Information Technology Security and Compliance Statement


Topic: Information Technology Solution Provider Security Statement


Overview

A solution provider, software solution provider, or vendor, hereafter called "Solution Provider", will receive this document if Oakland University (“University” or “the University”):

· Intends to purchase or contract outsourced, hosted, software as a service, web site service, application service provider application, on-premise software solution, or similar service from a vendor; or

· Intends to transmit or relocate data currently and actively resident in an on-premise information technology resource to a Solution Provider or between software solutions; or

· Intends to have a Solution Provicer or vendor collect or capture data on behalf of the University or for subsequent use by the University.

The document defines the minimum security and operational criteria that the Solution Provider must provide to engage in business with the University. Solution Provider must comply with or submit materials in compliance with those statements for which a particular standard or security protocol is identified. Such compliance shall continue for the duration of the agreement, purchase order, or contract (“Agreement”).

Security Statement

1.0 Audit and Compliance

  1. The Solution Provider must submit relevant statements of security practice:
    1. Attestation of Compliance with Payment Card Industry Data Security Standards https://www.pcisecuritystandards.org/ Required for Solution Provider solutions that involve payment card processing. Specific contract language may be required. Please review Payment Card PCI Compliance documentation if payment (credit) card processing is involved.

    2. Higher Education Cloud Vendor Assessment Tool Required for cloud solutions.

    3. Certification of the product by Common Criteria https://www.commoncriteriaportal.org/ Optional.

    4. Statement from auditor for compliance with ISO/IEC 27001:2013 or later.
    5. Statement from auditor for compliance with SAS 70 / SSAE 16.
    6. Statement from auditor for compliance with Health Insurance Portability and Accountability Act (HIPAA/HiTech) regulations; required for HIPAA related processing.
    7. Statement describing compliance with the EU General Data Protection Regulation (GDPR) if processin Personal Data; include a copy of GDPR Privacy Statement.
  2. The University is committed to enabling equally effective, integrated, and independent access to information through information technologies, databases, services and resources to all constituents with disabilities as described in University policy. Solution Provider must submit statement of accessibility compliance. Solution Providers are required to demonstrate that the proposed solution conforms to or addresses each of the W3C's Web Content Accessibility Guidelines (WCAG) Level AA (including Level A). Solution Providers may submit a Voluntary Product Accessibility Template (VPAT) 2.0 based on WCAG 2.0 Level AA. The VPAT 2.0 template is available from the Information Technology Council. Alternatively, the Solution Provider may submit an independent third party evaluation from a qualified accessibility consultancy.

  3. The University aggressively protects copyrighted material, and all University logos, emblems, images, and gif files must be used only with University approval. Solution Provider must destroy all related University material at the end of the Agreement.
  4. Solution Provider must present evidence insurance according to University Risk Management standards, Information Technology Services.

  5. Solution Provider must demonstrate compliance with relevant data privacy laws and regulations. Compliance with the Family Educational Rights and Privacy Act (FERPA), if student records are involved in the process. Solution Provider must provide information about compliance with the General Data Privacy Regulation, if personally identifiable data are involved in the process. If medical records are involved, Solution Provider must provide statements of compliance to medical records laws or HIPAA, as appropriate.

  6. Solution Provider must demonstrate ability to comply with E-Evidence legal preservation at the request of the university.

2.0 Data Controls

  1. A data integration plan must be discussed. What data elements are being sent by the university to the vendor and what data elements are being sent from the vendor to the university?
  2. If ERP integration is planned, describe data integration for Ellucian Banner Release 9. Include description for how Ellucian APIs are used. Describe both initial data load and ongoing data integration.
  3. Solution Provider will store University data only in data centers located within the United States, meeting or exceeding network, host, and physical security standards commonly found acceptable by regulatory agencies or organizations (i.e., PCI -DSS 2.0 or later).
  4. Solution Provider agrees to keep University information and data private and confidential, and to treat information and data confidentially except as specifically provided for in the Agreement. Data cannot be shared with or sold to third parties.
  5. Solution Provider will use data encryption standards commonly found acceptable in by regulatory agencies or organizations (i.e., PCI -DSS 2.0 or later) for the protection of University data matching the State of Michigan law for Personally Identifiable Information.
  6. Solution Provider will provide capabilities for storing and processing full Legal Name and Preferred First Name if any name service (student name, employee name, etc.) is included in the solution.
  7. Solution Provider will provide data in response to University request in a preservation standard consistent with industry best practices for forensic retrieval, for review and use in connection with law enforcement, human resource management, litigation, or contested matters in all forums, audits and for the University’s own use.
  8. Solution Provider will notify the University contact assigned for this engagement in the event of accidental data exposure, access of data by unauthorized parties or individuals, request for data by law enforcement, or any other third-party access to University data, within 48 hours of request or discovery.
  9. Standards for data quality are established by the University and enforced by the Solution Provider. The Solution Provider must meet the University standards for the quality and integrity of data. The University retains the right to approve the quality of data displayed on web sites; the Solution Provider will remove any University data from any web site based on the University noting a lack of quality. Processes that gather, edit, modify, calculate or otherwise manipulate data must meet University standards for data quality. The University must approve the sources of data and the data maintenance method.

3.0 Identity Access and Accounts Management

  1. The University and the Solution Provider will determine a secure access identity infrastructure process for the solution, including a unique login identity and password that is encrypted in storage and at rest for account users. The University and Solution Provider will determine the best practices for issuing login accounts, password attributes, password resets, and other access identity management processes using standard industry practices for security and privacy, with the University solely responsible for the final solution decision.
  2. The University requires that the proposed solution meet University identity access management standards. Login processes can authenticate using Single Sign On for InCommon Federation, Shibboleth IDP Version 3.3x or higher, CAS protocol 2.0 or higher, openLDAP/RedHat Directory Server 10.3 or higher, and Active Directory within the University Identity Access Management Environment. ADFS is not an option at this time. Solution Provider must indicate whether the firm is a member of InCommon Federation. If not a member of InCommon, describe the login management process using Shibboleth Version IDP 3.3.x or higher, CAS protocol 2.0 or higher, or openLDAP/RedHat Directory Server 10.3 or higher.

  3. If none of the preferred processes are usable, please describe the process. If the Solution Provider is providing identity access accounts for the solution, will provide a unique login identity and password that is encrypted in storage and at rest. Solution Provider will manage issuing login accounts, password attributes, password resets, minimum password length, password generation guidelines, password expiration, and other access identity management processes using standard industry practices for security and privacy. Describe in detail the following processes:
    • Creating new accounts
    • Suspending accounts for temporary security reasons
    • Terminating accounts
    • Password resets
    • Password security protocols
    • Name changes
  4. Solution Provider changes system default and system administration passwords on implementation and regularly thereafter following standard security best practices.

4.0 Technical and Network Architecture

  1. Solution Provider must supply any specific firewall rules, custom domain names, email configurations, messaging integration, or other configurations required for successful network and communications connectivity to the Solution Provider solution. Solution Provider should supply a full network architecture diagram that details traffic flows and communication requirements, such as network ports, protocols, and applications. Costs and project delays associated with missing or incomplete documentation will be the sole responsibility of the Solution Provider.
  2. If proposing an on-premise solution, provide high-level diagrams and a description of the proposed architecture.
  3. Solution Provider will provide a test environment available to the University for upgrades and ongoing product testing and verification.
  4. Describe how technology upgrades are handled and university control of the timing of upgrades. If proposing a cloud or software-as-a-service solution, provide a cadence for planned outages including time zone considerations for Eastern Time Zone.
  5. Mobile architectures implemented with Responsive Web Design are preferred.
  6. Describe storage limits or record limites associated with the proposed solution. Describe when additional storage or record purchases are necessary. If proposing a cloud or software-as-a-service solution, describe any limitations for storage and archival of data. Are there any capacity limitations on the number of years or amount of data? Number of students? Number of faculty? Number of courses?

5.0 Host Security and Service Health

  1. Solution Provider will maintain the security of hosts (Unix, Windows, etc.) comprising the University application and server infrastructure will be hardened against attack.
  2. Solution Provider will meet minimum service level agreement of 99.9% uptime. Service up time is guaranteed to 99.9% (Consider: 365 days a year, 24 hours a day = 8,760 hours x 99.9% up time = 8,751.24 hours. That means that there would be roughly 1 full business day of system unavailability every year.)
  3. If the Solution Provider proposes an Agreement that provides that the University is responsible for notifying or providing evidence to the Solution Provider that the service being utilized was degraded or unavailable, then the Solution Provider shall maintain an online, customer-facing, near real-time service health dashboard. The dashboard shall be provided to University for review on an ongoing basis and will include a history of application and service health for the last calendar quarter (as a minimum). Examples of service health that provide models include:

6.0 Email Communications

  1. Describe any email notifications process, the types of emails that are system-generated, and the actions that trigger these emails.
  2. Preference is given to systems where individuals can set personal email preferences.
  3. The application administrator must be able to disable specifice email messages.
  4. Describe the ability to customize email message content.
  5. If messages contain hyperlinks, what will the recipient see when hovering and what will the recipient obtain by clicking on the hyperlink?
  6. Describe all domains used for sending email; does the solution send mail for muliple domains from the same server?
  7. Solutions must comply with Google's Bulk Senders Guidelines.

  8. Email must stay within the single user limits outlined in Google G Suite Sending Limits.

  9. The University will not whitelist an entire hosting domain. Solutions must state if the service requires the use of email address, domain, or IP address whitelisting for successful communications.
  10. Solutions must describe any requirements such as adding SPF records or DKIM keys to DNS for the University domain in order for message delivery to be successful.
  11. Identify FROM addresses for email and whether the REPLY-TO is the same as the FROM address.
  12. Services are required to have a valid MX, A, and PTR record for email servers.
  13. Preferences is given to a solution that requires SMTP Authentication.
  14. In general, compliance with Common Internet Message Headers is expected.

For further help, please email <<MailTo(uts@oakland.edu)>>.

November 2018