Information Security Policy 

 

Policy Number:

OPER_0043

Contents

1. Introduction
2. Information Security Policy
3. Acceptable Use Policy
4. Disciplinary Action
5. Protect Stored Data
6. Information Classification
7. Access to the sensitive card holder data
8. Physical Security
9. Protect Data in Transit
10. Disposal of Stored Data
11. Security Awareness and Procedures
12. Network security
13. System and Password Policy
14. Anti-virus policy
15. Patch Management Policy
16. Remote Access policy
17. Vulnerability Management Policy
18. Configuration
19. Change Control Process
20. Audit and Log review
21. Secure Application development
22. Penetration testing methodology
23. Incident Response Plan

• Garden City Community College Incident Response Team:
• VISA Steps
• MasterCard Steps
• Discover Card Steps
• American Express Steps

24. Roles and Responsibilities
25. Third party access to sensitive data
26. User Access Management
27. Access Control Policy
28. Wireless Policy
29. Identity Theft Policy “Red Flag Rule”

Definitions

Applicability

Sensitive Information to be protected:

Risk Assessment

Suspicious Documents

Suspicious Personal Identifying Information

Unusual use of, or Suspicious Activity Related to the Covered Account

Protective Actions to be Taken

Detection of Red Flags GCCC shall address the detection of Red Flags in connection with the opening of Covered Accounts by:

Response to Red Flags

Oversight of Service Providers

Non-disclosure of Specific Practices

Annual Updates

Program Administration

Appendix B

List of Service Providers

 

 

 

1.       Introduction

This Policy Document encompasses all aspects of security surrounding confidential Garden City Community College information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and understand this policy fully.

This document will be reviewed and updated by Director of Information Technology on an annual basis or, when relevant, include newly developed security standards. Policy updates will be distributed to all employees and contracts as applicable.

2.       Information Security Policy

Garden City Community College handles sensitive information daily. Safeguards must be in place to protect sensitive information, to protect privacy, to ensure compliance with various regulations and to guard the future of the organization.

Garden City Community College commits to respecting the privacy of all its employees and students and protecting any data about them from outside parties. To this end the college is committed to maintaining a secure environment in which to process information so that we can fulfill these promises.

Employees handling Sensitive data should ensure:

• Handle Garden City Community College and sensitive information in a manner that fits with their sensitivity;
• Limit personal use of Garden City Community College information and telecommunication systems and ensure it doesn’t interfere with your job performance;
• Not to use e-mail, INTERNET and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
• Not to disclose personnel information unless authorized;
• Protect sensitive information;
• Keep passwords and accounts secure;
• Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
• Not to install unauthorized software or hardware, including modems and wireless access unless you have explicit management approval;
• Always leave desks clear of sensitive data and lock computer screens when unattended;
• Report information security incidents, without delay, to the individual responsible for local incident response.

We each have a responsibility for ensuring our company’s systems and data are protected from unauthorized access and improper use.  Garden City Community College reserves the right to monitor, access, review, audit, copy, store or delete any electronic communications, equipment, systems and network traffic for any purpose. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your director.

3.       Acceptable Use Policy

The Administration's intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Garden City Community College’s established culture of openness, trust and integrity. Garden City Community College Administration is committed to protecting the college, employees and partners from illegal or damaging actions by individuals, either knowingly or unknowingly. The IT department will maintain an approved list of technologies and devices and personnel with access to such devices, as detailed in Appendix B.

• Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
• Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies
• Employees should take all necessary steps to prevent unauthorized access to confidential data.
• Employees should ensure that technologies should be used and setup in acceptable network locations.
• Employees should keep passwords secure and do not share accounts.
• Authorized users are responsible for the security of their passwords and accounts.
• All PCs, laptops and workstations should be secured with a password-protected screen saver with the automatic activation feature.
• All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
• Because information contained on portable computers is especially vulnerable, special care should be exercised.
• Postings by employees from a company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Garden City Community College, unless posting is in the course of business duties.
• Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.

 

 

4.       Disciplinary Action

Violation of the standards, policies and procedures presented in this document by an employee will result in disciplinary action, from warnings or reprimands up to and including termination of employment. Claims of ignorance, good intentions or using poor judgment will not be accepted as excuses for non-compliance. 

5.       Protect Stored Data

• All sensitive data stored and handled by Garden City Community College and its employees must be securely protected against unauthorized use at all times. Any sensitive data that is no longer required by Garden City Community College for business reasons must be discarded in a secure and irrecoverable manner.
• If there is no specific need to see the full PAN (Permanent Account Number), must be masked when displayed.
• PANS, which are not protected as stated above, should not be sent to the outside network via end user messaging technologies like chats, ICQ messenger, etc.

 

It is strictly prohibited to store:

• The contents of the payment card magnetic stripe (track data) on any media whatsoever.
• The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
• The PIN or the encrypted PIN Block under any circumstance.

6.       Information Classification

Data, and media containing data, is required to be labelled to indicate sensitivity level.

• Confidential data might include information assets for which there are legal requirements preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to Garden City Community College if disclosed or modified. Confidential data includes cardholder data.
• Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure;
• Public data is information that may be freely disseminated.

 

7.       Access to the sensitive card holder data

All Access to sensitive card holder data should be controlled and authorized. Any job functions that require access to card holder data should be clearly defined.

• Any display of the card holder should be restricted at a minimum of the first 6 and the last 4 digits of the card holder data.
• Access rights to privileged user ID’s should be restricted to uses necessary to perform job responsibilities
• Privileges should be assigned to individuals based on job classification and function (Role based access control)
• Access to sensitive card holder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
• No other employees should have access to this confidential data unless otherwise authorized.
• If card holder data is shared with a Service Provider (3^rd party) then a list of such Service Providers will be maintained as detailed in Appendix B.
• Garden City Community College will ensure a written agreement is in place that includes an acknowledgment that the Service Provider will be responsible for the for the card holder data that the Service Provider possesses.
• Garden City Community College will ensure that a there is an established process, including proper due diligence, is in place before engaging with a Service provider.
• Garden City Community College will have a process in place to monitor the PCI DSS compliance status of the Service provider.

 

 

8.       Physical Security

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorized individuals from obtaining sensitive data.

• Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
• Media containing sensitive information must be handled and distributed in a secure manner by trusted individuals.
• Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Garden City Community College sites.
• A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day. Visitors must always be escorted by a trusted employee when in areas that hold sensitive information.
• Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
• Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies
• Employees should take all necessary steps to prevent unauthorized access to confidential data.
• Employees should ensure that technologies should be used and setup in acceptable network locations.
• A list of devices that accept payment card data should be maintained.
• This list should include make, model and location of the device, the serial number or a unique identifier of the device and should be updated when devices are added, removed or relocated
• POS devices surfaces should be periodically inspected to detect tampering or substitution.
• Personnel using POS devices should be trained and aware of handling procedures.
• Personnel using the devices should verify the identity of any third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
• Personnel using the devices should be trained to report suspicious behavior and indications of tampering of the devices to the appropriate personnel.
• Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.
• Network Jacks located in public and areas accessible to visitors must be disabled and enabled when network access is explicitly authorized.
• All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
• Strict control is maintained over the external or internal distribution of any media containing data and has to be approved by the department director or administration.
• Strict control is maintained over the storage and accessibility of media
• All computers that store sensitive data must have a password protected screen saver enabled to prevent unauthorized use.

 

 

9.       Protect Data in Transit

• All sensitive data must be protected securely if it is to be transported physically or electronically.
• Sensitive data (PAN, track data, etc) must never be sent over the INTERNET via email, instant chat or any other end user technologies.
• If there is a business justification to send data via email, the INTERNET or any other modes then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, SSL,TLS,IPSEC, GSM, GPRS, Wireless technologies etc.,).
• The transportation of media containing sensitive data to another location must be authorized by the department director or administration, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.
  
  

10.   Disposal of Stored Data

• All data must be securely disposed of when no longer required by Garden City Community College, regardless of the media or application type on which it is stored.
• An automatic process must exist to permanently delete on-line data, when no longer required.
• All hard copies of data must be manually destroyed as when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic data has been appropriately disposed of in a timely manner.
• Garden City Community College has procedures for the destruction of hard copy (paper) materials. These will require that all hard copy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
• Garden City Community College will have documented procedures for the destruction of electronic media. These will require:
  • All data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
  • If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.
• All information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” - access to these containers must be restricted.

 

 

11.   Security Awareness and Procedures

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors. 

• Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
• Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A)
• All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with Garden City Community College.
• All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
• Company security policies must be reviewed annually and updated as needed.

12.   Network security

• Firewalls must be implemented at each INTERNET connection and any demilitarized zone and the internal company network.
• A network diagram detailing all the inbound and outbound connections must be maintained and reviewed every 6 months.
• A firewall and router configuration document must be maintained which includes a documented list of services, protocols and ports including a business justification.
• Firewall and router configurations must restrict connections between untrusted networks and any systems in the data environment.
• Stateful Firewall technology must be implemented where the Internet enters Garden City Community College network to mitigate known and on-going threats. Firewalls must also be implemented to protect local network segments and the IT resources that attach to those segments such as the business network, and open network.
• All inbound and outbound traffic must be restricted to that which is required for the data environment.
• All inbound network traffic is blocked by default, unless explicitly allowed and the restrictions have to be documented.
• All outbound traffic has to be authorized by the IT department (i.e. what are the white-listed category of sites that can be visited by the employees) and the restrictions have to be documented
• Garden City Community College will have firewalls between any wireless networks and the data environment.
• Garden City Community College will quarantine wireless users into a DMZ, where they will be authenticated and firewalled as if they were coming in from the Internet.
• Disclosure of private IP addresses to external entities must be authorized.
• A topology of the firewall environment has to be documented and has to be updated in accordance to the changes in the network.
• The firewall rules will be reviewed on a six month basis to ensure validity and the firewall must have a clean-up rule at the bottom of the rule base.
• No direct connections from Internet to data environment will be permitted. All traffic has to traverse through a firewall.

 

13.   System and Password Policy

All users, including contractors and vendors with access to Garden City Community College systems, are responsible for taking the appropriate steps, as outlined below, to select and secure their passwords.

• A system configuration standard must be developed along industry acceptable hardening standards (SANS, NIST, ISO)
• System configurations should be updated as new issues are identified (as defined in PCI DSS requirement 6.1)
• System configurations must include common security parameter settings
• The systems configuration standard should be applied to any new systems configured.
• All vendor default accounts and passwords for the systems have to be changed at the time of provisioning the system/device into Garden City Community College network and all unnecessary services and user/system accounts have to be disabled.
• All unnecessary default accounts must be removed or disabled before installing a system on the network.
• Security parameter settings must me set appropriately on system components
• All unnecessary functionality (scripts, drivers, features, subsystems, file systems, web servers etc.,) must be removed.
• All unnecessary services, protocols, daemons etc., should be disabled if not in use by the system.
• Any insecure protocols, daemons, services in use must be documented and justified.
• System services and parameters will be configured to prevent the use of insecure technologies like telnet and other insecure remote login commands
• Administrator access to web based management interfaces is encrypted using strong cryptography.
• All users with access to data must have a unique ID.
• All users must use a password to access the Garden City Community College network or any other electronic resources
• All user ID’s for terminated users must be deactivated or removed immediately.
• The User ID will be locked out if there are more than 5 unsuccessful login attempts. This locked account can only be enabled by the system administrator. Locked out user accounts will be disabled for a minimum period of 15 minutes or until the administrator enables the account.
• All system and user level passwords must be changed on at least a quarterly basis
• Users will be prohibited from re-using the last 10 previously used passwords.
• A unique password must be setup for new users and the users prompted to change the password on first login.
• Group, shared or generic user account or password or other authentication methods must not be used to administer any system components.
• Where SNMP is used, the community strings must be defined as something other than the Standard defaults of "public," "private" and "system" and must be different from the passwords used to log in interactively.
• All non-console administrative access will use appropriate technologies like ssh,vpn,ssl etc or strong encryption is invoked before the administrator password is requested
• The responsibility of selecting a password that is hard to guess generally falls to users. A strong password must:
  • Be as long as possible with at least 8 characters.
  • Include mixed-case letters.
  • Include digits and punctuation marks, if possible.
  • Not be based on any personal information.
  • Not be based on any dictionary word, in any language.
• To protect against network analysis attacks, both the workstation and server should be cryptographically secured. Examples of strong protocols are the encrypted Netware login and Kerberos.

14.   Anti-virus policy

• All machines must be configured to run the latest anti-virus software as approved by Garden City Community College. The preferred application to use is FortiClient Anti-Virus software, which must be configured to retrieve the latest updates to the antiviral program automatically on a daily basis. The anti-virus should have periodic scanning enabled for all the systems.
• The anti-virus software in use should be cable of detecting all known types of malicious software (Viruses, Trojans, adware, spyware, worms, cryptoware and rootkits).
• All removable media (for example USB drives and others) should be scanned for viruses before being used.
• All the logs generated from the anti-virus solutions have to be retained as per legal/regulatory/contractual requirements or at a minimum of PCI DSS requirement 10.7 of 3 months online and 1 year offline.
• Master Installations of the anti-virus software should be setup for automatic updates and periodic scans.
• End users must not be able to modify any settings or alter the anti-virus software
• E-mails with attachments coming from suspicious or unknown sources should not be opened. All such emails and their attachments should be deleted from the mail system as well as from the trash bin. No one should forward any e-mail, which they suspect may contain virus.

 

 

15.   Patch Management Policy

• All Workstations, servers, software, system components etc. owned by Garden City Community College must have up-to-date system security patches installed to protect the asset from known vulnerabilities.
• Where ever possible, all systems and software must have automatic updates from their respective vendors enabled for system patches. Security patches have to be installed within one month of release from the respective vendor and must follow the change control process.
• Any exceptions to this process must be documented.
  
  

16.   Remote Access policy

• It is the responsibility of Garden City Community College employees, contractors, vendors and agents with remote access privileges to the Company’s corporate network to ensure that their remote access connection is given the same consideration as the user's on-site connection to Garden City Community College.
• Secure remote access must be strictly controlled. Control will be enforced by two factor authentication via one-time password authentication or public/private keys with strong passphrases.
• Vendor accounts with access to Garden City Community College network will only be enabled during the time period the access is required and will be disabled or removed once access is no longer required.
• Remote access connection will be configured to be disconnected automatically after 30 minutes of inactivity.
• All hosts that are connected to Garden City Community College internal networks via remote access technologies will be monitored on a regular basis.
• All remote access accounts used by vendors or 3rd parties will be reconciled at regular intervals and the accounts will be revoked if there is no further business justification.

 

 

17.   Vulnerability Management Policy

• All the vulnerabilities will be assigned a risk ranking such as High, Medium and Low based on industry best practices, such as CVSS base score.
• As part of the PCI-DSS Compliance requirements, Garden City Community College will run internal and external network vulnerability scans quarterly and after any significant change in the network (such as new system component installations, changes in network topology, firewall rule modifications, product upgrades, etc.).
• Quarterly internal vulnerability scans will be performed by internal staff at Garden City Community College or by a 3rd party vendor. Rescans will be done until passing results of the vulnerability scans are obtained or all High vulnerabilities, as defined in PCI DSS Requirement 6.2, are resolved.
• Quarterly external vulnerability scans must be performed by an Approved Scanning Vendor (ASV) qualified by PCI SSC. Scans conducted after network changes may be performed by Garden City Community College’s internal staff. Rescans will be done until passing results of the vulnerability scans are obtained or all High vulnerabilities, as defined in PCI DSS Requirement 6.2, are resolved.

 

18.   Configuration

• Information systems that process, transmit or store data must be configured in accordance with the applicable standard for that class of device or system. Standards must be written and maintained by the team responsible for the management of the system in conjunction with the IT department.
• All network device configurations must adhere to Garden City Community College required standards before being placed on the network.
• Before being deployed into production, a system must be certified to meet the applicable configuration standard
• Updates to network device operating system and/or configuration settings that fall under Garden City Community College standards are announced by the IT department. Updates must be applied within the time frame identified by the IT department.
• Administrators of network devices that do not adhere to Garden City Community College standards (as identified via a previous exception) must document and follow a review process of announced vendor updates to operating system and/or configuration settings. This process must include a review schedule, risk analysis method and update method.
• All network device configurations must be checked annually to ensure the configuration continues to meet required standards.
• Where possible, network configuration management software will be used to automate the process of confirming adherence to the configuration.
• For other devices an audit will be performed quarterly to compare the configuration to the configuration currently in place.
• All discrepancies will be evaluated and re-mediated by Network Administration.

 

19.   Change Control Process

• Changes to information resources shall be managed and executed according to a formal change control process. The control process will ensure that changes proposed are reviewed, authorized, tested, implemented, and released in a controlled manner; and that the status of each proposed change is monitored.
• The change control process shall be formally defined and documented. A change control process shall be in place to control changes to all critical company information resources (such as hardware, software, system documentation and operating procedures). This documented process shall include management responsibilities and procedures.  Wherever practicable, operational and application change control procedures should be integrated.
• All change requests shall be logged whether approved or rejected on a standardized and central system. The approval of all change requests and the results thereof shall be documented. A documented audit trail, maintained at a Business Unit Level, containing relevant information shall be maintained at all times. This should include change request documentation, change authorization and the outcome of the change. No single person should be able to effect changes to production information systems without the approval of other authorized personnel.
• A risk assessment shall be performed for all changes and dependent on the outcome, an impact assessment should be performed.
• The impact assessment shall include the potential effect on other information resources and potential cost implications. The impact assessment should, where applicable consider compliance with legislative requirements and standards.
• All change requests shall be prioritized in terms of benefits, urgency, effort required and potential impact on operations.
• Changes shall be tested in an isolated, controlled, and representative environment (where such an environment is feasible) prior to implementation to minimize the effect on the relevant business process, to assess its impact on operations and security and to verify that only intended and approved changes were made.
• Any software change and/or update shall be controlled with version control. Older versions shall be retained in accordance with corporate retention and storage management policies.
• All changes shall be approved prior to implementation. Approval of changes shall be based on formal acceptance criteria i.e. the change request was done by an authorized user, the impact assessment was performed and proposed changes were tested.
• All users, significantly affected by a change, shall be notified of the change. The user representative shall sign-off on the change. Users shall be required to make submissions and comment prior to the acceptance of the change.
• Implementation will only be undertaken after appropriate testing and approval by stakeholders. All major changes shall be treated as new system implementation and shall be established as a project. Major changes will be classified according to effort required to develop and implement said changes.
• Procedures for aborting and recovering from unsuccessful changes shall be documented. Should the outcome of a change be different to the expected result (as identified in the testing of the change), procedures and responsibilities shall be noted for the recovery and continuity of the affected areas. Fall back procedures will be in place to ensure systems can revert back to what they were prior to implementation of changes.
• Information resources documentation shall be updated on the completion of each change and old documentation shall be archived or disposed of as per the documentation and data retention policies.
• Specific procedures to ensure the proper control, authorization, and documentation of emergency changes shall be in place. Specific parameters will be defined as a standard for classifying changes as Emergency changes.
• All changes will be monitored once they have been rolled-out to the production environment. Deviations from design specifications and test results will be documented and escalated to the solution owner for ratification.
  
  

20.   Audit and Log review

• This procedure covers all logs generated for systems within the data environment, based on the flow of data over Garden City Community College network, including the following components:
  • Operating System Logs (Event Logs and SU logs).
  • Database Audit Logs.
  • Firewalls & Network Switch Logs.
  • IDS Logs.
  • Anti-virus Logs.
  • CCTV Video recordings.
  • File integrity monitoring system logs.
• Audit Logs must be maintained for a minimum of 3 months online (available for immediate analysis) and 12 months offline.
• Review of logs is to be carried out by means of the Company’s network monitoring system Netwrix, which is controlled from Garden City Community College console. The console is installed on the server Orion, located within Garden City Community College data center environment.
• The following personnel are the only people permitted to access log files, IT staff or other personnel as authorized by college administration.
• The network monitoring system software Netwrix is configured to alert Garden City Community College, IT staff to any conditions deemed to be potentially suspicious, for further investigation. Alerts are configured to: administrator@gcccks.edu
• A dashboard browser-based interface, monitored by Garden City Community College IT staff.
• Email/SMS alerts to Garden City Community College administrator@gcccks.edu mailbox with a summary of the incident. Garden City Community College IT@gcccks.edu also receives details of email alerts for informational purposes.
• The following Operating System Events are configured for logging, and are monitored by the console Netwrix:
  • Any additions, modifications or deletions of user accounts.
  • Any failed or unauthorized attempt at user login.
  • Any modification to system files.
  • Any access to the server, or application running on the server, including files that hold data.
  • Actions taken by any individual with root or administrative privileges.
  • Any user access to audit trails.
  • Any creation / deletion of system-level objects installed by Windows. (Almost all system-level objects run with administrator privileges, and some can be abused to gain administrator access to a system.)
• The following Database System Events are configured for logging, and are monitored by the network monitoring system Netwrix:
• Any failed user access attempts to log in to the MSSQL databases.
• Any login that has been added or removed as a database user to a database.
• Any login that has been added or removed from a role.
• Any database role that has been added or removed from a database.
• Any password that has been changed for an application role.
• Any database that has been created, altered, or dropped.
• Any database object, such as a schema, that has been connected to.
• Actions taken by any individual with DBA privileges.
• The following Firewall Events are configured for logging, and are monitored by the network monitoring system Fortinet EMS:
  • ACL violations.
  • Invalid user authentication attempts.
  • Login and actions taken by any individual using privileged accounts.
  • Configuration changes made to the firewall (e.g. policies disabled, added, deleted, or modified).
• The following Switch Events are to be configured for logging and monitored by the network monitoring system Extreme NMS:
  • Invalid user authentication attempts.
  • Login and actions taken by any individual using privileged accounts.
  • Configuration changes made to the switch (e.g. configuration disabled, added, deleted, or modified).
• The following Intrusion Detection Events are to be configured for logging, and are monitored by the network monitoring system Fortinet EMS:
  • Any vulnerability listed in the Common Vulnerability Entry (CVE) database.
  • Any generic attack(s) not listed in CVE.
  • Any known denial of service attack(s).
  • Any traffic patterns that indicated pre-attack reconnaissance occurred.
  • Any attempts to exploit security-related configuration errors.
  • Any authentication failure(s) that might indicate an attack.
  • Any traffic to or from a back-door program.
  • Any traffic typical of known stealth attacks.
• The following File Integrity Events are to be configured for logging and monitored by Netwrix:
  • Any modification to system files.
  • Actions taken by any individual with Administrative privileges.
  • Any user access to audit trails.
  • Any Creation / Deletion of system-level objects installed by Windows. (Almost all system-level objects run with administrator privileges, and some can be abused to gain administrator access to a system.)
• For any suspicious event confirmed, the following must be recorded and Garden City Community College VP informed:
  • User Identification.
  • Event Type.
  • Date & Time.
  • Success or Failure indication.
  • Event Origination (e.g. IP address).
  • Reference to the data, system component or resource affected.
    
    

21.   Secure Application development

• This policy aims to be language and platform independent so that it is applicable across all software development projects.
• The adherence to and use of Secure Application Development Coding Policy is a requirement for all software development on Garden City Community College information technology systems and trusted contractor sites processing Garden City Community College data.
• Each phase of the SDLC is mapped with security activities, as explained below:
  • Design
    • Identify Design Requirements from security perspective
    • Architecture & Design Reviews
    • Threat Modeling
  • Coding
    • Coding Best Practices
    • Perform Static Analysis
  • Testing
    • Vulnerability Assessment
    • Fuzzing
  • Deployment
    • Server Configuration Review
    • Network Configuration Review
      
      
  • Development of code shall be checked and validated with the most current versions of the Company Coding Standards for Secure Application Development. All code developers shall verify that their code is in compliance with the most recent and approved coding standards and guidelines.
  • Only validated code shall be implemented into Garden City Community College production environment. A review and validation ensures that code exhibits fundamental security properties to include correctness, predictability, and attack tolerance.

Application Code Developers shall:

• Ensure code meets the level of confidence that software is free from exploitable code vulnerabilities, regardless of whether they are already designed into the software or inserted later in its life cycle.
• Ensure code provides predictable execution or justifiable confidence and that the software, when executed, will provide security functionality as intended.
• Coding techniques must address injection flaws particularly SQL injection, buffer overflow vulnerabilities, cross site scripting vulnerabilities, improper access control (insecure direct object reference, failure to restrict URL access, directory traversal etc.,), cross site request forgery (CSRF), broken authentication and session management.
• Never trust incoming data to the system, apply checks to this data.
• Never rely on the client to store sensitive data no matter how trivial.
• Disable Error messages that return any information to the user.
• Use object inheritance, encapsulation, and polymorphism wherever possible.
• Use environment variables prudently and always check boundaries and buffers.
• Applications must validate input to ensure it is well-formed and meaningful.
  
  

22.   Penetration testing methodology

• In this section should be listed the risks inherent in conducting penetration testing over the information systems of Garden City Community College. Additionally, it should be noted for each mitigation measures that will be taken. Examples might be:

Example 1#

Risk: Denial of Service in systems or network devices because of the network scans.

Mitigation measure 1: network scans must be performed in a controlled manner. The start and end of the scan must be notified to responsible personnel to allow monitoring during testing. For any sign of trouble will abort the scan in progress.

Mitigation measure 2: scanning tools must be configured to guarantee that the volume of sent packets or sessions established per minute does not cause a problem for network elements. In this sense, we must perform the first scans in a very controlled way and a use minimum configuration that may be expanded when is evident that the configuration is not dangerous for network devices or servers in the organization.

• Key staff involved in the project by the organization will be listed:

Director of IT: Andrew Knoll

Responsible for web site:www.gcccks.edu

• External intrusion tests will be performed remotely from the supplier's premises. Internal intrusion tests will be conducted in the Garden City Community College IT department. Audit team must to have access to the Organization's network. It must manage access permissions to the building early enough to ensure that the audit team can access without problems during planning period.
• All the tests will be conducted from the equipment owned by the audit team so no equipment for the execution of the tests is required. The only requirement in this regard will be to have an active network connection for each member of the audit team. Those connections must provide access to the target network segment in every case.
• If an incident occurs during the execution of the tests that have an impact on the systems or services of the organization, the incident should be brought immediately to the attention of those responsible for incident management in the project
• It should be noted that in order to comply with PCI DSS the scope of the test should include, at least the following:
  • All systems and applications that are part of the perimeter of the cardholder data environment card (CDE).

Example:

• Systems included in the scope
  System 1: IP: System: System Description
  System 2: IP: System: System Description
  Wifi network Garden City Community College
• Applications included in the scope
  Application 1: URL: Description of the application
• Systems excluded from the scope
  System 5: IP: System: System Description
  System 6: IP: System: System Description
• Applications excluded from the scope
  Application 3: URL: Description of the application

 

• Technical tests must follow the OSSTMM methodology. Tests must be conducted at network, system and application level and must ensure that at least identifies any vulnerabilities documented by OWASP and SANS, as well as those identified in the PCI DSS standard v3:
  1. Injections: Code, SQL, OS commands, LDAP, XPath, etc.
  2. Buffer overflows.
  3. Insecure storage of cryptographic keys
  4. Insecure Communications
  5. Improper error handling
  6. Cross -site scripting (XSS)
  7. Control of inappropriate access.
  8. Cross - site request forgery (CSRF).
  9. Broken authentication and incorrectly session management.
  10. Any other vulnerability considered High Risk by the organization.
• For all findings or vulnerabilities identified during the tests carried out will be generated and documented sufficient evidence to prove the existence of the same. The format of the evidence can be variable in each case, screen capture, raw output of security tools, photographs, paper documents, etc.
• As a result of tests performed should generate a document containing at least the following sections:
  • Introduction
  • Executive Summary
  • Methodology
  • Identified vulnerabilities
  • Recommendations for correcting vulnerabilities
  • Conclusions
  • Evidence

 

23.   Incident Response Plan

'Security incident' means any incident (accidental, intentional or deliberate) relating to your communications or any information breach. The attacker could be a malicious stranger, a competitor, or a disgruntled employee, and their intention might be to steal information or money, or just to damage your business.

The Incident response plan has to be tested once annually. Copies of this incident response plan is to be made available to all relevant staff members, and take steps to ensure that they understand it and what is expected of them.

Employees of Garden City Community College will be expected to report to the security officer for any security related issues.

Garden City Community College PCI security incident response plan is as follows:

1. Each department must report an incident to the Information Security Officer (preferably) or to another member of the IT Staff.
2. That member of the team receiving the report will advise the Vice President of the incident.
3. The IT Staff will investigate the incident and assist the potentially compromised department in limiting the exposure of data and in mitigating the risks associated with the incident.
4. The IT Staff will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
5. The IT Staff will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.
6. If an unauthorized wireless access point or devices is identified or detected as part of the quarterly test this is should be immediately escalated to the Security officer or someone with similar privileges who has the authority to stop, cease, shut down, and remove the offending device immediately.
7. A department that reasonably believes it may have a data breach or of systems related to the PCI environment in general, must inform Garden City Community College IT Staff. After being notified of a compromise, the IT Staff, along with other designated staff, will implement the Incident Response Plan to assist and augment departments’ response plans.

Garden City Community College Incident Response Team:

(Update as applicable)

Vice President of Administrative Services/CFO: CFO@gcccks.edu

Information Security Officer: IT@gcccks.edu

Collections & Merchant Services: Business@gcccks.edu

Incident Response Notification
Escalation Members:  IT Director, Network Administrator, IT@gcccks.edu
Escalation – First Level: Computer Technician, IT@gcccks.edu
Information Security Officer: IT Director, IT@gcccks.edu
Director of Financial Aid: finaid@gcccks.edu
Controller: business@gcccks.edu
Director of Marketing and Public Relations: marketing@gcccks.edu

Escalation – Second Level
Garden City Community College President Executive Cabinet
Internal Auditing Group
Auxiliary members (as needed)
External Contacts (as needed)
Merchant Provider Card
Brands
Internet Service Provider (if applicable)
Internet Service Provider of Intruder (if applicable)
Communication Carriers (local and long distance) Business Partners
Insurance Carrier
External Response Team as applicable (CERT Coordination Center 1, etc)
Law Enforcement Agencies as applicable inn local jurisdiction

In response to a systems compromise, the Incident Response Team will:
Ensure compromised system/s is isolated on/from the network.

• Gather, review and analyze the logs and related information from various central and local safeguards and security controls.
• Conduct appropriate forensic analysis of compromised system.
• Contact internal and external departments and entities as appropriate.
• Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
• Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.
• The card companies have individually specific requirements the Response Team must address in reporting suspected or confirmed breaches of card holder data.

 

Incident Response notifications to various card schemes: 

• In the event of a suspected security breach, alert the information security officer or your director immediately.
• The security officer will carry out an initial investigation of the suspected security breach.
• Upon confirmation that a security breach has occurred, the security officer will alert IT and begin informing all relevant parties that may be affected by the compromise.
  
  

VISA Steps

If the data security compromise involves credit card account numbers, implement the following procedure: 

1. Shut down any systems or processes involved in the breach to limit the extent, and prevent further exposure.
2. Alert all affected parties and authorities such as Commerce Bank, Visa Fraud Control, and the law enforcement.
3. Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.
4. For more Information visit:http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html
   
   

Visa Incident Report Template

This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident reporting must be securely distributed to VISA and Commerce Bank. Visa will classify the report as “VISA Secret”*. • Executive Summary

• Include overview of the incident
• Include RISK Level(High, Medium, Low)
• Determine if compromise has been contained II.
• Background
  • Initial Analysis
  • Investigative Procedures
  • Include forensic tools used during investigation.
• Findings
  • Number of accounts at risk, identify those stores and compromised
  • Type of account information at risk
  • Identify ALL systems analyzed. Include the following:
    • Domain Name System (DNS) names
    • Internet Protocol (IP) addresses
    • Operating System (OS) version
    • Function of system(s)
  • Identify ALL compromised systems. Include the following:
    • DNS names
    • IP addresses
    • OS version
    • Function of System(s)
  • Timeframe of compromise
  • Any data exported by intruder
  • Establish how and source of compromise
  • Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)
  • If applicable, review VisaNet endpoint security and determine risk
    • Compromised Entity Action
    • Recommendations
    • Contact(s) at entity and security assessor performing investigation
  • This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.

MasterCard Steps

1. Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
2. Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to compromised_account_team@mastercard.com.
3. Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
4. Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as a detailed forensics evaluation).
5. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
6. Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
7. Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard.

Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:

• Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.
• Distribute the account number data to its respective issuers.
  
  

Employees of Garden City Community College will be expected to report to the security officer for any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within Garden City Community College and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implementation of the incident response plan in the event of a sensitive data compromise. 

Discover Card Steps

1. Within 24 hours of an account compromise event, notify Discover Fraud Prevention
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances.
3. Prepare a list of all known compromised account numbers.
4. Obtain additional specific requirements from Discover Card
   
   

American Express Steps

1. Within 24 hours of an account compromise event, notify American Express Merchant Services
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
3. Prepare a list of all known compromised account numbers
4. Obtain additional specific requirements from American Express
   
   

24.   Roles and Responsibilities

The Vice President of Administrative Services/CFO (or equivalent) is responsible for overseeing all aspects of information security, including but not limited to:

• Creating and distributing security policies and procedures.
• Monitoring and analyzing security alerts and distributing information to appropriate information security and business unit management personnel.
• Creating and distributing security incident response and escalation procedures that include:
• Maintaining a formal security awareness program for all employees that provide multiple methods of communicating awareness and educating employees (for example, posters, letters, meetings).
• The Information Technology Office (or equivalent) shall maintain daily administrative and technical operational security procedures that are consistent with the PCI-DSS/GLBA/FERPA (for example, user account maintenance procedures, and log review procedures).
• System and Application Administrators shall:
• Monitor and analyze security alerts and information and distribute to appropriate personnel  Administer user accounts and manage authentication  Monitor and control all access to data.
• Maintaining a list of service providers.
• Ensuring there is a process for engaging service providers including proper due diligence prior to engagement.
• Maintaining a program to verify service providers’ PCI-DSS/GLBA/FERPA compliant status, with supporting documentation.

 

The Human Resources Office (or equivalent) is responsible for tracking employee participation in the security awareness program, including:

• Facilitating participation upon hire and at least annually.
• Ensuring that employees acknowledge in writing at least annually that they have read and understand the Company’s information security policy.

 

General Counsel (or equivalent) will ensure that for service providers with whom sensitive information is shared have:

• Written contracts that require adherence to PCI-DSS/GLBA/FERPA by the service provider.
• Written contracts that include acknowledgment or responsibility for the security of sensitive data by the service provider.

25.   Third party access to sensitive data

• All third-party companies providing critical services to Garden City Community College must provide an agreed Service Level Agreement.
• All third-party companies providing hosting facilities must comply with the Company’s Physical Security and Access Control Policy.
• All third-party companies which have access to sensitive information must:
  • Adhere to the PCI-DSS/GLBA/FERPA security requirements.
  • Acknowledge their responsibility for securing the sensitive data.
  • Acknowledge that the data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
  • Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
  • Provide full cooperation and access to conduct a thorough security review after a security intrusion to a Payment Card industry representative, or a Payment Card industry approved third party.

26.   User Access Management

• Access to Garden City Community College controlled through a formal user registration process beginning with a formal notification from HR or IT.
• Each user is identified by a unique user ID so that users can be linked to and made responsible for their actions. The use of group IDs is only permitted where they are suitable for the work carried out.
• There is a standard level of access; other services can be accessed when specifically authorized by HR/line management.
• The job function of the user decides the level of access the employee has to sensitive data
• A request for service must be made in writing (email or hard copy) by the newcomer’s Director or by HR. The request is free format, but must state:

Name of person making request:

Job title of the newcomers and workgroup:

Start date:

Services required (default services are: MS Outlook, MS Office and Internet access)

• Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access.
• Access to all company systems is provided by IT and can only be started after proper procedures are completed.
• As soon as an individual leaves Garden City Community College employment, all his/her system logons must be immediately revoked.
• As part of the employee termination process HR (or line managers in the case of contractors) will inform IT operations of all leavers and their date of leaving.

27.   Access Control Policy

• Access Control systems are in place to protect the interests of all users of Garden City Community College computer systems by providing a safe, secure and readily accessible environment in which to work.
• Garden City Community College will provide all employees and other users with the information they need to carry out their responsibilities in as effective and efficient manner as possible.
• Generic or group IDs shall not normally be permitted, but may be granted under exceptional circumstances if sufficient other controls on access are in place.
• The allocation of privilege rights (e.g. local administrator, domain administrator, super-user, root access) shall be restricted and controlled, and authorization provided jointly by the system owner and IT Services. Technical teams shall guard against issuing privilege rights to entire teams to prevent loss of confidentiality.
• Access rights will be accorded following the principles of least privilege and need to know.
• Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
• Users electing to place information on digital media or storage devices or maintaining a separate database must only do so where such an action is in accord with the data’s classification.
• Users are obligated to report instances of non-compliance to the Garden City Community College CISO
• Access to Garden City Community College IT resources and services will be given through the provision of a unique Active Directory account and complex password.
• No access to any Garden City Community College IT resources and services will be provided without prior authentication and authorization of a user’s Garden City Community College Windows Active Directory account.
• Password issuing, strength requirements, changing and control will be managed through formal processes. Password length, complexity and expiration times will be controlled through Windows Active Directory Group Policy Objects.
• Access to Confidential, Restricted and Protected information will be limited to authorized persons whose job responsibilities require it, as determined by the data owner or their designated representative.
• Requests for access permission to be granted, changed or revoked must be made in writing.
• Users are expected to become familiar with and abide by Garden City Community College policies, standards and guidelines for appropriate and acceptable usage of the networks and systems.
• Access for remote users shall be subject to authorization by IT Services and be provided in accordance with the Remote Access Policy and the Information Security Policy. No uncontrolled external access shall be permitted to any network device or networked system.
• Access to data is variously and appropriately controlled according to the data classification levels described in the Information Security Management Policy.
• Access control methods include logon access rights, Windows share and NTFS permissions, user account privileges, server and workstation access rights, firewall permissions, IIS intranet/extranet authentication rights, SQL database rights, isolated networks and other methods as necessary.
• A formal process shall be conducted at regular intervals by system owners and data owners in conjunction with IT Services to review users’ access rights. The review shall be logged and IT Services shall sign off the review to give authority for users’ continued access rights.

 

28.   Wireless Policy

• Installation or use of any wireless device or wireless network intended to be used to connect to any of the Garden City Community College networks or environments is prohibited.
• A quarterly test should be run to discover any wireless access points connected to Garden City Community College network
• Usage of appropriate testing using tools like net stumbler, kismet etc. must be performed on a quarterly basis to ensure that:
• Any devices which support wireless communication remain disabled or decommissioned.
• If any violation of the Wireless Policy is discovered as a result of the normal audit processes, the security officer or any one with similar job description has the authorization to stop, cease, shut down, and remove the offending device immediately.

 

If the need arises to use wireless technology it should be approved by Garden City Community College and the following wireless standards have to be adhered to:

• Default SNMP community strings and passwords, pass-phrases, Encryption keys/security related vendor defaults (if applicable) should be changed immediately after the installation of the device and if anyone with knowledge of these leaves Garden City Community College.
• The firmware on the wireless devices has to be updated accordingly as per vendors release schedule
• The firmware on the wireless devices must support strong encryption for authentication and transmission over wireless networks.
• Any other security related wireless vendor defaults should be changed if applicable.
• Wireless networks must implement industry best practices (IEEE 802.11i) and strong encryption for authentication and transmission of card holder data.
• An Inventory of authorized access points along with a business justification must be maintained. (Update Appendix B)

29.   Identity Theft Policy “Red Flag Rule”

• The Board of Trustees requires college staff to establish policies and procedures to combat identify theft. Procedures are developed and implemented to detect, prevent, and mitigate identify theft in connection with new and existing accounts.
• The Federal Trade Commission (FTC), the federal bank regulatory agencies, and the National Credit Union Administration jointly issued regulations pursuant to the Fair and Accurate Credit Transactions Act (“FACT”) known as the “Red Flag Rules.” Garden City Community College recognizes that some of its activities are subject to the provisions of the FACT Act and its Red Flag Rules.
• Additional information can be found at: http://www.ftc.gov/redflagsrule
• GCCC adopts these procedures to identify relevant Red Flags for new and existing covered accounts and incorporate said Red Flags into the program; detect Red Flags that have been incorporated into the program; respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft; and ensure the program is updated periodically to reflect changes in risks to students, employees or contractors or to the safety and soundness of the individual from identity theft.
• Approval and Management; Program Administration; Training; Annual Report
• The Vice President of Administrative Services/Chief Financial Officer (hereinafter, the Program Administrator) is responsible for overall program management and administration. The Program Administrator shall provide appropriate identity theft training for selected college employees and provide reports and periodic updates to college administration on an annual basis.
• The annual report shall identify and evaluate issues such as the effectiveness of the college’s procedures for addressing the risk of identity theft with respect to Covered Accounts, oversight of service providers, significant incidents involving identity theft and the college’s response, and any recommendations for material changes to this Program.
  
  

 

 

Definitions

• A “Creditor” is any entity that regularly extends, renews, or continues credit or regularly arranges for the extension, renewal or continuation of credit.
• A “Covered Account” is a consumer account designed to permit multiple payments or transactions and any other account for which there is a reasonably foreseeable risk from identity theft.
• A “Customer” is a person with a Covered Account at the college.
• “Identity Theft” means fraud committed or attempted using the identifying information of another person.
• “Red Flag” means a pattern, practice or specific activity that indicates the possible existence of identity theft.
• “Identifying Information” is “any name or number that may be used, alone or in conjunction with any other information, to identify a specific person,” including, but not limited to: name, address, telephone number, social security number, date of birth, government issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer’s Internet Protocol address or routing code.

Applicability

This program applies to all staff, faculty, students and all personnel affiliated with third parties providing services to the college relating to Covered Accounts and/or Sensitive Information within the custody of control of the college.

Sensitive Information to be protected:

• Personal Information upon enrollment, hire or contract
  • Social Security Number
  • Date of Birth
  • Address
  • Phone Numbers
  • Maiden Name
• Payroll Information
  • Paychecks
  • Paystubs
  • Any document or electronic file containing payroll information
• Medical Information for employee or student
  • Doctor names and claims
  • Insurance claims
  • Any personal medical information
• Credit Card Information
  • Credit card number (in part or whole)
  • Credit card expiration date
  • Card holder name
  • Card holder address
    
    

Risk Assessment

• GCCC will consider the following risk factors in identifying Red Flags for Covered Accounts, if appropriate:
  • The types of Covered Accounts offered or maintained;
  • The methods provided to open Covered Accounts;
  • The methods provided to access Covered Accounts; and
  • Past experience with identity theft.
• GCCC, on a periodic basis, will incorporate relevant Red Flags from sources such as:
  • Incidents of identity theft that have been experienced or that have been experienced by other colleges and universities;
  • Methods of identity theft known by us or other Creditors that reflect changes in identity theft risks; and,
  • Applicable supervisory guidance.
• GCCC identifies the following Red Flags in each of the following categories:
  • Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detection services;
  • The presentation of suspicious documents;
  • The presentation of suspicious personal identifying information, such as a suspicious address change;
  • The unusual use of, or other suspicious activity related to a Covered Account; and,
  • Notices from customers, law enforcement authorities, or other persons regarding possible identity theft in connection with Covered Accounts.
• The following instances are examples of Red Flags recognized by the college:
  • Notifications or warnings from a consumer reporting agency
  • A fraud or active duty alert is included with a consumer report;
  • A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report;
  • A consumer reporting agency provides a notice of address discrepancy that informs the user of a substantial difference between the address for the consumer that the user provided to request the consumer report and the address(es) in the agency’s file for the consumer;
  • A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as:
    • A recent and significant increase in the volume of inquiries;
    • An unusual number of recently established credit relations;
    • A material change in the use of credit, especially with respect to recently established credit relationships; or
    • An account that was closed for cause or identified for abuse of account privileges by a financial institution or Creditor.
      
      

Suspicious Documents

• Documents provided for identification appear to have been altered for forged;
• The photo or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification;
• Other information on the identification is not consistent with information provided by the person opening a new Covered Account or customer presenting the identification;
• Other information of the identification is not consistent with readily accessible information that is on file with the college.

 

Suspicious Personal Identifying Information

• Personal Identifying information provided is inconsistent when compared against external information sources. For example:
  • The address does not match any address in the consumer report; or,
  • The Social Security Number (SSN) has not been issued, or is listed on the Social Security Administration’s Death Master File.
• Personal identifying information is not consistent with other personal identifying information provided by the customer, such as a lack of correlation between the Social Security Number range and date of birth.
• Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources utilized by the college, such as:
  • The address on an application is the same address provided on a fraudulent application; or,
  • The telephone number on an application is the same as the phone number provided on a fraudulent application.
• Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal third-party sources used by the college, such as:
  • The address on an application is fictitious, a PO box, or a prison; or,
  • The telephone number is invalid, or is associated with a pager or answering device.
• The Social Security Number provided is the same as that submitted by other persons.
• The address or phone number provided is the same as that submitted by others.
• The person who has a covered account fails to provide all required identifying information.
• Personal identifying information provided is not consistent with personal identifying information that is on file at the college.
  
  

Unusual use of, or Suspicious Activity Related to the Covered Account

• A new Covered Account is used in a manner commonly associated with known patterns of fraud, such as the customer failing to make first payment of the payment plan and no subsequent payments.
• Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s account.
• The college is notified that the customer is not receiving paper account statements.
• The college is notified of unauthorized charges or transactions in connection with a customer’s Covered Account.
• The college is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that the college may have an open account for a person engaged in identity theft.

Protective Actions to be Taken

• File cabinets, desk drawers, storage cabinets and any other space containing documents with Sensitive Information will be locked or otherwise secured when not in use at the end of each workday or when unsupervised.
• Writing tablets, note pads, post-its, etc. in common shared work areas will be erased, removed, or shredded when not in use.
• Passwords for the college database will not be shared.
• Keys will not be given to persons other than to those for whom the key request is made.
• Sensitive Information to be discarded will be placed in a locked shred bin or immediately shredded using a mechanical cross cut shredding machine.
• A photo ID will be required any time a request is made in person to change information to a Covered Account.
• A photo ID will be required for picking up any check of any origin, such as payroll, loan, refund, etc., from the Business Office or the Payroll Office.
  
  

Detection of Red Flags GCCC shall address the detection of Red Flags in connection with the opening of Covered Accounts by:

• Obtaining identifying information about and verifying the identity of newly hired employees, newly enrolled students, etc. Identifying information may include name, date of birth, residential or business address, principal place of business for an entity, SSN, driver’s license or other identification;
• Verifying identity, such as by reviewing a driver’s license or other identification.
• Monitoring transactions through photo ID verification.
• Requiring transactions through photo ID verification.
• Rejecting any application for a service or transaction that appears to have been altered or forged.
• Verifying identity via a consumer reporting agency which will independently contact the newly hired employee, newly enrolled student as appropriate for admission to selected programs, etc. GCCC shall address the detection of Red Flags in connection with existing Covered Accounts by:
  • Verifying identity if an employee, student or contractor requests information (in person, via telephone, via facsimile, via email).
  • Verifying the validity of requests to change mailing addresses.
• Not sharing identity information with anyone, including the employee, student or contractor. Requiring them to give the information and verify with the information on the account. Verifying changes in banking or credit card information given for billing and payment purposes.
  
  

Response to Red Flags

GCCC shall respond quickly to prevent identity theft. In all cases Red Flags are to be reported to the Chief Financial Officer. Response to Red Flags may include, but not be limited to:

• Contacting owner of account in question by:
  • Electronic method (e.g. email, text message, etc.)
  • Written letter via the USPS
  • Phone number on record
• Terminating transaction
• Changing any passwords, security codes, or other security devices that permits access to a Covered Account
• Reopening a Covered Account with a new account number
• Not opening a new Covered Account
• Closing an existing Covered Account
• Notifying and cooperating with appropriate law enforcement
• Continuing to monitor an Account for evidence of Identity Theft.
• Determining that no response is warranted under the particular circumstances.
  
  

Oversight of Service Providers

The college will make reasonable efforts to ensure that the activity of a service provider engaged by the College to perform an activity in connection with Covered Accounts, is conducted with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft. The college shall request that a copy of the service providers Red Flag Policy be sent to the college for review and maintained on file.

Non-disclosure of Specific Practices

For the effectiveness of this Identity Theft Prevention Program, knowledge about specific Red Flag identification, detection, mitigation and prevention practices may need to be limited to those employees with a need to know them. Any documents that may have been produced or are produced in order to develop or implement this program that list or describe such specific practices and the information those documents contain are considered “confidential” and should not be share with other College employees or the public. The Program Administrator shall inform the Committee and those employees with a need to know the information of those documents or specific practices which should be maintained in a confidential manner.

Annual Updates

The administrators of the College shall annually review this policy and recommend revisions when necessary to address changes in risks to students, faculty and staff based upon factors such as:

• Experiences with identity theft.
• Changes in methods of identity theft.
• Changes in methods to detect and prevent identity theft.
• Changes in the types of accounts that the college offers or maintains.
• Changes in organizational structure.

Program Administration

Training shall be conducted by the Program Administrator, Vice President of Business Affairs/Chief Financial Officer, for faculty and staff on an annual basis.

Additional information can be found at: http://www.ftc.gov/redflagsrule

 

Appendix B

 

List of Service Providers

 

 

Policy History:

October 1, 2025: Revised for accessibility