Information Access and Security Policy 1. Introduction 1.1 Information is an essential resource for teaching, research and administration within the University. The Information Access and Security Policy describes the University’s policy with regard to the creation, storage and dissemination of information. 1.2 The policy aims to help the University carry out its core activities effectively, to comply with legislation and good practice, to avoid breach of privacy or confidence and to safeguard its information assets against theft, fraud, malicious damage, and accidental damage or loss. The policy recognises that these aims may sometimes be in competition with each other, and that a balance needs to be struck between security requirements and an efficient flow and effective exploitation of information. 1.3 This policy should be read in the context of other University policies, including the policies on copyright and intellectual property, privacy and confidentiality, and the provision of IT services and connection to the network. 2. Scope of the policy 2.1 The policy applies to all University information. This term is understood to cover all information owned by, held by or processed by, or on behalf of, the University, regardless of its location (on or off the University’s premises) and whether it is stored on paper, electronically or on any other medium. 2.2 The policy covers all phases of the handling of information, from its creation or acquisition to processing, distribution, storage and ultimate disposal or destruction. 2.3 The policy applies to all those who have access to University information. These include staff and students of the University research partners and external contractors who have access to University information as part of their collaboration with the University visitors to the University who have access to University information 3. Principles 3.1 The Policy operates on the basis of the following principles: relevant, accurate, up-to-date and timely information should be readily and widely accessible where practicable storage and dissemination of information should take place under levels of security that are appropriate to the legal status of the information, its value to the University and the risks attached to it in the absence of any explicit statement to the contrary, any information created or acquired through University funds is assumed to be owned by the University 98879470 1 a responsible custodian should be designated for all information held by the University, whether or not it is owned by the University the University has regulations governing intellectual property 3.2 Are these principles, or anything like them, articulated in our Information Strategy documents? 3.2 Rights of access to information imply responsibilities. The University will provide a framework of policies and regulations, procedures and mechanisms to ensure that information is handled within the appropriate laws and codes of practice; individuals must operate within this framework and are accountable for their actions. 4. Access 4.1 The University will provide easy access to University information and appropriate external information in order to enable staff, students and others operating on its behalf to undertake their duties effectively. 4.2 The University will provide external bodies and individuals with access to University information where it is under a statutory or contractual obligation to do so. 4.3 The University will protect the rights of individuals in relation to access to personal or sensitive data held by the University, both under Data Protection and Human Rights legislation and in compliance with the University’s policy on privacy and confidentiality. 4.4 Physical and/or electronic access control systems will be provided to ensure that access to personal or sensitive information is available only to authorised individuals. The University will ensure that clear guidelines are provided on the deployment of personal or sensitive information and will provide training in their deployment. 5. Responsibilities 5.1 The loss, misuse or inappropriate exposure of information may have serious implications for the University both in legal sanctions and in damage to the University’s reputation. In some cases the individual processing the information has a personal legal liability in addition to the liability of the University. 5.2 Information should be handled within the laws and regulations in force. The University will provide general guidelines on the relevant laws and regulations, and will ensure that competent legal advice is available. 5.3 Whether or not legal sanctions apply in any given case the University expects all those handling University information to do so in a responsible manner. Each individual is responsible for his or her actions and should not take any action which they know to be outside the law or in breach of University policies, guidelines or codes of conduct. Where uncertainty exists as to the legal or other constraints upon the dissemination of information, individuals should exercise caution and seek competent advice. 5.4 There will be a designated custodian (normally the person who created or commissioned the information or a nominee) for each item of University 98879470 2 information. The custodian is responsible for ensuring its integrity and accuracy, for legal compliance, for determining access rights, and for carrying out risk assessments on the value and security of the information. 5.5 Policies, guidelines, and codes of practice must be adhered to. These may be issued by the University or by statuory or professional bodies with which the University has an association, such as the Joint Information Systems Committee (JISC), or the United Kingdom Education and Research Networking Association (UKERNA). 5.6 Anyone introducing visitors to the University, or involved in collaboration with external partners or entering into a contract on behalf of the University must ensure, in any cases where access to University might be granted, that the Policy is understood and complied with. 5.7 Heads of Schools and Units are responsible for the implementation and monitoring of the Policy within their School or Unit and for ensuring that their staff and students, and also any visitors and contractors, are aware of the Policy and associated guidelines. 5.8 The use of computer systems and networks is central to many aspects of information access and security. The Director of IT Services will ensure that adequate levels of computer and network security are in place, and that mechanisms are available for authorising appropriate access to University information, and will provide guidelines, advice and training on security. 6. Copyright and Intellectual Property 6.1 The University can be seriously damaged by any breach of the laws and agreements concerning copyright and intellectual property, whether by staff or students or any other person acting on behalf of or within the University. 6.2 All information in the UK is governed by the laws of copyright and regulations emanating from the European Union which bind all member states. Copyright laws vary in other countries, notably in the United States, and individuals must take appropriate steps to ensure compliance. 6.3 The University and the academic community of which the University is part, have entered into agreements with various 6.4 The University has a Copyright Adviser who will provide guidelines on the legal and other constraints on the handling of information. 7. Security 7.1 The University is committed to providing a secure environment in which information can be accessed and processed. Subject to disclosure under court order, data subjects have legal rights to confidentiality of information held about them by the University, and personal or sensitive information will be available only to those authorised. Also, the University has a duty to ensure the accuracy and currency of personal data that it holds. 7.2 Computer and network security 7.2.1 The University will take reasonable steps to ensure the integrity of its computer systems and data communications network. In particular, the University will implement access controls to the University’s network from 98879470 3 the Internet via a firewall and will control external access from the campus network. 7.2.2 The University will develop a policy together with associated mechanisms for accessing University information from home or from other off-campus locations. 7.2.3 Facilities and guidance will be provided for the detection and control of viruses and other malware. 7.2.4 Access to individual servers will normally require authorisation and authentication via passwords, but the University will, as far as is practicable, implement a single sign-on for access to central servers. The University requires all users of its computers and networks to have a strong password and to keep it secret. 7.2.5 Heads of Schools and Units will be responsible for the security of departmental systems. The University’s Network Connection policy requires that all systems connected to the network are kept up-to-date with the latest security patches. The University will provide guidance on best practice. 7.2.6 The University will continue to take advantage of appropriate technologies to improve access control and ease of use, e.g. digital signatures, encryption, and bio-authentication. 7.3 Security of data 7.3.1 Staff are required to take all reasonable steps to ensure the physical security of data. These include locking offices, desks and cupboards, and ensuring that visitors and unauthorised persons do not have access to offices where data is routinely displayed on screens. 7.3.2 Particular care must be taken when data is removed from the secure environment provided by a locked office and the secure network, for example when information is printed or photocopied copied onto portable media, such as CD/DVD, portable hard drives or memory-sticks sent by email carried on a portable computer 7.3.3 The custodian of information should decide the appropriate level of security for specific items. For example, in some cases it will be inappropriate for the information to be removed from a secure office, and in some it may be inappropriate for information to be stored on a networked computer. Those handling University information should consult the custodian in cases where there is any doubt about the level of security required. 7.3.4 The custodian of information must ensure, insofar as is possible, the accuracy and currency of information, and must take reasonable steps to maintain data integrity for information held in physical or in electronic form. In order to prevent corruption or loss of data, the custodian must ensure that reliable backup procedures are instituted. Restoration procedures following backup 98879470 4 must be tried and tested, in accordance with the University’s Business Continuation strategy. 7.3.5 Arrangements will be made for archiving material as needed (within the Data Protection Act), with attention given to retention schedules and secure storage. 7.3.6 The University has a policy and procedures for secure disposal which must be used for the disposal of sensitive material, include information relating to personnel, University committee papers or financial documents. Computing equipment holding University data or licensed software must be disposed of responsibly, ensuring that hard disks are wiped or reformatted, so that no data can subsequently be retrieved. 7.3.7 Guidance on matters relating to data security will be given by the Data Protection Officer; guidance on technical issues to do with the security of electronic data will be given by the Director of IT Services. 8. General 8.1 Standards 8.1.1 The University will adhere to appropriate national and international standards in deploying technology, consistent with the requirements of a teaching and research environment. In addition, the University will comply with appropriate codes of conduct and good practice developed by the higher education community, appropriate professional bodies, or by those bodies with which it collaborates. 8.1.2 The University will have regard to the British Standard: Code of Practice for Information Security Management, BS7799 in defining information management procedures and guidelines. 8.1.3 At any given time the University’s current strategy document for Information Technology should identify the major standards to be followed with regard to information security. 8.2 Audit 8.2.1 Heads of Schools and Units required to show what steps have been taken to ensure that appropriate strategies and procedures relating to the security, integrity, resilience and confidentiality of information are in place at departmental level. 8.2.2 Policies and procedures relating to information held or managed within the University will be audited and reviewed regularly by the Information Committee or other appropriate body. 8.3 Funding 8.3.1 The University will devote central or departmental funding as appropriate for the implementation and operation of the Policy, and will monitor implementation by reporting through central and departmental plans. 98879470 5 8.4 Complaints Procedures 8.4.1 Alleged contraventions of the legislation and the University’s policies, guidelines or codes of practice, or alleged breaches of security should be submitted via the appropriate University complaints or grievance procedure. 8.4.2 Alternatively, specific points of contact may be identified to obtain more detailed guidance or to carry out a preliminary investigation. In particular, where a technical investigation is required or where it is suspected that there has been a breach of computer or network security, the Director of IT Services must be contacted without delay. 8.4.3 The University will publish a point of contact for use by external individuals or bodies who wish to make a complaint relating to the behaviour of the University or any member of staff or student, for example in connection with breach of copyright or any illegal or inappropriate use of IT. 8.5 Disciplinary Procedures 8.5.1 In addition to any possible legal sanctions attaching to particular elements of this policy, breach of the policy and failure to follow the guidelines for computer and data security are internal disciplinary offences. 8.5.2 The Director of IT Services can authorise any reasonable steps to be taken to investigate suspected breaches of the policy, and can either impose sanctions as laid down in the Policy on the provision of IT services, or refer the matter to the appropriate disciplinary body. 98879470 6