Model Approaches to IT Policy Development

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Model Approaches to IT Policy

Development

EDUCAUSE Pre-Conference Seminar 05A, October 19, 2004

Amy Ginther , Coordinator of Policy Development and

Education, University of Maryland

Merri Beth Lavagnino, Deputy IT Policy Officer, Indiana

University

Jenny Mehmedovic , Coordinator of IT Policy & Planning,

University of Kansas

Seminar Overview

Check-In and Logistics

I. Introduction

II. The Policy Process

III. IT Policy Examples

IV. Conclusion

2

I. Introduction

3

What is a Policy?

This term can be used to describe:

The strategic direction or operating philosophy of an organization

Legislative and regulatory developments, also known as “public policy”

Operational statements or directions, also known as “institutional policy”

4

Institutional Policies

Statements that reflect the philosophies, attitudes, or values of an organization related to a specific issue.

 Concise statement of what the policy is intended to accomplish, not how to accomplish it

 One or two sentence description of general organizational intent

 General enough to provide flexibility

5

Policy Example

Indiana University will provide access to appropriate central and campus computing resources…to all members of the University community whose work requires it.

Excerpt from “General Policies: Access” section of

Computer Users’ Privileges and Responsibilities,

Fall

1999

6

What About the “How”?

The “how” is accomplished through:

 Procedures

 Guidelines

 Checklists

 Standards

Resist the temptation to put the “how” into the policy statement!!

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Procedures

Detailed statements (often supporting a policy) describing how to accomplish a task or reach a goal

Actions are generally mandatory

More explanatory text included

8

Procedure Example

Requests for access to central campus computing and networking resources should be directed to the regional Chief

Information Officer or their delegate on the campus where the required service is located.

Excerpt from “Procedure Reference” section of Policy on Eligibility to Use Indiana University Information

Technology Resources, March 26, 2002

9

Guidelines

Information about how to accomplish a task or reach a goal

Provided as suggestions – not mandatory, but a good idea

May contain an element of “best practices”

 Alternate actions might work, but these have been found to work the best

More explanatory text included

10

Guideline Example

Authentication is the process of ensuring that the person supplying an identity is the person to whom the supplied identity has been assigned.

There are industry-standard methods for authenticating the identity of users.

Generally, it is accepted that the forms of authentication come in three types -something the user knows (e.g., a password ), something the user carries (e.g., an

ID card), or something about the user (e.g., a fingerprint). A combination of at least two of these is necessary to adequately ensure appropriate access to the most sensitive/confidential information, while a simple password may be adequate for less sensitive (e.g., non-restricted) materials.

Six (6) standard levels of authentication for access to services are currently recognized, and selection of the appropriate method will be commensurate with the type of access and the sensitivity of the data involved. The Data Steward for the data area involved will, with input from others, make the decision about the level and type of authentication that will be deployed:

1)

Network Address/Physical Location. May be used where it is only important to restrict access to data or a particular service to persons using a specific or any Indiana

University networked device. "Proxy"-type services may be deployed where it is necessary to provide this access to IU users who are not physically attached to an IU network segment. However, some additional form of authentication is necessary to ensure that the person accessing this proxy mechanism is indeed a member of the IU community and as such authorized to access the network address-protected services.

Excerpt from “Appropriate Access” section of

Guidelines for Handling Electronic Institutional and Personal Information, Indiana University, October 26, 2000

11

Checklists

One or more statements dictating how to accomplish a task

 Considered as commands

Apply to an immediate circumstance and mandatory in that situation

Simple language, no explanatory text

Sequence important

12

Checklist Example

1)

2)

3)

4)

Immediately inform senior administrators present in the office of any request by a law enforcement agency.

All efforts will be made by the staff to ensure that, to the extent possible, communications with the law enforcement officer are made in a conference room or other area removed from any students or visitors who may be present.

If the request of the law enforcement agency is not submitted in writing, staff should make a written record of all information requested.

Senior administrators will notify University Counsel ((812) 855-

9739 or (317) 274-7460 on the IUPUI campus) of the law enforcement agency’s visit and request. The University Counsel will advise the administrator(s) regarding the appropriate response to the request.

Excerpt from “

Protocol for Police or FBI Requests for Information

,”

Indiana University

13

Standards

Statements dictating the state of affairs or action in a particular circumstance

A rule established by a recognized authority, with no deviation allowed

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Standards Example

A DES key consists of 64 binary digits ("0"s or "1"s) of which 56 bits are randomly generated and used directly by the algorithm. The other 8 bits, which are not used by the algorithm, may be used for error detection. The 8 error detecting bits are set to make the parity of each 8-bit byte of the key odd, i.e., there is an odd number of "1"s in each

8-bit byte1. A TDEA key consists of three DES keys, which is also referred to as a key bundle. Authorized users of encrypted computer data must have the key that was used to encipher the data in order to decrypt it. The encryption algorithms specified in this standard are commonly known among those using the standard. The cryptographic security of the data depends on the security provided for the key used to encipher and decipher the data.

Excerpt from “Explanation” section of Data Encryption Standard (DES),

15

National Institute of Standards and Technology , 1999 October 25

In Practice…

Procedures, guidelines, checklists, and standards all must implement, reflect, and support the applicable policy or policies

The entire set of statements is sometimes considered to be the “Policy.” They are often located together, even as sections in the same document.

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Why are Policies Created?

As a result of internal influences:

 Correction of misbehavior (reactive)

 Organizational change (reactive)

 Assessment of significant liabilities or problems

(proactive)

As a result of external influences:

 Legislative

 Regulatory

 Public policy

17

Who are Policies Created For?

We can refer to this as the “scope”:

Institution

Campus

Department/School/Unit

Or…

Users of a service

Or…

Subset of population by status

18

Who Creates Policies?

Likely differs by the scope of the policy as outlined in the previous slide

Likely differs also by size of the scope

 Large scope = dedicated policy office

 Medium scope = dedicated policy person

 Small scope = committee

19

Organizing for the Policy Process

Institution may have organized it for you

(generally only for institution-wide policies)

Look for a “Policy on Policies”

At minimum:

 Establish authority

 Create a common and consistent format

 Set up an online home for all your policies

20

II. The Policy Process

21

Policy Development Process with Best Practices (ACUPA)

22

ACUPA’s Policy Stages

Pre-development:

Identify issues

Conduct analysis

Development:

Draft language

Get approvals

Determine distribution/education

Maintenance:

Solicit evaluation & review

Plan measurement & compliance

23

Policy Life Cycle

5)

6)

7)

1)

2)

3)

4)

Setting the stage for policy development

Writing the policy

Approving the policy

Distributing the policy

Educating the community about the policy

Enforcing the policy

Reviewing the policy at regular intervals

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Traits of Sound Policy Processes

Setting the

Stage

Consistency with

University values and mission

Identification and involvement of stakeholders

Informed participants

Assess costbenefit

Writing Approving Distributing Educating Enforcing

Preventing reinvention of the wheel

Discussion and consensus building

Wide review and input

Allow for user feedback

Accessible from one online location

Allow for text and other searches

Use a common format

Approval from senior administrative levels

Send email to official distribution lists

Agree on common definitions & terms

Include contacts to answer questions

New and existing users

Create policy enforcement office

Hold a policy day

Have traveling road shows

Assess liability/ feasibility

Respond to complaints

Signed user agreements

Require policies to be read before services granted

Reviewing

Identify an owner for each policy

Develop a plan for active maintenance

Archive, date, and notify constituencies of major changes

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1) Setting the Stage

Understanding the Environment

What makes

IT policy development in our institutions different?

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1) Setting the Stage

Higher Education Values

The higher education environment tends to be more open than corporate or government environments

 Reality of student residential environments

 Academic values

Policy measures must protect and not impede the expression of these values

Balance need for policies with important aspects of higher education environment

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1) Setting the Stage

Core Academic Values

Community: shared decision making; outreach to connected communities (access to affiliates or other patrons)

Autonomy: academic and intellectual freedom; distributed computing

Privacy: “the right to open inquiry without having the subject of one’s interest examined or scrutinized by others” (American Library

Association, 2002)

Fairness: due process

From Oblinger, Computer and Network Security in Higher Education , 2003. Mark

Luker and Rodney Petersen, editors. http://www.educause.edu/asp/doclib/abstract.asp?ID=PUB7008

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1) Setting the Stage

Influences on IT Policy

EDUCAUSE/Internet2 six principles to guide policy development:

Civility and Community

Academic and Intellectual Freedom

Privacy and Confidentiality

Equity, Diversity and Access

Fairness and Process

Ethics, Integrity and Responsibility

29

1) Setting the Stage

Get Authorization and Support

Are you here because you have been assigned to do IT policies by some authority?

Or, are you still trying to figure out how to establish authority for creation and maintenance of IT policies?

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1) Setting the Stage

Identify Policy Issues

What are the IT issues affecting your organization that appear to need to be addressed through policy?

Ensure there aren’t already policies at your institution covering these issues

31

1) Setting the Stage

Identify Stakeholders

32

1) Setting the Stage

Assemble a Team

Usually it is a different team for each policy, because it depends on the issue being addressed in the policy

Remember some important stakeholders may be better reviewers than writers

33

1) Setting the Stage

Ensure Participants are Informed

Begin discussions with an understanding of underlying legal foundations and related policies

34

1) Setting the Stage

Consistency with University Values

How to achieve?

 Develop understanding of core values and mission by meeting with upper administrators

 Outline various scenarios that might arise and then discuss what values are around those scenarios

35

1) Setting the Stage

Assessing Cost-Benefit

Analyze need for policy in light of benefits, costs, liabilities

Must not cost more (in any terms) than the problem or situation addressed

36

1) Setting the Stage

Wait a Minute!

Is there a place for

IT policies?

37

1) Setting the Stage

Discussion

38

2) Writing the Policy

Don’t Reinvent the Wheel!

Is anyone else out there?

Using others’ work to fit your environment

 Ask and ye shall receive!

 Just give credit

 Asking questions of colleagues at other institutions

39

2) Writing the Policy

Don’t Reinvent the Wheel!

Are you writing a University-wide or departmental policy?

Highlight gaps in non-IT policy language

Insert IT needs into existing University policy

Add a paragraph, rather than write an entirely new policy

40

2) Writing the Policy

Consensus Building

Start discussions with a blank page to avoid getting caught up in semantics

Build consensus on issues not words

THEN, draft policy language

41

2) Writing the Policy

Define Terms

Agree on common definitions and terms related to the policy topic

Document these for a section of the policy

42

2) Writing the Policy

Use a Common Format

Check for a common format used for other policies at your institution

Check EDUCAUSE Policy Library for samples of other formats

Establish a format to be used for all your IT policies

43

2) Writing the Policy

Example: KU IT Policy Template

The University of Kansas

Information Services Policy and Procedures Template

Policy Name:

Policy Purpose:

Scope:

Responsible Office:

Approval: Provost and Executive Vice Chancellor

Approved: date

Effective:

Review Cycle:

General Policy Provisions

Responsibilities of Information Services

Responsibilities of University Departments

Consequences/Sanctions

44

2) Writing the Policy

Example: IU IT Policy Template

Subject

Source (what office produced it)

Policy Number

Date Issued

Rationale

Policy

Applicability

Definitions

Procedure Reference

Responsible Organization

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2) Writing the Policy

Writing Style

Use simple, exact text

 Remember everyone needs to be able to understand what it says

 Not florid and fancy

Does “should” mean they have to?

 If technical terms must be used, define them

Check to see if your campus has a Style

Manual

46

2) Writing the Policy

Discussion

47

3) Approving the Policy

Initial Feedback

Solicit comment for drafts throughout the writing process from:

 the approving officers

 senior administrative levels

 the identified stakeholders

Solicit and allow for user feedback

Consider a “Request for Comment” period

48

3) Approving the Policy

Final Approval

Secure approvals for final version from all stakeholders and approving bodies

49

3) Approving the Policy

Discussion

50

4) Distributing the Policy

Make the Policy Available

Create a policy website

 Ease of access

 Web-based directories

 Allow for searches

Codify policies in an easy to understand format

Ensure any central policy web site at your institution has a link to your IT policy site

Include contact information for asking questions

51

4) Distributing the Policy

Plan the Publicity Strategy

Establish a regular communication channel for announcing new and revised policies

 E-mail distribution lists

 Institutional publications

 Faculty

 Staff

 Students

 IT publications, online user support documents

 Direct mailings

52

4) Distributing the Policy

Discussion

53

5) Educating the Community

New Users

Try to get on Orientation agendas for new faculty, staff, and students

 Speaker

 Handouts

 Video

 Signed user agreements

Use your IT influence!

“I agree” statements to click through when obtaining accounts, registering to the network, etc.

Direct mailing

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5) Educating the Community

Existing Users

Educational postcards, posters, etc.

Have a traveling road show!

 Policy person attend departmental and faculty meetings to talk about policies

Hold policy brown bags

Sponsor a “Policies Day”

55

5) Educating the Community

Discussion

56

6) Enforcing the Policy

Liability Issues

Are there liability concerns in creating unenforceable policies?

 Standard of care/negligence

Do you have adequate staff to support enforcement?

Is information distributed to educate users on consequences of non-compliance?

57

6) Enforcing the Policy

Be Prepared for Complaints

Typical way to enforce is to respond to complaints

Create a policy enforcement office, if possible, or at least identify one person who will coordinate

Establish relationships with disciplinary authorities (Dean of Students for students; Human

Resources for staff; Dean of Faculties for faculty)

Establish relationships with Legal Counsel, auditing, University police, local prosecutors

Publicize procedures for reporting, especially within IT support units

58

6) Enforcing the Policy

Responding to Complaints

Focus on gathering evidence:

If there is no evidence, there is nothing to pursue

If technology is not the root problem, pass it off…

Determine which types of infractions:

 can receive a warning from your office

 are sent to disciplinary official

 require law enforcement involvement

Ensure records are kept confidential

59

6) Enforcing the Policy

Discussion

60

7) Reviewing the Policy

Plan for Active Maintenance

Assign an owner for each policy, or assign one person to maintain them all

Develop a timeline for regular review

Encourage feedback

Don’t forget IT support personnel

Archive changes, date new releases

Measure outcomes by monitoring or testing

61

7) Reviewing the Policy

Discussion

62

III. IT Policy Examples

63

Policy Feud!!

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Policy Library Demo

EDUCAUSE Policy Library Demo http://www.educause.edu/resources

University of Kansas

 h ttp://www.vpinfo.ku.edu/Policy_Library/

University of Minnesota

 http://www.fpd.finop.umn.edu/

65

Questions?

(Time for a little writing?)

66

IV. Conclusion

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(net)Working It!

Identify your peers at other institutions

Attend EDUCAUSE/Cornell Institute for

Computer, Policy and Law

Join ACUPA, ICPL listservs

Ask many questions!

Benefit from others’ expertise!

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Presenter Contact Information

Amy Ginther : aginther at umd.edu

, (301) 405-2619

Merri Beth Lavagnino : mbl at iu.edu

, (317) 274-3739

Jenny Mehmedovic : jmehmedo at ku.edu

, (785) 864-4999

© Copyright 2004 Amy Ginther, Merri Beth Lavagnino, Jenny

Mehmedovic. Permission to make and distribute verbatim copies is granted for non-profit, educational purposes provided this copyright and permission notice is preserved on all copies.

69

Policy Writing Workshop

EDUCAUSE Pre-Conference Seminar 05P, October 19, 2004

Amy Ginther , Coordinator of Policy Development and Education,

University of Maryland

Merri Beth Lavagnino, Deputy IT Policy Officer, Indiana

University

Jenny Mehmedovic , Coordinator of IT Policy & Planning,

University of Kansas

Workshop Overview

Check-In and Logistics

I. Introduction

II. Review of Sample IT Policies

III. Review of Policy Tools

IV. Policy Writing Exercise

V. Conclusion

71

I. Introduction

72

Goals for Today

Lead all through one example of planning for and drafting a policy

We’ll make up a lot of assumptions in order to do this!

Participants will plan for and draft at least one local policy

 You may do as many as you have time for

 You will have feedback from others on at least one of them

73

II. Review of Sample IT

Policies

74

Most Common IT Policies

Review

Identify what issue each of us will start work on today

75

III. Review of Policy Tools

76

Tools of the Trade

Policy Process Planning Template

Policy Writing Template

Your institution’s

Style Guide, or your choice of commercial style guide (such as

Chicago Manual of Style , APA ,

Strunk’s

, etc.)

Samples of the type of policy you are writing, from other institutions

77

Leading Questions

Is this a University-wide or a departmental policy?

Who needs to approve the policy?

Who are the stakeholders?

What are some scenarios needing a resolution that could use this policy?

What are the values of the institution in relation to these scenarios? (institutional culture)

What are the risks of not having a policy about this?

Is it an IT policy or somebody else’s policy that’s just related to IT?

Is there a difference between student, faculty, staff for this policy?

78

Hints

More leading questions in your packet

Be imaginative at this stage – you won’t know all the answers but you can make something up which can be tweaked later. The key is to START!

Don’t get caught up on one section or issue. If you find you’ve spent more than ten minutes on something without a result, mark it for feedback and move on.

79

IV. Policy Writing Exercise

80

Policy Writing Exercise

Demo

81

Policy Writing

82

Feedback Time!

83

V. Conclusion

84

Presenter Contact Information

Amy Ginther : aginther at umd.edu

, (301) 405-2619

Merri Beth Lavagnino : mbl at iu.edu

, (317) 274-3739

Jenny Mehmedovic : jmehmedo at ku.edu

, (785) 864-4999

© Copyright 2004 Amy Ginther, Merri Beth Lavagnino, Jenny

Mehmedovic. Permission to make and distribute verbatim copies is granted for non-profit, educational purposes provided this copyright and permission notice is preserved on all copies.

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