels.

Security Management:

The responsibility and actions required to manage the security environment including the security policies and mechanisms.

Security Program:

The set of criteria for the provision of security services based on global rules imposedfor all users. These rules usually rely on a comparison of the sensitivity of the resourcesbeing accessed and the possession of corresponding attributes of users, a group of users, or entities acting on behalf of users.

Sensitivity:

This, in terms of confidentiality, would cause a negative impact to the organization if the information were leaked or disclosed.

Sniffing:

Monitoring network traffic.

Spamming:

Blindly posting something to a large number of groups.

Spoofing:

Representing yourself as someone else.

Standard:

Sets of rules for implementing program. Standards make specific mention of technologies, methodologies, implementation procedures and other detail factors.

State:

Shall mean the State of New York.

Technical Security Review:

A technical security review would consist of reviewing the controls built into a system orapplication to ensure they still perform as designed. It would also include reviewingsecurity patches to ensure they have been installed and are operational, review of security rules such as access control lists for currency, testing of firewall rules, etc.

The College:

The State University of New York, College at Oneonta

Third Party:

Any non-College entity such as a contractor, vendor, consultant, another College, etc.

Threat:

A threat is a force, organization or person, which seeks to gain access to, orcompromise, information. A threat can be assessed in terms of the probability of anattack. Looking at the nature of the threat, its apability and resources, one can assess it, and then determine the likelihood of occurrence, as in risk assessment.

Trojan Horse:

Illegal code hidden in a legitimate program that when executed performs some unauthorized activity or function.

Unauthorized Access Or Privileges:

Insider or outsider who gains access to network or computer resources without permission.

USENET News group:

A USENET news group is a bulletin board where people can read or post Netnewsmessages on specific topics. There are many specialized business news groups. Manynews groups are subscribed to by experts in the given topic and these individuals can provide valuable information and will sometimes respond to direct queries.

User:

One who has authorized access to information on a computer. The authorization may include the ability to add or update information as well as access.

Virus:

Any security threat that executes in a manner so that computer resources are damaged, lost or otherwise occupied so they are unavailable.

VPN:

Virtual Private Network. Internet protocol (IP) virtual private networks (VPNs) are acollection of technologies that ensure the privacy of data over a shared unsecured IPnetwork infrastructure. The two key points as to what constitutes an IP VPN are privacy and an IP network.

Vulnerability:

A weakness of a system or facility holding information which can be exploited to gainaccess. Vulnerability can be assessed in terms of the means by which the attack would be successful.

World Wide Web (WWW):

The World Wide Web is a hypertext-based system designed to allow access toinformation in such a way that the information, may physically reside on locally orgeographically different servers. This access was greatly improved through theintroduction of a graphical interface to the World Wide Web called a web browser. Netscape and Internet Explorer are two of the most popular web browsers.

Worm:

A program similar to a virus that can consume large quantities of network bandwidth and spread from one network to another.

Effective Dates

• Approved by the President on 3/27/2005

• Revised on 9/25/2010