Customer Information Security Program

Policy Number: 
Reason for Policy: 

Summarizes the University of Oregon's comprehensive written information security program (the "Program") mandated by the Federal Trade Commission's Safeguards Rule and the Gramm-Leach-Bliley Act (GLBA). In particular, this document describes the Program elements pursuant to which the Institution intends to (i) ensure the security and confidentiality of covered records, (ii) protect against any anticipated threats or hazards to the security of such records, and (iii) protect against the unauthorized access or use of such records or information in ways that could result in substantial harm or inconvenience to customers. The Program incorporates procedures enumerated below and is in addition to any institutional policies and procedures that may be required pursuant to other federal and state laws and regulations, including, without limitation, FERPA.

Entities Affected by this Policy: 

University community

Responsible Office: 

For questions about this policy, please contact the Chief Information Officer at 541-346-1702,

Enactment & Revision History: 

03/30/16: Technical revisions made by the University Secretary and policy number revised from 01.00.12 to IV.06.06

02/08/2010  Policy number revised from 3.100 to 01.00.12

11/2003 Reviewed and Recommended by President Dave Frohnmayer


Designation of Representatives: The Vice President for Student Affairs will designate a Program Officer who shall be responsible for coordinating and overseeing the Program. The Program Officer may designate other representatives of the Institution to oversee and coordinate particular elements of the Program. Any questions regarding the implementation of the Program or the interpretation of this document should be directed to the Program Officer or his or her designees.

Scope of Program: The Program applies to any record containing nonpublic financial information about a student whether in paper, electronic or other form, that is handled or maintained by or on behalf of the Institution or its affiliates. For these purposes, the term nonpublic financial information shall mean any information (i) a student provides in order to obtain a financial service from the Institution, (ii) about a student resulting from any transaction with the Institution involving a financial service, or (iii) otherwise obtained about a student in connection with providing a financial service to that person.

Policy: The Program Officer will oversee and coordinate a comprehensive written information security program as mandated by the Federal Trade commission's Safeguards Rule and the Gramm-Leach-Bliley Act.

Elements of the Program:

1. Risk Identification and Assessment. The Institution intends, as part of the Program, to undertake to identify and assess external and internal risks to the security, confidentiality, and integrity of nonpublic financial information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information. In implementing the Program, the Program Officer will establish procedures for identifying and assessing such risks in each relevant area of the Institution's operations, including:

  • Employee training and management. The Program Officer will coordinate with institutional representatives to evaluate the effectiveness of the Institution's procedures and practices relating to access to and use of student records, including financial aid information. This evaluation will include assessing the effectiveness of the Institution's current policies and procedures in this area, including, 05.00.04, Student Records Policy and UO Policy 571.020, (Student Records.
  • Information Systems and Information Processing and Disposal. The Program Officer will coordinate with representatives of the Computing Center to assess the risks to nonpublic financial information associated with the Institution's information systems, including network and software design, information processing, and the storage, transmission and disposal of nonpublic financial information. This evaluation will include assessing the Institution's current Acceptable Use Policy, Records Retention Policy and procedures for Confidential Document Destruction. The Program Officer will also coordinate with the Computing Center to assess procedures for monitoring potential information security threats associated with software systems and for updating such systems by, among other things, implementing patches or other software fixes designed to deal with known security flaws.
  • Detecting, Preventing and Responding to Attacks. The Program Officer will coordinate with the Computing Center to evaluate procedures for and methods of detecting, preventing and responding to attacks or other system failures and existing network access and security policies and procedures, as well as procedures for coordinating responses to network attacks and developing incident response teams and policies. In this regard, the Program Officer may elect to delegate to a representative of the Computing Center the responsibility for monitoring and participating in the dissemination of information related to the reporting of known security attacks and other threats to the integrity of networks utilized by the Institution.

2. Designing and Implementing Safeguards. The risk assessment and analysis described above shall apply to all methods of handling or disposing of nonpublic financial information, whether in electronic, paper or other form. The Program Officer in coordination with appropriate institutional representatives will, on a regular basis, evaluate safeguards to control the risks identified through such assessments and to regularly test or otherwise monitor the effectiveness of such safeguards. Such testing and monitoring may be accomplished through existing network monitoring and problem escalation procedures.

3. Overseeing Service Providers. The Program Officer shall coordinate with those responsible for the third party service procurement activities among relevant parties (e.g. the Business Affairs Office) and other affected departments to raise awareness of, and to institute methods for, selecting and retaining only those service providers that are capable of maintaining appropriate safeguards for nonpublic financial information of students. In addition, the Program Officer will work with the Office of the General Counsel to develop and incorporate standard, contractual protections applicable to third party service providers, which will require such providers to implement and maintain appropriate safeguards. Any deviation from these standard provisions will require the approval of the Office of the General Counsel. These standards shall apply to all existing and future contracts entered into with such third party service providers, provided that amendments to contracts entered into prior to June 24, 2002 are not required to be effective until May 2004.

4. Adjustments to Program. The Program Officer is responsible for evaluating and adjusting the Program on a periodic basis based on the risk identification and assessment activities undertaken pursuant to the Program, as well as any material changes to the Institution's operations or other circumstances that may have a material impact on the Program.

  • Volume IV: Finance, Administration and Infrastructure
  • Chapter 6: Information technology