Contributed by: Nancy A. Nasca, Manager, Institute Audit, Compliance & Advisement
Whether you handle Private student information and are bound by FERPA requirements, work with chemicals in the labs and are required to comply with OSHA regulations, or perform research internationally and must be cognizant of Export Control rules, there is a high likelihood that your responsibilities at RIT are affected by multiple Federal and State regulations. In addition to performing financial and operational audits, Institute Audit, Compliance & Advisement (IACA) also performs regulatory compliance audits. The objective of these audits is not only to evaluate whether RIT is in compliance with relevant Federal and State regulations, but to evaluate whether there are adequate procedures in place at RIT to promote and monitor compliance with these regulations.
To promote compliance with Federal and State regulations, RIT has multiple policies in place which specifically address procedures which must be followed in order to comply with these laws such as: RIT’s Educational Records Policy which addresses FERPA; Policy Prohibiting Discrimination and Harassment which addresses key requirements of both Title IX and the Americans with Disabilities Act; and the Foreign Corrupt Practices Act(FCPA), the policy which addresses the law with the same name, to name a few. In addition, at the college and departmental level, additional policies and procedures have been created in order to promote compliance with relevant regulations. For example, The Department of Environmental, Health and Safety (EH&S) has created laboratory standard operating procedures which address proper chemical storage, proper handling of particularly hazardous chemicals, and use of proper personal protective equipment consistent with OSHA requirements.
Another important aspect of promoting compliance with Federal and State regulations is providing training to faculty, staff and students. RIT’s Center for Professional Development offers many courses both in a classroom or e-learning setting which include information to educate faculty, staff, and students regarding relevant Federal and State requirements such as lab safety training, compliance and conflict of interest programs, and RIT’s Policy on Prohibiting Harassment and Discrimination. In addition, there are numerous external resources available (i.e., conferences, webinars, governmental websites) to educate RIT faculty, staff, and students on regulatory requirements. The Higher Education Compliance Allianceis a great website to obtain information regarding laws and regulations relevant to universities.
Subsequent to verifying that there are adequate procedures in place to promote compliance with a particular Federal or State regulation, IACA will assess whether there is adequate monitoring and oversight by department management in place to evaluate the effectiveness of these procedures. For example, EH&S performs periodic inspections of RIT labs to verify compliance with RIT policies and procedures (which are consistent with Federal and State regulatory requirements). IACA’s compliance audits also serve as a process employed by RIT senior management to monitor whether RIT has adequate procedures in place to ensure compliance with Federal and State laws and regulations which could have a significant impact on operations.
Ultimately, it is each employee’s responsibility to ensure that you are aware of the key regulations which affect your area of operations and to discuss any questions or concerns regarding compliance with these laws with your supervisor or other knowledgeable resource (i.e., Office of Legal Affairs, EH&S, Information Security Office, Human Resources Department).
Contributed by: Ben Woelk, Program Manager, RIT Information Security Office, firstname.lastname@example.org
Inform RIT is a recurring column provided by the RIT Information Security Office. The column highlights current issues and initiatives that impact the RIT community.
Changes to the Desktop and Password Security Standards and How They Will Affect You
After a lengthy review process, a number of new and revised security standards were approved for the RIT community this past summer. Most of the new and revised standards are effective January 23, 2015, although their implementation will occur over the next several months. In this issue, we’ll talk about changes to the Desktop and Portable Computer and Password Standards and how they affect you. You can access all of the information security standards on the RIT Information Securitywebsite.
Desktop and Portable Computer Security Standard (revised)
The Desktop and Portable Computer Security Standard provides requirements for allcomputers that connect to the RIT network, excluding computers that connect only through their web browsers.
The key changes that impact end users are around encryption and managing Private Information. All systems (laptop or desktop) that access Private Information will be encrypted. (Previously, all laptop computers were encrypted, regardless of whether or not they accessed Private Information.) At the discretion of your deans and vice presidents, any systems (laptop or desktop) that do not access Private Information and that report no unprotected matches in the Identity Finder scan reports mayhave encryption removed. (You will still need to run monthly Identity Finder scans and remediate any unprotected matches.)
Note that lab computers and grant-funded computers that don’t access Private Information are not required to run Identity Finder. If you have any questions about whether a computer is required to run Identity Finder or about encryption requirements in your area, contact your PIMI rep.
What remains the same?
The standard requires appropriate security software and settings on each computer. For most RIT computers, that includes centralized management, anti-virus or a host-based intrusion prevention system, an endpoint firewall, software with up-to-date patches, and automatic log out/lockout. Note that implementation of the requirement for host-based vulnerability management is pending product selection.
The Password/Passphrase Standard provides requirements around password length and complexity, change frequency, and storage of passwords.
Length and complexity
The standard requires passwords of at least 8 characters. The passwords should include an upper case letter, a lower case letter, a number, and a symbol. (Requiring a symbol is the new part.)
We encourage you to start using a passphrase instead of a jumble of letters, numbers, and symbols. A long passphrase is easier to remember and harder for a hacker to break than a short jumble. (An example of a long passphrase is Itwas&theBestof45Times.)
Another change is that we’ve lengthened the time a password can be used from 120 days to one year. That change will make it easier to keep your passwords on your mobile devices in synch. You’ll still need to change passwords if you’ve shared the password, if there’s a possible compromise, or if you’re using a default/temporary password.
We don’t want you to write down your passwords. However, if you do, you should secure them physically. If you’re storing them digitally, they must be encrypted. It’s not a good practice to store them in a spreadsheet on your desktop. (You may find a password safe/vault helpful. There are a number of good choices, including KeePass, Password Gorilla, and LastPass.)
Committee of Sponsoring Organizations of the Treadway Commission (COSO) Corner
Contributed by: Nancy A. Nasca, Manager, Institute Audit, Compliance & Advisement, email@example.com
As explained in previous editions of the Quaestor Quarterly, the COSO Framework (an internationally recognized standard with which the adequacy and effectiveness of an organization’s internal controls are evaluated) was updated in May 2013 to further define the principles underlying the five components of internal control (Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring). According to the Framework, these principles are fundamental concepts that must be present and functioning in order to achieve an effective system of internal control.
In addition, the Framework includes points of focus or characteristics that are examples of behaviors or processes that would be expected to be in place to demonstrate that the related principle is in fact present and functioning. This edition of the COSO Corner will summarize the fourth principle relating to the Control Environment component of the COSO Framework, as well as the related points of focus.
Principle 4 – The organization demonstrates a commitment to attract, develop, and retain competent individuals in alignment with objectives:
Policies and procedures are developed to reflect expectations of competence necessary to achieve the organization’s objectives. These policies and procedures provide accountability and support effective decision making by providing guidance on acceptable employee conduct.
Competence requirements such as knowledge, skills, and experience are defined to support the achievement of the organization’s objectives. The Board of Trustees and senior management evaluate competence across the organization and act as necessary to address any shortcomings or excesses.
Sufficient and competent personnel are attracted, developed (mentored and trained), and retained in support of the organization’s business objectives and strategic plan.
Management identifies and assesses those functions that are deemed essential to achieving the organization’s objectives and develops contingency and/or succession plans for assigning key responsibilities in the absence of the individuals filling those functions.
Committee of Sponsoring Organizations of the Treadway Commission (May 2013). “Internal Control – Integrated Framework – Framework and Appendices”
Additional Information by IACA
Watch IACA’s Monday Minute video series here!
Our video series focuses on opportunities for improving internal controls and increasing awareness of various university processes, policies, and protocols. If you have questions, feel free to contact anyone in the IACA office using information on our webpage.
Just to name a few, past topics include: Travel Policy changes, FERPA Regulations, RIT’s Ethics & Compliance Hotline, Records Management Policy, Risk Assessment, and many others.