UF Risk Management EV0004 IT Products & Services Security Risk Assessment Information Security and Privacy Evaluation The UF IT Risk Assessment process begins with this document. This Security Evaluation will help to determine the security fitness of a planned implementation of a new product to be purchased or developed, a major upgrade, enhancement, or the migration of an existing system to be used for purposes other than healthcare or with healthcare related data. Please complete as much as you can. We understand there may be some questions so feel free to contact the Security Analyst assigned to this project. Please understand that risk assessments can take from 2-12 weeks to complete. The risk team is only one part of the process. When appropriate, we also involve Purchasing, Privacy, Legal, and Contracts and Grants. The more documentation and details you provide will help expedite the process. If you would like to learn more about the risk management workflow please visit: UF IT Risk Assessment. For instructions on how to complete this form please visit: Intake Form Instructions Project/System Name: xxxx Sponsoring UF Unit: xxxx The UF Information Security Office has completed a point-in-time assessment of the Project/System Name risk posture. If any changes occur in this system, it is essential that the risk posture be reevaluated. New vulnerabilities and exploits are found almost every day. Some of the most common targets of these attacks are authentication mechanisms, session management, access controls, data stores (injection), faulty application logic, and bypassing client side controls. Even when appropriate security measures are being taken to protect information systems from internal and external attacks, there is no 100% way to ensure complete security. All Internet connected applications and websites can be potentially attacked. This Risk Assessment consists of an objective evaluation of risk based on the NIST (National Institute of Standards and Technology) Security Standards, in which assumptions and uncertainties are clearly considered and presented in the recommendations and known residual risk. Private data use approved by: Chief Privacy Officer Residual risk accepted by: Sponsoring Dean, Director, or Department Chair Signature: _________________________ Signature: ____________________________ Name: __Susan Blair_________________ Name: _______________________________ Date: _____________________________ Date: ________________________________ Page 1 Version 4.1 UF Risk Management EV0004 IT Products & Services Security Risk Assessment Part I – Identification (to be filled out by the sponsoring UF Unit) Identify all that is known about planned ownership and responsibility of the new system or service. Completeness and accuracy of identification information is very important for expediency of the evaluation process. Ownership and Responsibility Project Name Department Purchasing/UF Sponsoring Unit UF Project Customer IRB Approval # Lead Administrator Information Security Manager (ISM) Find your ISM/ISA Information Security Administrator (ISA) Information Security Analyst Acceptable Downtime: 0 24 72 hour hours hours ☐ ☐ ☐ 2 weeks ☐ As resources become available ☐ Acceptable Data Loss: 0 1 24 hour hours hours ☐ ☐ ☐ 1 week ☐ Data Loss Not Important ☐ FISMA Accreditation Required? Yes No ☐ ☐ Acceptable Downtime (Recovery Time Objective-RTO) is a measure of importance of the system to the sponsoring Unit. The Unit should think about and declare how long it will be willing to operate without the system in the event of a natural or environmental disaster, or a major hardware failure. Acceptable Data Loss (Recovery Point Objective-RPO) is the point in time to which you must recover data as defined by your organization. This is generally a definition of what an organization determines is an "acceptable loss" in a distressed situation. These parameters are business decisions and are best determined up front so that appropriate design and funding can be planned in advance. FISMA Accreditation (Federal Information Security Management Act) is required by most federal government contracts and many grants, and entails significant effort to achieve compliance. Page 2 Version 4.1 UF Risk Management EV0004 IT Products & Services Security Risk Assessment Product(s) Being Evaluated Software: Hardware: Services: Vendor/Developer Contact System Administration Contact Technology Yes No N/A Comments Is this system or application similar to any other UF Enterprise System? ☐ ☐ ☐ Please provide any comments. Will this data be stored at UF? ☐ ☐ ☐ [If yes, please provide additional details on location.] If this projects involves the use of PHI has a BAA been reviewed by legal and privacy? BAA Info ☐ ☐ ☐ Please attach or provide link to location of document. If other restricted data is going to be used and a third party has access, is there a confidentiality agreement? ☐ ☐ ☐ Please attach or provide link to location of document. Also provide the name of the Attorney you are working with. Does this involve an external hosting? ☐ ☐ ☐ Please indicate if this is SaaS, PaaS, IaaS. SaaS: Software as a Service (turnkey software service; UF does not manage underlying infrastructure) PaaS: Platform as a Service (UF manages the software, but everything else is provided by the cloud vendor) IaaS: Infrastructure as a Service (UF manages software and server OS, but everything else is provided by the cloud vendor) ☐ ☐ ☐ Yes No N/A Has risk been assessed previously? ☐ ☐ ☐ [Replace this text with the location of the Risk Assessment document.] If hosting, has the vendor had an independent assessment performed? ☐ ☐ ☐ [Replace this text with the location of the Risk Assessment document.] Is remote access required? If yes, how is it provided: VPN, RDP, etc.? Risk Please describe remote access method. Comments Time Estimates Comments Assessment Time Frame Start Date of Assessment Estimated End Date Project Start Date Approximately 2-12 weeks Page 3 Version 4.1 UF Risk Management EV0004 IT Products & Services Security Risk Assessment Part II - Information to be collected and purpose (to be answered by sponsoring unit) To understand more about data classification, see: Data Classification Policy Information Classification Guide Restricted: Data subject to specific protections under federal or state law or under applicable contracts. Protected Health Information – Individually identifiable health information; health information combined with name, or med record #, or address, or key dates, or family members, or any other information that would link a person to their health condition. (http://privacy.ufl.edu/) Student Records - Individually identifiable student information; name or UF ID or SSN or photo, in combination with grades, demographics, admissions, schedules, class rosters, financial, or any information needed and used by our faculty and staff about our students, with the exception of a limited amount of directory information. (Confidentiality and Privacy Information - FERPA) Personal Identification Information - Names combined with SSNs, or driver’s license numbers or Florida Ids, or any Financial account numbers and access codes, or any other information that could be used to commit fraud using someone else’s identity. (http://privacy.ufl.edu/) Credit Card Numbers with or without any other type of identifier. Credit cards – Any of Primary Account Number (PAN), Cardholder name, expiration date, security code or PIN. (see University of Florida Merchant Credit Card Policy) Export controlled – Data covered by the International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR). (see Export Control Regulations) Sensitive: Important for UF to protect, but not protected by laws. Research work in progress Animal research protocols Financial information Employee performance reviews, disciplinary documentation, compensation Risk assessment and security vulnerability information Privacy/Security incidents and investigations User identifiable audit records Proprietary courseware, software code or other UF trade secrets Open: Intended for public use. Advertisements Job opening announcements University catalogs Regulations and policies Faculty publication titles Press releases Data Types to be Collected Protected Health Information ☐ Credit or debit card ☐ Financial account ☐ SSN ☐ Financial account ☐ Passport number ☐ Driver’s License or FL ID ☐ Full name ☐ Student grades or records ☐ Date of birth ☐ ☐ ☐ Other restricted data protected by law, regulations or contracts Other (specify below) ☐ Sensitive data Export controlled (ITAR, EAR) Open Data Page 4 ☐ Version 4.1 ☐ UF Risk Management EV0004 IT Products & Services Security Risk Assessment Other Risk Factors Estimated number of person’s data to be collected Number of users: The approximate number of individuals that directly interact with this system Financial impact: An estimate of the university's costs if this system were to be lost. Could a substantial or specific danger to the health and safety of a person due to the malfunction or lack of availability of this information system? Purpose of Data Collection Student education Non-credit activity University administration (including HR) Sales of goods or services (non-academic) ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ Law enforcement Medical care Sponsored research Other (Specify below): 1. Describe why the data elements to be collected are required for the purpose(s) indicated above, and why the desired purpose cannot be accomplished without the indicated data elements: Please answer: Page 5 Version 4.1 UF Risk Management EV0004 IT Products & Services Security Risk Assessment Part III – Detailed Description and Demo Please answer the below questions. If a live demonstration is possible, please work with the security analyst to schedule a live demonstration of the system to show system functionality and confirm any information security assertions made by the vendor. Please include: 1. A detailed description of the purpose of the system, including how the information will be used. Please answer: 2. For Restricted Data, please include data retention plans. Data retention plans must include: a. The amount of unique personally identifiable information records the system will store at the time the system will be put in production, b. The amount of records the system will grow during a specific period of time (month, quarter, and year). c. The plans to properly destroy the data. d. If records are downloaded and stored separately, what is the medium and how long are records retained? Please answer: Page 6 Version 4.1 UF Risk Management EV0004 IT Products & Services Security Risk Assessment 3. A diagram that includes the dataflow and storage locations of Restricted information (SSNs, credit card numbers, PHI, student records, etc.) that will take place or be permitted in the operation, support, and use of this information system. (How to create an Information System/Data Flow Diagram) a. Indicate firewalls, VLANs, servers, databases, applications, and other infrastructure components. b. Indicate who manages each information system component (Ex: UFIT, UF Health, Unit, vendor, etc.) c. Indicate on the diagram the service, port, and protocols of each component of the system. d. Indicate the authorization boundary. (The Authorization Boundary describes the limits of the Information System – which pieces are currently being assessed. Information Systems often depend on other Information Systems, but those other Information Systems will be assessed independently, and their risk factored into the current Information System.) e. Indicate on the diagram methods of user access to the system and the directional flow of information using arrows. f. Indicate any connections in which this system may exchange restricted information with another system. g. Indicate clearly where any data is transferred to or accessed by any third party, including vendors, technical support, or outsourced service providers. Insert Diagram (addressing the above): Below is a sample Dataflow Diagram (Visio and PPT templates available): Page 7 Version 4.1 UF Risk Management EV0004 IT Products & Services Security Risk Assessment Uses and Disclosures (To be answered by the Sponsoring UF Unit) YES NO N/A Comments 1. If the system and human subject or patient information are to be used for research, has it been reviewed and approved by the UF IRB and have appropriate waivers or subject authorizations been obtained? ☐ ☐ ☐ 2. If the system and personal information are to be used for marketing, have (or will) personal authorizations been completed and reviewed and approved by the UF Privacy Office? ☐ ☐ ☐ 3. If the system and personal information is to be used for fund raising, have (or will) personal authorizations been completed and reviewed and approved by the UF Privacy Office? ☐ ☐ ☐ 4. If personal information or access to the system will be provided to a 3rd party (anyone who is not a UF workforce member), will a Business Associate Agreement or Confidentiality Agreement be signed with the 3rd party? ☐ ☐ ☐ 5. If a support vendor will have a logon id into the system or will be removing hardware from the site for repair or replacement, will a Business Associate Agreement or Confidentiality Agreement be signed with the support vendor? ☐ ☐ ☐ 6. If the system will be used to store or transmit full or partial social security numbers, has an exemption request been approved by the Privacy Office? ☐ ☐ ☐ 7. If the system will be used to store or process credit card or other financial account information, have Red Flags policy and standards for identity protection been written and approved by the Privacy Office? ☐ ☐ ☐ 8. Will all data remain within and under the jurisdiction of the State of Florida? If no, indicate states of jurisdiction in part IV – Description ☐ ☐ ☐ 9. Will all data remain within and under the jurisdiction of the United States? If no, indicate countries of jurisdiction in part IV - Description ☐ ☐ ☐ Part IV – Supporting Documentation Please attach any DUA, BAA, Confidentiality Agreements, or any other supporting documentation here. Page 8 Version 4.1