Standards for Technologies Prohibited by Regulation

Purpose

This standard establishes (1) a non-exhaustive record of technologies and technology service providers from which the college is prohibited from using and/or acquiring and (2) a non-confidential explanation of technical and administrative controls implemented in the furtherance of related compliance goals. Prohibitions highlighted in this standard correspond to state and federal laws, directives, executive orders, and other regulatory requirements applicable to the college. The absence of an otherwise prohibited item from this Standard does not imply a means by which the item is authorized.

The contents of this standard are additive overlays that incorporate, detail, and extend requirements set by the TSUS Information Technology Policies, institutional policies, other institutional standards, procedures, and guidelines, and additional prohibitions, such as the “Debarred Vendor List” maintained by the Texas Comptroller of Public Accounts.

Pursuant to section 552.139 of Texas Government Code (“Public Information”), some descriptions of technical security controls, procedures, and practices will be abbreviated to avoid disclosure of confidential information pertaining to the security posture of the college’s information resources.

Scope

This standard generally applies to all college-owned information systems, devices, networks, and other information resources that are within the custodianship of the college regardless of location. As detailed within, certain sections of this standard may also be applicable to college personnel (e.g., college officers, employees, contractors), locations (e.g., campuses, properties), and personally owned devices (e.g., those used to conduct state or college business).

Summary

This section provides an overview of the requirements of this standard. This summary is provided for reference purposes and does not take the place of the full text below.

  • All college employees are prohibited from downloading or using TikTok on any college device or other information resource. Similarly, the installation or use of TikTok on any college owned device or other information source is prohibited by any user. Exceptions to this prohibition may only be granted by the college’s president.

Publication and Updates

This standard was first published on 12/9/2022. This section will be updated when any updates or changes are made to this standard.

Definitions

Terms used in this standard have the meaning ascribed in the Information Security Glossary unless otherwise clarified in this section.

DIR. Initialism for the Texas Department of Information Resources

DPS. Initialism for the Texas Department of Public Safety

Institutional User. A privileged or non-privileged user of an information system who holds an active affiliation (e.g., faculty, staff, student) with LSCO.

ISO. Initialism for LSCO’s “Information Security Office”

Logical Device. Logical equivalents of Devices, such as virtual Servers and virtualized versions of Networks

Non-privileged User. See “User"

OOG. Initialism for the Texas Office of the Governor

Organizational User. See “Institutional User”

Exceptions to this Standard

The feasibility of exceptions to this standard and processes by which such exceptions may be facilitated will be detailed within the body of this document. Unlike certain security controls, policies, standards, and other requirements of the college, the regulatory nature of the prohibitions described by this standard significantly limit or prevent exceptions from being granted by the college’s agency head, information security officer, individual department heads, or other college personnel.

Appropriate Use of Information Resources

Users of college information resources are subject to the requirements set by college policy, including Information Resources Policy 7.1 Information Resources – Appropriate Use. Requirements set by this policy include, but are not limited to, the following summary:

  • 1 Information resources are provided for the purpose of accomplishing tasks related to the college’s mission. The college may restrict or limit the use of or access to its information resources in keeping with the Lamar State College Orange mission,
  • 4 Subject to State of Texas law and college policy, incidental personal use of information resources by college employees is tolerated, subject to review and restriction by the employee’s supervisor. Such personal use must not violate any applicable policies and statutes, must not interfere with the employee’s job performance, must not result in any additional expense to the college, and must not be used for personal gain. Information technology resources should not be used in an extensive or regularly recurring manner for activities that are unrelated to institutional purposes.
  • 5 Any unauthorized or illegal access, use, alteration, duplication, destruction, or disclosure of any information resource is prohibited.

Prohibition of TikTok [12/7/22 Texas OOG Executive Order]

This prohibition stems from an OOG executive order issued on 12/7/22. As stated in the letter sent to state agency heads,

“…effective immediately, every state agency in Texas shall ban its officers and employees from downloading or using TikTok on any of its government-issued devices. This TikTok ban extends to all state- issued cell phones, laptops, tablets, desktop computers, and other devices capable of internet connectivity, and it must be strictly enforced by your agency’s IT department.”

For further information, see the following pages:

https://gov.texas.gov/news/post/governor-abbott-orders-aggressive-action-against-tiktok

https://gov.texas.gov/uploads/files/press/State_Agencies_Letter_1.pdf

Effective 12/7/22, all college employees are prohibited from downloading or using TikTok on any college-owned or college-issued devices and other college information resources. Further, the installation or use of TikTok on college-owned or college-issued devices and other college information resources by any user, including contractors, students, sponsored student organizations, and non-affiliates, is prohibited.

Pursuant to the executive order, exceptions to this prohibition may be made with authorization from the college’s president as the designated state agency head. As stated in the letter sent to state agency heads,

“As head of your agency, you may grant exceptions to enable law- enforcement investigations and other legitimate uses of TikTok on state-issued devices. This authority may not be delegated. These narrow exceptions must be reported to the Office of the Governor (OOG).”

As of 12/9/2022, the following scenarios have been approved by the college president:

  1. Cybersecurity incident investigations
  2. Dean of Students investigations
  3. Title IX investigations
  4. Legal Discovery
  5. Temporary maintenance of dormant, high value TikTok handles to reduce risk of impersonation

In response to this prohibition of the use of the TikTok social media service on college- owned devices, a series of technical controls will be used. Technical controls include, but may not be limited to, the following:

  • Blocking the use of TikTok software and access to TikTok services on college- managed endpoints via technology-based controls
  • Blocking access to TikTok from all parts of the college network
  • Measures that have or will be taken include, but may not be limited to, the following:
  • Issuance of this standard
  • Removal of content on college webpages referencing and/or linking to TikTok other than those used to communicate and facilitate compliance with the order such as this standard
  • Reviews of institutional procurement activity to assess direct spending with TikTok
  • Identification and neutralization of TikTok accounts controlled by the college and external parties on behalf of the college
  • Communication to multiple stakeholder groups
  • Establishing and appropriately reporting exceptions authorized by the college president

Prior to the 12/7/22 executive order, parts of the college used TikTok as a component of social media strategies. In order to mitigate the likelihood of username reclamation and subsequent impersonation by threat actors, the following procedures are to be implemented by the respective information resource owner and information resource custodian of college-managed TikTok accounts:

  1. Archive copies of content posted to the account and store the archived copies in an authorized location (e.g., college fileshare, SharePoint) in compliance with the records retention schedule
  2. Remove all content from each account
  3. De-brand each account by removing all institutional logos, contact information, and similar details
  4. Leave the account active and maintain it under LSCO control
  5. Remove any remaining instances of TikTok applications from college-owned devices
  6. Confirm the account has been registered with the Information Security department and do not use it further

Additional procedures may include temporarily logging on to the account from an authorized source to prevent deactivation of the account and loss of the account’s reserved username after a period of approximately 170 days of inactivity. These procedures may be activated based on several factors, including risk analysis, shifts in the threat landscape, and the status of authorized exceptions.

Next Steps