Technology Risk Assessment 

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. More information is available on the Technology Risk Assessment Process webpage. 

Risk and Compliance (RAC) Process

1. Gather and compile product and vendor information.
2. Complete the Technology Risk Assessment form.
3. Have availability on your Outlook Calendar.
4. Ensure your department IT support representative is aware of the request.
5. Attend the scheduled intake interview. 
6. Inform the vendor the RAC team will be reaching out.
7. Collaborate with RAC to prompt the vendor to answer the Security and Accessibility Questionnaire.
8. Identify someone within your department who can sign an NDA, if requested.
9. Respond to questions promptly.
10. Ensure the vendor answers any follow-up questions.
11. Read the best practices outlined by RAC.
12. Attach the Close Out email to your requisition in Marketplace.
13. Inform the vendor the assessment is completed.
14. Respond to the 90-Day Assessment annual reminder. 
15. Submit the Renewal Requisition in Marketplace.

In addition, the process also includes working with our vendor to ensure that technology procured by the university are inclusive and accessible. The RAC process will now collect a Voluntary Product Accessibility Template (VPAT) and accessibility questionnaire from the vendor to produce a digital accessibility risk assessment. This digital accessibility risk assessment will provide insight on the technology's digital accessibility level of compliance and will be sent back to the original requestor. For recommended steps following the risk assessment, please reference steps 2 and 3 in our CU Anschutz Procuring Accessible IT guide.

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

• In-depth Technology Risk Assessment Process
• University Data Classification
• University Adverse Impact Level
• IT Security Program APS-6005
• University HIPAA Policy
• FERPA - Student Data Use Guidelines
• PCI
• Approved University Applications
• Vendor Requirements 
• CU Digital Accessibility Vendor Procurement
• Colorado Accessibility Law 
• CU Anschutz Digital Accessibility 
• Digital Accessibility and Colorado Law HB21-1110