Information security, compliance and the grant life cycle. October 10, 2013
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1 Information security, compliance and the grant life cycle October 10, 2013
2 Presenters Beth Chancellor, Chief Information Security Officer, Division of IT Jeremy Cox, Lead Accountant, Office of Sponsored Programs Administration Jennifer Duncan, Director, Office of Sponsored Programs Administration Jennifer May, Director of Research Compliance Services, Office of Research Michelle Wisdom, IT Compliance Officer & Health ISO, Division of IT
3 The Grant Lifecycle Pre-submission External and Internal Influences Planning & Submission Post Award / Operational Compliance Close Out Importance of consolidated resources
4 External Influences - Standards, Laws and Regulations Presubmission External Export Control Federal Information Security Management Act (FISMA) Considerations Nat l Institute of Standards & Technology (NIST) FDA 21 CFR Part 11 (electronic records & electronic signatures) Office of Management & Budget (OMB) Circular A-130 (information resource management) International Traffic in Arms Regulations Federal Acquisition Regulation (FAR) & Defense Federal Acquisition Regulation Supplement (DFARS) Health Insurance Portability and Accountability Act (HIPAA) Research Classification Family Educational Rights and Privacy Act (FERPA)
5 Highlight on DFARS Defense Federal Acquisition Regulation Supplement Example Clauses that impact data use and security DFAR (Dec 1991) DFAR (Aug 2013) Proposed Rule that could impact data use and security Safeguarding Unclassified DoD Information (DFARS Case 2011-D039)
6 Internal Influences Policies, Programs and PI Self-categorization Presubmission -Internal Management, Access and Use policy (BPM1201) Info Sec policy (BPM1203) Information Security Program Data classification Requirement to report IT Procurement policy (BPM1204) Considerations What s the value of research data and information? Data integrity IP Tech transfer Your life s work How should it be protected regardless of formal classification?
7 UNC Mammography Registry Breach
8 Higher Ed Data Breaches Continue to Rise
9 Planning & Submission Think ahead to the end If there happens to be an audit, can you show adequate documentation for: Pre-award activities Financial activities Security measures Communication/delegation to sub-recipients Data Use and Reporting
10 Planning & Submission What regulations, laws, policies, procedures apply to your work? How do you ensure that you can meet the requirements pre-submission? What IT resources are planned for ahead of time? Storage, Collaboration tools, sharing/file transfers, access control technologies, outsourced services such as cloud-based tools
11 Planning & Submission Do you ever have to certify that information/data is secure? Already seeing an increase and likely to see more Signature required by a security official Do you ever have to submit security plans to the sponsor? Technology controls General workplace security (
12 Adobe cloud service breached
13 Evernote cloud service breached
14 Post Award and Operational Compliance Who manages the infrastructure and/or the services? Data steward / data custodian, these are separate roles Do they know their responsibilities? Are they qualified? What terms & conditions are in place with outsourced providers? What has been agreed to from an information security perspective? Potential effects of non-compliance
15 Grant Close Out Reporting/Publishing Archival If it s worth archiving, it s worth securing Return of data Disposal
16 What does all of this mean? Myriad of compliance hurdles to address, plus A host of security implications Data stewards / Data custodians Data storage / Data encryption Secure file sharing / transmission Access Control technologies Archival and Disposal
17 How can we help? Plan ahead and engage early How can we help? Ask for expert help and advice Look ahead for potential audit issues Engage OSPA in audit requests Leverage the Compliance Office The DoIT security team can provide templates for security plans ISOs should and can sign security certifications Seek approval from an ISO to use outsourced technology services
18 How can you help? All of our eggs in one basket! Scalability Security standards Highly trained security and technical staff Management & administration Encryption Access control technologies and standard processes Documentation Support the efforts of the CIC!!!
19 Policies & Resources Information Security & Access Management Team Office of Sponsored Programs Administration Research Compliance Office Institutional Review Board (IRB) IT Management, Access and Use policy BPM1201 IT Security policy BPM 1203 IT Procurement policy BPM1204 Information Security Program Data Classification System
20 Contacts Information Security Officers Beth Chancellor, Chief Information Security Officer Brandon Hough, Information Security Officer Michelle Wisdom, IT Compliance Officer/Health ISO
Using Technology Control Plans in Export Compliance. Mary Beran, Georgia Tech David Brady, Virginia Tech
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