New: In July 2012 an Information Security Policy was approved by Council and this will be implemented across the University. For further information about this IS Policy and resources such as the IS Toolkit to help you implement this in your unit please see the Information Security pages from the InfoSec project in the IT Services department. The University IS Policy supersedes the policy on the ISBP pages below.
This policy provides a framework for the management of information security throughout the University. It applies to:
2. Aims and Committments
Council has ultimate responsibility for information security within the University. More specifically, it is responsible for ensuring that the University complies with relevant external requirements, including legislation.
3.2. PRAC ICT sub-committee (PICT)
The PRAC ICT sub-committee (PICT), or any future equivalent body, is responsible to Council for:
3.3. Heads of department
Given the University’s devolved structure, heads of department are responsible for information security within their departments. They must ensure that the department has in place a local information security policy to meet its own particular needs, consistent with the requirements of this overarching policy. The local information security policy should identify the department’s own information security requirements and provide a management framework for meeting those requirements. ‘Department’ in this context includes equivalent local units, as well as divisional offices.
Specific roles and responsibilities for information security within departments should be clearly identified.
The head of department must approve the policy, and ensure that it is implemented and kept under regular review.
3.4. Users and External Parties
Users of University information will be made aware of their own individual responsibilities for complying with University and departmental policies on information security.
Agreements with third parties involving accessing, processing, communicating or managing the University’s information, or information systems, should cover all relevant security requirements, and be covered in contractual arrangements.
4. Risk Assessment and the Classification of Information
4.1. Risk assessment of information held
The degree of security control required depends on the sensitivity or criticality of the information. The first step in determining the appropriate level of security therefore is a process of risk assessment, in order to identify and classify the nature of the information held, the adverse consequences of security breaches and the likelihood of those consequences occurring.
Given the devolved nature of the University’s structure, the risk assessment should be carried out in the first instance by departments, as defined in paragraph 3.3 above. However, the departmental assessment must be consistent with the general principles in this section.
The risk assessment should identify the department’s information assets; define the ownership of those assets; and classify them, according to their sensitivity and/or criticality to the department or University as a whole. In assessing risk, departments should consider the value of the asset, the threats to that asset and its vulnerability. (An example of a risk assessment is at Annex A.) Further guidance on risk assessment and the classification of information is available in the Toolkit.
Where appropriate, information assets should be labelled and handled in accordance with their criticality and sensitivity.
Rules for the acceptable use of information assets should be identified, documented and implemented. The University’s Regulations and Policies applying to all users of University ICT facilities are available from http://www.ict.ox.ac.uk/oxford/rules/.
Information security risk assessments should be repeated periodically and carried out as required during the operational delivery and maintenance of the University’s infrastructure, systems and processes.
4.2. Personal Data
Personal data must be handled in accordance with the Data Protection Act 1998 (DPA) and in accordance with the University’s policy and guidance on personal data.
The DPA requires that appropriate technical and organisational measures are taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
A higher level of security should be provided for ‘sensitive personal data’, which is defined in the DPA as data relating to ethnic or racial origin, religious beliefs, physical or mental health, sexual life, political opinions, trade union membership, or the commission or alleged commission of criminal offences.
5. Protection of Information Systems and Assets
Having completed a risk assessment, departments should draw up their own information security policy, setting out appropriate controls and procedures, in accordance with the Toolkit. Information owners must be satisfied that the controls will reduce any residual risk to an acceptable level.
Confidential information should be handled in accordance with the requirements set out in section 6 below.
6. Protection of Confidential Information
Identifying confidential information is a matter for assessment in each individual case. Broadly, however, information will be confidential if it is of limited public availability; is confidential in its very nature; has been provided on the understanding that it is confidential; and/or its loss or unauthorised disclosure could have one or more of the following consequences:
Confidential information should be kept secure, by keeping it, where possible, on site using dedicated storage (e.g. file servers), rather than local hard disks, and with an appropriate level of physical security.
File or disk encryption should be considered as an additional layer of defence, where physical security is considered insufficient.
Confidential information must be stored in such a way as to ensure that only authorised persons can access it.
All users must be authenticated. Authentication should be appropriate, and where passwords are used, clearly defined policies should be in place and implemented. Users must follow good security practices in the selection and use of passwords.
Where necessary, additional forms of authentication should be considered.
To allow for potential investigations, access records should be kept for a minimum of six months, or for longer, where considered appropriate.
Users with access to confidential information should be security vetted, as appropriate, in accordance with existing policies.
Physical access should be monitored, and access records maintained.
6.3. Remote Access
Where remote access is required, this must be controlled via a well-defined access control policy and tight access controls provided to allow the minimum access necessary.
Any remote access must be controlled by secure access control protocols using appropriate levels of encryption and authentication.
The number of copies made of confidential information, whether on portable devices or media or in hard copy, should be the minimum required, and, where necessary, a record kept of their distribution. When no longer needed, the copy should be deleted or, in the case of hard copies, destroyed (see 6.12.5).
All copies should be physically secured e.g. stored in a locked cupboard drawer or filing cabinet.
Policies and procedures must be in place for the secure disposal/destruction of confidential information The University's policy on the disposal of old computers can be found at http://www.ict.ox.ac.uk/oxford/disposal/.
6.6. Use of Portable Devices or Media
Procedures should be in place for the management of removable media in order to ensure that they are appropriately protected from unauthorised access.
The permission of the information owner should be sought before confidential information is taken off site. The owner must be satisfied that the removal is necessary and that appropriate safeguards are in place e.g. encryption. For further information, please see the Toolkit.
In the case of personal data, the ICO recommends that all portable devices and media should be encrypted where the loss of the data could cause damage or distress to individuals.
The passphrase of an encrypted device must not be stored with the device (see also section 6.8.2).
6.7. Exchange of Information and Use of Email
Controls should be implemented to ensure that electronic messaging is suitably protected.
Email should be appropriately protected from unauthorised use and access.
Email should only be used to send confidential information where the recipient is trusted, the information owner has given their permission, and appropriate safeguards have been taken e.g. encryption.
Further guidance on managing the risks associated with the use of e-mail is available on the University website and in the Toolkit.
6.8. Cryptographic Controls
Procedures should be in place to support the use of cryptographic techniques and to ensure that only authorised personnel may gain access to confidential information.
University guidance, provided via the Toolkit, on cryptographic policy and key management, should be followed to ensure that data are appropriately secured and that all legal and regulatory requirements have been considered.
6.9. System Planning and Acceptance
A risk assessment should be carried out as part of the business case for any new ICT system that may be used to store confidential information. The risk assessment should be repeated periodically on any existing systems.
Information owners should ensure that appropriate backup and system recovery procedures are in place. Backup copies of all important information assets should be taken and tested regularly in accordance with such an appropriate backup policy.
6.11. Further information
The Toolkit provides further guidance on the matters covered in this section.
6.12. Hard Copies
6.12.1. Protective Marking
Documents containing confidential information should be marked as ‘Confidential’ or with another appropriate designation e.g. ‘sensitive’, etc, depending on the classification system adopted by the department.
Confidential information should not be removed from the University unless it can be returned on the same day or stored securely overnight, as described in section 6.12.2 above.
Confidential documents must be shredded in a confidential manner prior to disposal.
There must be a written policy in place at the local level for the handling of confidential information, whether electronic or hard copy, and a copy of the procedures must be provided to every user so that they are aware of their responsibilities.
Any failure to comply with the policy may result in disciplinary action.
Any loss or unauthorised disclosure must be promptly reported to the owner of the information.
Computer security incidents involving the loss or unauthorised disclosure of confidential information held in electronic form must be reported to Oxford University Computer Emergency Response Team (OxCERT) and investigated.
If the loss or unauthorised disclosure involves personal data, whether electronic or hard copy, the University’s Data Protection Officer must also be informed, either by e-mail or by phone ((2)70002).
The University has established this policy to promote information security and compliance with relevant legislation, including the DPA. The University regards any breach of information security requirements as a serious matter, which may result in disciplinary action.
Compliance with this policy should form part of any contract with a third party that may involve access to network or computer systems or data.
Relevant legislation includes, but is not limited to: