Tools and Services

Application and Cloud Services Assessment Process

Third party vendor applications and cloud services can present significant risk to the University. To mitigate the risk, the Risk and Compliance (RAC) team reviews the security of vendor organizations for server applications facing the internet, or services provided by a vendor that will have access to university confidential, or highly confidential data (including HIPAA, FERPA, and PCI data). This process is essential in minimizing legal issues during the negotiation of the IT Security language during the contract process.

Third party vendors are now subject to the same Security Rule requirements as Covered Entities, and are also subject to relevant sections of the Privacy Rule and the HITECH Breach Notification Rule. In order to protect university confidential and highly confidential data, including PHI, the risk and compliance team assesses the security and practices of all third party vendor server applications and cloud services. Third party vendor applications include those that process, transmit or store PCI (Payment Card Industry) data.

Third party vendors must:

• Prevent the loss, theft, unauthorized access and/or disclosure of university data
• Destroy data when no longer needed per university data owner instructions
• Have incident response procedures and reporting requirements in case of a breach

Timeline: Please note, we complete requests in the order we receive them and timelines are dependent on the responsiveness of the requestor, vendor, and the complexity of the agreement.

Risk and Compliance Process

1. Go to the Requestor Questionnaire. (Form works best in Chrome and Firefox)  *Additional steps may be needed. See other team information below.
2. Vendor Interaction - RAC team sends out vendor questionnaire and reviews to determine next steps.
3. RAC team provides assessment results to the requestor.
4. If approved, RAC sends approval email to the requestor and all interested parties. (PSC, ORC, and Data Integration contact).
5. Contract Negotiations and Language - The RAC team works with the PSC to negotiate the IT Security language for the contract. 
6. Exceptions to this process is the Security Risk Acceptance signed by Data Owner.
   
   

Other University Teams to Contact for Process

• Procurement Service Center (PSC) - The team that will assist you with your purchase.
• Data Integration Requests - If your request will include the integration of your software with CU System to retrieve university data, enter a data integration request as soon as possible.
• Office of Regulatory Compliance (ORC) - If your request involves HIPAA data, the Office of Regulatory Compliance will be asked by the PSC to prepare a BAA for both parties to sign.

Resources

• University Data Classification
• University Adverse Impact Level
• IT Security Program APS-6005
• University HIPAA Policy
• FERPA - Student Data Use Guidelines
• PCI