Wayne School District (WSD) supports secure network systems, including security for all personally identifiable information that is stored on paper or stored digitally on WSD-maintained computers and networks. This policy supports efforts to mitigate threats that may cause harm to the district, schools, students, or employees at WSD.

WSD will ensure reasonable efforts will be made to maintain network security. Data loss can be caused by human error, hardware malfunction, natural disaster, security breach, etc., and may not be preventable.

All persons who are granted access to the WSD network and other technology resources are expected to be careful and aware of suspicious communications and unauthorized use of devices on the network. When an employee or other user becomes aware of suspicious activity, he/she is to immediately contact the network administrator with the relevant information.

This policy also covers third party vendors/contractors that contain or have access to WSD critically sensitive data. All third party entities will be required to sign the Restriction on Use of Confidential Information Agreement before accessing our systems or receiving information.

It is the policy of WSD to fully conform with all federal and state privacy and data governance laws.  Including the Family Educational Rights and privacy Act, 20  U.S. Code §1232g and 34 CFR Part 99 (hereinafter “FERPA”), the Government Records and Management Act  U.C.A. §62G-2 (hereinafter “GRAMA”), U.C.A. §53A-1-1401 et seq. and Utah Administrative Code R277-487.

The board directs the WSD IT Director to develop procedures to support this policy. Employees are required to follow the procedures developed by the IT Director. Professional development for staff regarding the importance of network security and best practices is to be included in the procedures. Students are also required to follow the procedures as applicable. The procedures associated with this policy are consistent with guidelines provided by cyber security professionals worldwide and in accordance with Utah Education Network. The board supports the development, implementation and ongoing improvements for a robust security system of hardware and software that is designed to protect data, users, and electronic assets.

WSD Security Procedures

Definitions

Access: Directly or indirectly use, attempt to use, instruct, communicate with, cause input to, cause output from, or otherwise make use of any resources of a computer, computer system, computer network, or any means of communication with any of them.

Authorization: Having the express or implied consent or permission of the owner, or of the person authorized by the owner to give consent or permission to access a computer, computer system, or computer network in a manner not exceeding the consent or permission.

Computer: Any electronic device or communication facility that stores, retrieves, processes, or transmits data.

Computer system: A set of related, connected or unconnected, devices, software, or other related computer equipment.

Computer network: The interconnection of communication or telecommunication lines between: computers; or computers and remote terminals; or the interconnection by wireless technology between: computers; or computers and remote terminals.

Computer property: Includes electronic impulses, electronically produced data, information, financial instruments, software, or programs, in either machine or human readable form, any other tangible or intangible item relating to a computer, computer system, computer network, and copies of any of them.

Confidential: Data, text, or computer property that is protected by a security system that clearly evidences that the owner or custodian intends that it not be available to others without the owner's or custodian's permission.

Encryption or encrypted data:  The most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it.

Personally Identifiable Information (PII):  Any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered Protected data

Security system: A computer, computer system, network, or computer property that has some form of access control technology implemented, such as encryption, password protection, other forced authentication, or access control designed to keep out unauthorized persons.

Sensitive data:  Data that contains personally identifiable information.

System level:  Access to the system that is considered full administrative access.  Includes operating system access and hosted application access.

Security Responsibility

District IT security shall be the primary responsibility of the District IT Department, led by the IT Director. The IT Department shall be responsible for the development of policies and adherence to the standards defined in this document.

Employee Security Awareness Training

1.     Overview

WSD, led by the IT Director, shall ensure that all employees having access to sensitive information undergo annual IT security training which emphasizes their personal responsibility for protecting student and employee information. Training resources will be provided to all employees.

2.     Purpose

These methods help ensure employees have a solid understanding of our security policy, procedures, and best practices. Employees shall also have a basic understanding of the following security related topics: social engineering tactics, email and messaging security, safely browsing the internet, social networking threats, mobile device security, password best practices, data classification, data transmission and encryption, data destruction, WiFi security, working remotely, insider threats from students and staff, physical security issues, protecting personal/work computers, copyright infringements, malware and virus protection, sharing files with local and state entities, and workspace security.

3.     Procedure

All WSD employees shall receive security specific trainings Annually.

Security for Workstations

1.     Overview

The workstations at WSD contain sensitive information and data. WSD IT Department will implement procedures to ensure that this information will be secure.

2.     Purpose

WSD shall ensure that any user’s computer must not be left unattended and unlocked, especially when logged into sensitive systems or data including student or employee information. Automatic log off, locks and password screen savers should be used to enforce this requirement.

3.     Procedure

Appropriate measures must be taken when using workstations to ensure the confidentiality, integrity and availability of sensitive information; including personally identifiable information (PII) and that access to sensitive information is restricted to authorized users.

• WSD employees using controlled workstations shall consider the sensitivity of the information, including personally identifiable information (PII) that may be accessed and minimize the possibility of unauthorized access.
• WSD will implement physical and technical safeguards for all workstations that access electronic personally identifiable information (PII) to restrict access to authorized users.
• Appropriate measures include:

○      Restricting physical access to workstations to only authorized personnel.

○      Securing workstations (screen lock or logout) prior to leaving area to prevent unauthorized access.

○      Enabling a password protected screensaver with a 15 minutes or less to ensure that workstations that were left unsecured will be protected. The password must comply with WSD Password Procedure.

○      Complying with all applicable password policies and procedures. See WSD Password Procedure.

○      Ensuring controlled workstations are used for authorized business purposes only.  Never installing unauthorized software on controlled workstations.

○      Storing all sensitive information, including personally identifiable information (PII) on secured network servers

○      Securing laptops that contain sensitive information by locking laptops up in drawers, cabinets or in a classroom/office.

○      Enable Workstation Encryption

○      Users are not set up as computer administrators

Network Security

1.     Overview

Network security entails protecting the usability, reliability, integrity, and safety of network and data. Effective network security defeats a variety of threats from entering or spreading on a network. The primary goals of network security are Confidentiality, Integrity, Availability and Accountability.

2.     Purpose

The minimal security configuration required for all routers and switches connecting to a production network or used in a production capacity at or on behalf of WSD. WSD shall ensure that all untrusted and public access computer networks are separated from main computer networks and utilize security policies to ensure the integrity of those computer networks. WSD will utilize industry standards and current best practices to segment internal computer networks based on the data they contain. This will be done to prevent unauthorized users from accessing services unrelated to their job duties and minimize potential damage from other compromised systems.

3.     Procedure

Network perimeter controls will be implemented to regulate traffic moving between trusted internal (WSD) resources and external, untrusted (Internet) entities. All network transmission of sensitive data should enforce encryption where technologically feasible.

Wireless Network Security

1.     Purpose

Network security entails protecting the usability, reliability, integrity, and safety of network and data. Effective network security defeats a variety of threats from entering or spreading on a network. The primary goals of network security are Confidentiality, Integrity, and Availability.

2.     Purpose

No wireless access point shall be installed on WSD computer network that does not conform to current network standards as defined by the IT Department.  WSD shall scan for and remove or disable any rogue wireless devices on a regular basis. All wireless access networks shall conform to current best practices and shall utilize at minimal WPA2 encryption for any connections.  Open access networks are not permitted with the exception of a managed guest network.

3.     Procedure

Wireless Network controls will be implemented to regulate traffic moving between trusted internal (WSD) resources and external, untrusted (Internet) entities. All network transmission of sensitive data should enforce encryption where technologically feasible.

Remote Access Procedure

1.     Overview

Remote access allows a user to connect from outside the WSD organization network. This procedure applies to all WSD employees, contractors, vendors and agents with a WSD owned or personally owned computer or workstation used to connect to the WSD network. This procedure applies to remote access connections used to do work on behalf of WSD

2.     Purpose

The purpose of this procedure is to define standards for connecting to WSD network from any host. These standards are designed to minimize the potential exposure to WSD from damages, which may result from unauthorized use of WSD resources. Damages include the loss of sensitive or company confidential data, intellectual property, damage to public image, damage to critical WSD internal systems, etc.  Remote access implementations that are covered by this procedure include, but are not limited to DSL, VPN, and SSH.

3.     Procedure

It is the responsibility of WSD employees, contractors, vendors and agents with remote access privileges to WSD network to ensure that their remote access connection is given the same consideration as the user’s on-site connection to WSD.

Please review the following procedures to ensure protection of information when accessing the WSD network via remote access methods, and acceptable use of WSD network:

• Encryption Procedures
• Wireless Infrastructure Communications Procedure
• Acceptable Use Procedure

Requirements

• Secure remote access must be strictly controlled. Control will be enforced via one-time password authentication or public/private keys with strong pass phrases. For information on creating a strong pass phrase see the Password Procedures.
• At no time should any WSD employee provide his or her login or email password to anyone, not even family members.
• WSD employees with remote access privileges must ensure that their WSD owned or personal computer or workstation, which is remotely connected to WSD network, is not connected to any other network at the same time, with the exception of personal networks that are under the complete control of the user.
• The WSD director must approve non-standard hardware configurations. Security configurations for access to hardware must also be approved.
• All hosts that are connected to WSD internal networks via remote access technologies, must use the most up-to-date anti-virus software, this includes personal computers.
• Personal equipment that is used to connect to WSD networks must meet the requirements of WSD owned equipment for remote access.
• Organizations or individuals who wish to implement non-standard Remote Access solutions to the WSD production network must obtain prior approval from WSD director.

Password Procedure

1.     Overview

Passwords are a critical component of information security. Passwords serve to protect user accounts; however, a poorly constructed password may result in the compromise of individual systems, data, or the entire network. This guideline provides best practices for creating secure passwords.

2.     Purpose

The purpose of this procedure is to establish a standard for the creation of strong passwords, the protection of those passwords, and the frequency of change.  This procedure applies to all personnel and entities working on behalf of WSD, who have or are responsible for any account (or any form of access that supports or requires a password) on any system that resides at or is connected to WSD.

3.     Procedure

To minimize the possibility of unauthorized access, all passwords should meet or exceed the guidelines for creating strong passwords.

Password Characteristics

Strong passwords

• Contain at least 10 alphanumeric characters
• Contain both upper and lower case letters
• Contain at least one number (for example, 0-9)
• Contain at least one special character (for example,!$%^&*()_+|~-=\`{}[]:”;'<>?,/)

Protection of passwords

• Users must not use the same password for WSD accounts as for other non-WSD access (for example, personal email accounts, shopping sites, social media, and so on
• Where possible, users must not use the same password for various WSD access needs or user accounts that have system-level privileges granted through group memberships or programs such as FileMaker must have a unique password from all other accounts held by that user to access system-level privileges; unless account has 2-factor authentication enabled
• All system-level passwords (for example, root, enable, NT admin, application administration accounts, and so on) must be changed on at least a quarterly basis
• All user-level passwords (for example, email, web, desktop computer, and so on) must be changed at least annually.
• Password cracking or guessing may be performed on a periodic or random basis by the UETN team or its delegates. If a password is guessed or cracked during one of these scans, the user will be required to change it
• Default passwords must be changed during initial setup and configuration
• Passwords must not be shared with anyone. All passwords are to be treated as sensitive, confidential information
• Passwords must not be inserted along with the username into email messages or other forms of electronic communication
• Do not reveal a password on questionnaires or security forms
• Do not share your WSD passwords with anyone, including administrative assistants, secretaries, managers, co-workers while on vacation, and family members
• Do not write passwords down and store them anywhere in your office. Do not store passwords in a file on a computer system or mobile devices (phone, tablet) without encryption
• Never use the “Remember Password” feature of applications (for example, web browsers)
• Any user suspecting that his/her password may have been compromised must report the incident to their supervisor and change all passwords immediately

Access Control

1.     Overview

Access control is the process of authorizing users, groups, and computers to access objects on the network or computer. It is a good practice to assign permissions to groups because it improves system performance when verifying access to an object.

2.     Purpose

The purpose for setting access control in the WSD organization provides system and application access based upon the least amount of access to data and programs required by the user in accordance with a business need-to-have requirement.

3.     Procedure

This procedure is directed to the IT Management Staff who is accountable to ensure proper access is given to individual employees.

• WSD shall ensure that user access shall be limited to only those specific access requirements necessary to perform their jobs. Where possible, segregation of duties will be utilized to control authorization access.
• WSD shall ensure that user access should be granted and/or terminated upon timely receipt, and management’s approval, of a documented access request/termination.
• WSD shall ensure that audit and log files are maintained for at least ninety days for all critical security-relevant events such as: invalid logon attempts, changes to the security policy/ configuration, and failed attempts to access objects by unauthorized users, etc.
• WSD shall limit IT administrator privileges (operating system, database, and applications) to the minimum number of staff required to perform these sensitive duties.

Security Response Plan Procedure

1.     Overview

A Security Response Plan (SRP) provides the impetus for security and operational groups to integrate their efforts from the perspective of awareness and communication, as well as coordinated response in times of crisis (security vulnerability identified or exploited). Specifically, an SRP defines a product description, contact information, escalation paths, expected service level agreements (SLA), severity and impact classification, and mitigation/remediation timelines.

2.     Purpose

The purpose of this procedure is to establish the requirement that all operational groups supported develop and maintain a security response plan. This ensures that the security incident response team has all the necessary information to formulate a successful response should a specific security incident occur. This procedure applies any established and defined operational group or entity within the WSD.

3.     Procedure

The development, implementation, and execution of a Security Response Plan (SRP) are the primary responsibility of the WSD director and network administrator.

Service or Product Description

The product description in an SRP must clearly define the service or application to be deployed with additional attention to data flows, logical diagrams, architecture considered highly useful.

Contact Information

The SRP must include contact information for dedicated team members to be available during non-business hours should an incident occur and escalation be required. This may be a 24/7 requirement depending on the defined business value of the service or product, coupled with the impact to customer. The SRP document must include all phone numbers and email addresses for the dedicated team member(s).

Triage

The SRP must define triage steps to be implemented with the intended goal of swift security vulnerability mitigation. This step typically includes validating the reported vulnerability or compromise.

Identified Mitigations and Testing

The SRP must include a defined process for identifying and testing mitigations prior to deployment. These details should include both short-term mitigations as well as the remediation process.

Mitigation and Remediation Timelines

The SRP must include levels of response to identified vulnerabilities that define the expected timelines for repair based on severity and impact.

Disaster Recovery Plan Procedure

1.     Overview

Since disasters happen so rarely, management often ignores the disaster recovery planning process. It is important to realize that having a contingency plan in the event of a disaster gives WSD an advantage. This procedure requires management to financially support and diligently attend to disaster contingency planning efforts. Disasters include, but are not limited to adverse weather conditions. Any event that could likely cause an extended delay of service should be considered.

2.     Purpose

This procedure defines the requirement for a baseline disaster recovery plan to be developed and implemented by WSD that will describe the process to recover IT Systems, Applications and Data from any type of disaster that causes a major outage.

3.     Procedure

This procedure is directed to the IT Management Staff who is accountable to ensure the plan is developed, tested and kept up to date. This procedure is solely to state the requirement to have a disaster recovery plan, it does not provide requirement around what goes into the plan or sub plans. The WSD director and IT director will develop the following contingency plans.

The following contingency plans must be created:

• Data Study: Detail the data stored on the systems, its criticality, and its confidentiality.
• Data Backup: Procedures for performing routine daily/weekly/monthly backups and storing backup media at a secured location other than the server room or adjacent facilities. As a minimum, backup media must be stored off-site a reasonably safe distance from the primary server room.
• Restoration Plan: Describes how the backups are restored.
• Equipment Replacement Plan: Describe what equipment is required for providing services
• Critical Systems Instructions: Documentation must include:

○      Location of installation software

○      Backup frequency and storage locations

○      Username and passwords

○      Support phone numbers

○      Steps to restart, reconfigure, and recover the system

○      Power up and power down procedures

○      Equipment age

○      Model and serial numbers

○      Warranty and maintenance contract information

○      Software licensing information and storage location

○      IP and MAC addresses

○      Supplier contacts for sources of expertise to recover systems. These might include vendors that sell/support the products, or the manufacturers themselves

○      Website username and password

○      Server username and password

○      Assigned computer username and password

Malicious Software Procedure

1.     Overview

Malicious Software is any software used to disrupt computer or mobile operations, gather sensitive information, gain access to private computer systems, or display unwanted advertising. It may be stealthy, intended to steal information or spy on computer users for an extended period without their knowledge.

2.     Purpose

The purpose of the procedure is to ensure that malicious software protection will include frequent update downloads (minimum weekly), frequent scanning (minimum weekly), and that malicious software protection is in active state (real time) on all operating servers/workstations.

3.     Procedure

This procedure is directed to the IT Management Staff who is accountable to ensure the security of district networks and data.

• Server and workstation protection software will be deployed to identify and eradicate malicious software attacks such as viruses, spyware, and malware.
• WSD shall install, distribute, and maintain spyware and virus protection software on all WSD-owned equipment, i.e. servers, workstations, and laptops.
• WSD shall ensure that all security-relevant software patches (workstations and servers) are applied within thirty days and critical patches shall be applied as soon as possible.
• All computers must use the District approved anti-virus solution.
• Any exceptions to malicious software procedure must be approved by the Security Information Officer.

Internet Content Filtering Procedure

1.     Overview

Internet content filtering is the use of a program or hardware to screen and exclude from access or availability Web pages or e-mail that is deemed objectionable.

2.     Purpose

The purpose of Internet content filtering is to provide best effort to protect students, teachers, and school employees from objectionable material.

3.     Procedure

This procedure is directed to the IT Management Staff who is accountable to ensure that Internet content filtering best practices are implemented.

• In accordance with Federal and State Law, WSD shall filter internet traffic for content defined in law that is deemed harmful to minors.
• WSD acknowledges that technology based filters are not always effective at eliminating harmful content and due to this, WSD uses a combination of technological means and supervisory means to protect students from harmful online content.
• In the event that employees take devices home, WSD will provide a technology based filtering solution for those devices.  However, the District will rely on parents to provide the supervision necessary to fully protect students from accessing harmful online content. WSD[1]  will cut because we do not provide direct access to students.
• Students shall be supervised when accessing the internet and using district owned devices on school property. WSD[2]  will cut because we do not provide direct access to students.

Data Privacy Procedure

1.     Overview

Data can be used to facilitate change and improvement, there is however a need to balance the usefulness of this data with the privacy of who the data is about.

2.     Purpose

The purpose of protecting data is to provide best effort to ensure that data breaches do not happen and to place into training and procedure steps to protect individuals.

3.     Procedure

This procedure is directed to the IT Management Staff who is accountable to ensure that Privacy and data protection best practices are implemented. Data privacy within the district shall be in accordance with the district’s Data Governance Plan.

• WSD recognizes its responsibility as the steward for all confidential information maintained within the district.
• WSD considers the protection of the data it collects on students, employees and their families to be of the utmost importance.
• WSD protects student data in compliance with the Family Educational Rights and privacy Act, 20 U.S. Code §1232g and 34 CFR Part 99 ( “FERPA”), the Government Records and Management Act  U.C.A. §62G-2 ( “GRAMA”), U.C.A. §53A-1-1401 et seq, 15 U.S. Code §§ 6501–6506 (“COPPA”) and Utah Administrative Code R277-487 (“Student Data Protection Act”).
• WSD shall ensure that employee records access shall be limited to only those individuals who have specific access requirements necessary to perform their jobs. Where possible, segregation of duties will be utilized to control authorization access.
• WSD shall designate Data Stewards to oversee the collection, storage and maintenance of confidential information within the district. Data Stewards shall manage confidential information/data in accordance with the district’s Data Governance Plan.
• All WSD board members, employees, contractors and volunteers shall undergo annual privacy training and shall be required to comply with the district’s security policy.

Audit Procedures

1.     Overview

Planned and random security audits are important in order to mitigate risk and evaluate our preparedness for a security incident. WSD contracts with UETN to conduct periodic security penetration tests using the CIS Critical Security Controls on devices and networks.

2.     Purpose

The purpose of this procedure is to ensure all devices and network are configured according to the WSD security policy. All devices connected to the WSD network are subject to audit at any time. Audits may be conducted to:

• Ensure integrity, confidentiality and availability of information and resources
• Ensure conformance to the WSD security policy

3.     Procedure

WSD hereby provides its consent to allow the UETN security audit team or an external auditor to access its devices to the extent necessary, within a predetermined scope; which will be written and approved by the UETN team to allow the auditor to perform scheduled and random audits of any/all devices at WSD.

• Specific Concerns
• WSD devices may support critical business functions and store sensitive information. Improper configuration of devices could lead to the loss of confidentiality, availability or integrity of these systems
• Guidelines
• Approved and standard configuration templates shall be used when deploying devices:

○      Host security agents such as antivirus and malware protection shall be installed and updated

○      Perform network scans to verify only required network ports and network shares are in use

○      Verify administrative group membership

○      Conduct baselines when systems are deployed and upon significant system changes

○      Changes to configuration template shall be coordinated with WSD network administrator

○      Must follow all other applicable procedures for deployed new devices

4.     Responsibility

The UETN Team or an external auditor shall conduct audits of all devices owned or operated by WSD. Device owners are encouraged to audit their own devices as needed; this does not allow a device owner to perform an audit of the WSD network or on any device not owned by the employee

5.     Relevant Findings

All relevant findings discovered as a result of an audit shall be listed in the UETN report to WSD to ensure prompt resolution and/or appropriate mitigating controls

6.     Ownership of Audit Report

All results and findings generated by the UETN team or an external auditor must be provided to appropriate WSD management within one month of project completion. This report will become the property of WSD and be considered confidential

Clean Desk Procedure

1.     Overview

The purpose of this procedure is to establish a culture of security for all WSD employees. An effective clean desk effort, involving the participation and support of all employees, will protect paper documents that contain personally identifiable and other sensitive information.

2.     Purpose

The primary reasons for a clean desk procedure are:

• A clean desk reduces the threat of a security incident since confidential information will be locked away when unattended.
• Sensitive documents left in the open can be viewed and/or stolen by a malicious entity.

3.     Procedure

Appropriate measures must be taken to ensure the confidentiality, integrity and availability of sensitive information, including but not limited to Personally Identifiable Information (PII) or sensitive personal information(SPI).

Appropriate measures include:

• Restricting physical access to devices.
• Ensuring that all sensitive/confidential information in hardcopy or electronic form is secure in the work area at the end of each day.
• Securing workstations (screen lock or logout) prior to leaving an area to prevent unauthorized access.
• Enabling a password-­‐protected screen saver with a short timeout period to ensure that devices left unsecured will be protected.
• Complying with all applicable password policies and procedures. See WSD Password Procedure.
• Ensuring devices are used for authorized educational/business purposes only.
• Never sending personally identifiable information (PII) or sensitive personal information(SPI) via email to anyone, including forwarding a message.
• Storing all sensitive information on password-­‐protected drives or secure, restricted, network servers.
• Securing laptops that contain sensitive information by using cable locks, locking laptops up in drawers or cabinets, and/or by locking the door behind you.
• Sensitive working papers should be placed in locked drawers whenever a user is away from their desk.
• At the end of the work-­‐day the employee is expected to tidy their desk by locking up all sensitive papers and devices.

Email Procedure

1.     Overview

Electronic email is used pervasively, and is often the primary communication and awareness method within an organization. Misuse of email, however, can pose many legal, privacy and security risks, thus it is important for users to understand the appropriate use of electronic communications.

2.     Purpose

The purpose of this email procedure is to ensure the proper use of the WSD email system and make users aware of what WSD deems as acceptable and unacceptable use of its email system. This procedure outlines the minimum requirements for use of email within the WSD network.

3.     Procedure

• All use of email must be consistent with WSD policies and procedures of ethical conduct, safety, compliance with applicable laws and proper business practices
• WSD email account should be used primarily for WSD business related purposes; personal communication is permitted on a limited basis, but non‐WSD related commercial uses are prohibited
• The WSD email system shall not to be used for the creation or distribution of any disruptive or offensive messages; including offensive comments about race, gender, disabilities, age, sexual orientation, pornography, religious beliefs and practice, political beliefs, or national origin. Employees who receive any emails with this content from any WSD employee should report the matter to their supervisor immediately
• Users are prohibited from automatically forwarding WSD email to a third party email system. 
• Using a reasonable amount of WSD resources for personal emails is acceptable. Sending chain letters or inappropriate joke emails from a WSD email account is prohibited
• WSD employees shall have no expectation of privacy in anything they store, send or receive
• WSD may monitor messages without prior notice. WSD is not obligated to monitor email messages

EMPLOYEE TECHNOLOGY ACCEPTABLE USE

Every WSD employee will be required to sign this acceptable use policy.

All employees are responsible for following WSD policy and procedures.

1.     INTERNET & INTERNET USE:

WSD has access to the Internet, which is governed and supported by the Utah Education Network.

Use of the electronic information resources in WSD shall be to improve and support the educational process by providing access to global information and improving communication between our districts, employees of WSD, and community members. WSD desires to provide electronic mail service, electronic conferencing, global information resources via the World Wide Web, to employees of WSD at no cost.

2.     ACCEPTABLE INTERNET USE

All Internet or computer equipment use shall be consistent with the purposes, goals, and policies of WSD. It is imperative that users of the Internet or computer equipment conduct themselves in a responsible, ethical, moral, and polite manner. All participants must abide by all local, state, and federal laws. The Internet user accepts the responsibility of adhering to high standards of conduct and the terms and conditions set forth in all parts of this policy.

3.     IMPERMISSIBLE INTERNET & COMPUTER EQUIPMENT USES

The following uses of the Internet & computer equipment are prohibited:

• Any violation of applicable WSD policy or public law by such use;
• Any activity that is immoral or contrary to the high moral standards which must be maintained in an educational setting;
• Any attempt to bypass state, WSD, district, or school security (e.g. bypassing proxies or hacking servers or work stations) is forbidden;
• Accessing or transmitting of immoral, obscene, pornographic, profane, lewd, vulgar, rude, defaming, harassing, threatening, disrespectful, or otherwise inappropriate images or information, or receiving such information from others;
• Any commercial use, product advertisement, display of private information, or promotion of political candidates;
• Any violation of copyright, trade secret or trademark laws;
• Any attempt to damage, disrupt or interfere with the use of any computer electronic information resource;
• Any attempt to access information beyond the users authorized access to any electronic information resource;
• Any destruction, defacement, theft, or altering of WSD equipment;
• Any storing or accessing of illegal, inappropriate, or obscene material on WSD owned electronic equipment;
• Excessive non-work related computer use during work hours;

4.  PRIVILEGE

The use of the Internet and computer equipment within WSD is a privilege. The information produced from Internet access or computer use shall be deemed the property of WSD, this is confidential information to the user unless it is transmitted to others with the user’s permission. Violation of this policy can result in the loss of computer access privileges.

5.  MONITORING

WSD reserves the right to monitor and review any material on any machine at anytime in order for the service center to determine any inappropriate use of network services.

6.  DISCLAIMER OF ALL WARRANTIES

WSD makes no warranties of any kind, whether expressed or implied, for the services provided in connection with use of the Internet or any and all computer equipment. Neither WSD nor any supporting Internet services will be responsible for any damages that an computer or Internet user suffers. WSD expressly disclaims any liability in connection with the loss of data resulting from delays, failure to deliver data, mistaken deliveries, viruses, backup device failure, or service interruptions caused by WSD or the Internet provider or by the users error or omissions. Use of any information obtained via the Internet is at the user’s own risk. WSD expressly denies any responsibility for the accuracy or quality of information obtained through any Internet service. All users must consider the source of any information they obtain and evaluate the validity of that information.

7.   SECURITY

WSD will implement security procedures on Internet access to protect against unacceptable use. Employees are responsible for the security of their computer equipment, files and passwords. Employees with access to student records may not use, release, or share these records except as authorized by Federal, State, or Local laws. Employees are responsible for any accounts they may have. Sharing of any usernames or passwords to anyone is not permissible and may result in the loss of account privileges. Employees will be held accountable for any activity under their user account. Any security violations by employees must be reported to Technology Specialist and Director.

8.   ENCOUNTER OF CONTROVERSIAL MATERIAL

Internet users may encounter material that is controversial which the user or administrator may consider inappropriate or offensive. WSD has taken precautions to restrict access to inappropriate materials through a filtering and monitoring system. However, it is impossible on a global Internet, to control access to all data which a user may discover. It is the user’s responsibility not to initiate access to such material. Any site or material that is deemed controversial should be reported immediately to the appropriate administrator. WSD expressly disclaims any obligation to discover all violations of inappropriate internet access.

9.   TERMS OF USE

a.     Only registered employees of WSD and Board of Directors members qualify for Internet access under this policy.

b.     Only the authorized users who have signed the user agreement shall have computer access. Users are ultimately responsible for all activity while using the Internet and all computer equipment.

c.      All Internet or computer equipment access by an employee or Board member is automatically terminated upon retirement, resignation, or termination of employment.

d.     All student computer use must be supervised. Employees who supervise students with access to computer equipment must be familiar with the district's Student Computer Acceptable Use Policy and be willing to enforce it. Employees must appropriately secure rooms and areas where school computer equipment is housed.

10.  PENALTIES FOR IMPROPER USE

Any violation of this policy or applicable state and federal laws may result in disciplinary action (including the possibility of termination) and/or referral to legal authorities. The Technology Specialist may limit, suspend, or revoke access to electronic resources at any time.

WSD INTERNET USER AGREEMENT

I understand and will abide by the WSD Employee Computer Acceptable Use Policy. I further understand that any violations of the above Computer Acceptable Use Policy, when using WSD electronic information resources, may result in the loss of my access privileges and/or other disciplinary or legal action. This action may include, but not limited to, suspension, probation, or termination of employment. I, therefore, agree to maintain professional standards and to report any misuse of the electronic information resources to the Technology Specialist or Director.

_________________________________________

^{Employee Name (Please Print)}

____________________________________

^{Employee Signature and Date}

1. Governing Principles

Wayne School District (referred to as the LEA throughout) takes its responsibility toward student data seriously. This governance plan incorporates the following Generally Accepted Information Principles (GAIP):

• Risk: There is risk associated with data and content. The risk must be formally recognized, either as a liability or through incurring costs to manage and reduce the inherent risk.
• Due Diligence:If a risk is known, it must be reported. If a risk is possible, it must be confirmed.
• Audit:The accuracy of data and content is subject to periodic audit by an independent body.
• Accountability:An organization must identify parties which are ultimately responsible for data and content assets.
• Liability: The risks in information means there is a financial liability inherent in all data or content that is based on regulatory and ethical misuse or mismanagement.

2. Data Maintenance and Protection Policy

The LEA recognizes that there is risk and liability in maintaining student data and other education-related data and will incorporate reasonable data industry best practices to mitigate this risk. 

2.1 Process

In accordance with R277-487, the LEA shall do the following:

• Designate an individual as an Information Security Officer
• Adopt the CIS Controls or comparable
• Report to the USBE by October 1 each year regarding the status of the adoption of the CIS controls or comparable and future plans for improvement.

3. Roles and Responsibilities Policy

The LEA acknowledges the need to identify parties who are ultimately responsible and accountable for data and content assets. These individuals and their responsibilities are as follows:

3.1 Data Manager roles and responsibilities

• authorize and manage the sharing, outside of the student data manager's education entity, of personally identifiable student data for the education entity as described in this section
• provide for necessary technical assistance, training, and support
• act as the primary local point of contact for the state student data officer
• ensure that the following notices are available to parents: 
  • annual FERPA notice (see 34 CFR 99.7), 
  • directory information policy (see 34 CFR 99.37),
  • survey policy and notice (see 20 USC 1232hand 53E-9-203), 
  • data collection notice (see 53E-9-305)

3.2 Information Security Officer

• Oversee adoption of the CIS controls
• Provide for necessary technical assistance, training, and support as it relates to IT security

4. Training and Support Policy

The LEA recognizes that training and supporting educators and staff regarding federal and state data privacy laws is a necessary control to ensure legal compliance. 

4.1 Procedure

• The data manager will ensure that educators who have access to student records will receive an annual training on confidentiality of student data to all employees with access to student data. The content of this training will be based on the Data Sharing Policy. 
• By October 1 each year, the data manager will report to USBE the completion status of the annual confidentiality training and provide a copy of the training materials used.
• The data manager shall keep a list of all employees who are authorized to access student education records after having completed a training that meets the requirements of 53E-9-204.
  • In person training will be provided annually prior to the beginning of each school year. All individuals with access to student education records will be required to attend. Training will be provided by Information Security Officer.

5. Audit Policy

In accordance with the risk management priorities of the LEA, the LEA will conduct an audit of: 

• The effectiveness of the controls used to follow this data governance plan; and
• Third-party contractors, as permitted by the contract described in 53E-9-309(2).

6. Data Sharing Policy

There is a risk of redisclosure whenever student data are shared. The LEA shall follow appropriate controls to mitigate the risk of redisclosure and to ensure compliance with federal and state law.

6.1 Procedure

• The data manager shall approve all data sharing or designate other individuals who have been trained on compliance requirements with FERPA.
• Utah DPA as listed on the website will be the main source of vendor approval. It lists those who are approved, denied, or in the process of being vetted.
• Teachers can only release student information after the approval process has been completed and the vendor is listed on the Utah DPA website.
  • Teachers and Staff will submit the website/app to their Administrator
  • If it is approved by their Administrator, then it will be submitted to the Student Data Security Manager (SDSM)
  • The SDSM will check with the Utah Student Privacy Alliance to see if an agreement is already in place with the website/app and another district in the state.
  • If an agreement is already in place, Wayne School District will add their name to the agreement
  • If no agreement is in place with another district, the SDSM will go through the privacy policy and terms of service of each submitted website/app
  • The SDSM will also view all security protocols listed for the website, including login security
  • If the website is secure, the SDSM will then send the company a personalized Contract for signature
  • When the Contract is signed and returned to the SDSM, the website/app will be added to the approved list
• For external research, the data manager shall ensure that the study follows the requirements of FERPA’s study exception described in 34 CFR 99.31(a)(6).
• After sharing from student records, the data manager shall ensure that an entry is made in the LEA Metadata Dictionary to record that the exchange happened.
• After sharing from student records, the data manager shall make a note in the student record of the exchange in accordance with 34 CFR 99.32.

7. Expungement Request Policy

The LEA recognizes the risk associated with data following a student year after year that could be used to mistreat the student. The LEA shall review all requests for records expungement from parents and make a determination based on the following procedure.

7.1 Procedure

The following records may not be expunged: grades, transcripts, a record of the student’s enrollment, assessment information.

The procedure for expungement shall match the record amendment procedure found in 34 CFR 99, Subpart C of FERPA.

• If a parent believes that a record is misleading, inaccurate, or in violation of the student’s privacy, they may request that the record be expunged.
• The LEA shall decide whether to expunge the data within a reasonable time after the request.
• If the LEA decides not to expunge the record, they will inform the parent of their decision as well as the right to an appeal hearing.
• The LEA shall hold the hearing within a reasonable time after receiving the request for a hearing.
• The LEA shall provide the parent notice of the date, time, and place in advance of the hearing.
• The hearing shall be conducted by any individual that does not have a direct interest in the outcome of the hearing.
• The LEA shall give the parent a full and fair opportunity to present relevant evidence. At the parents’ expense and choice, they may be represented by an individual of their choice, including an attorney.
• The LEA shall make its decision in writing within a reasonable time following the hearing.
• The decision must be based exclusively on evidence presented at the hearing and include a summary of the evidence and reasons for the decision.
• If the decision is to expunge the record, the LEA will seal it or make it otherwise unavailable to other staff and educators.

8. Data Breach Response Policy

The LEA shall follow industry best practices to protect information and data. In the event of a data breach or inadvertent disclosure of personally identifiable information, the LEA staff shall follow industry best practices for responding to the breach.

8.1 Procedures 

• The superintendent will work with the information security officer to designate individuals to be members of the cyber incident response team (CIRT)
• At the beginning of an investigation, the information security officer will begin tracking the incident and log all information and evidence related to the investigation.
• The information security officer will call the CIRT into action once there is reasonable evidence that an incident or breach has occurred.
• The information security officer will coordinate with other IT staff to determine the root cause of the breach and close the breach.
• The CIRT will coordinate with legal counsel to determine if the incident is meets the legal definition of a significant breach as defined in R277-487and determine which entities and individuals need to be notified. 
• If law enforcement is notified and begins an investigation, the CIRT will consult with them before notifying parents or the public so as to not interfere with the law enforcement investigation.

9. Publication Policy

The LEA recognizes the importance of transparency and will post this policy on the LEA website.