Information security at èAV
Last revised: June 6, 2022
1. Service Overview
As a provider of technology solutions to schools, èAV’s commitment to data privacy and security is essential to our organization. This overview of èAV’s Information Security Program describes physical, technical and administrative safeguards èAV implements to protect student data in our care.
Company profile
èAV. (èAV) is a privately held company founded in 2000 as Wireless Generation. èAV’s products include curriculum and instruction, assessment and intervention, professional development services and consulting services for K-12 education.
Service hosting
èAV leverages Amazon Web Services (AWS) as its cloud hosting provider. Within AWS, èAV utilizes Virtual Private Clouds (VPCs), which provide an isolated cloud environment within the AWS infrastructure. External network traffic to a VPC is managed via gateway and firewall rules, which are maintained in source code control to ensure that the configuration remains in compliance with èAV security policy. In addition, the production VPCs and the development VPCs are isolated from each other and maintained in separate AWS accounts.
2. Policies & standards
Information security program
èAV maintains a comprehensive information security program based on the National Institute of Standards and Technology (NIST) Cybersecurity Framework and the NIST SP 800-53 Rev. 5 family of information security controls. These provide a robust framework of best practices from which an organization can build its security policies and protocols based on identified risks, compliance requirements, and business needs. They cover critical practice areas, including access control, configuration management, incident response, security training, and other information security domains.
Governance
èAV’s Information Security Committee has primary responsibility for the development, maintenance, and implementation of the èAV information security program. The Information Security Committee is responsible for all information risk management activities within the company and is composed of technology, business and legal leaders from the organization. The Committee meets weekly and includes a dedicated VP of Information Security and a program manager to oversee, direct and coordinate its activities.
Policy execution
Adherence to the internal èAV information security policy is an obligation of every èAV employee. èAV conducts a series of internal monitoring procedures to verify compliance with internal information security policies, and all èAV employees undergo annual criminal background checks. In addition, any third-party contractors who come into contact with systems that may contain student data are contractually bound to maintain security and privacy of the data.
3. Data access controls
Access control
èAV’s access control principles dictate that all student data we store on behalf of customers is only accessible to district-authorized users and to a limited set of internal èAV users who may only access the data for purposes authorized by the district. Districts maintain control over their internal users and may grant or revoke access.
In limited circumstances and strictly for the purposes of supporting school districts and maintaining the functionality of systems, certain èAV users may access èAV systems with student data. All such access to student data by èAV technicians or customer support requires both authentication and authorization to view the information.
Encryption
Data encryption is an important element of our protection of sensitive data at rest and in transit, and is reviewed and updated as appropriate annually, based on the latest standards and guidelines published by OWASP and NIST.
- In transit: èAV encrypts all student data in transit over public connections, using Transport Layer Security (TLS), commonly known as SSL, using industry-standard protocols, ciphers, algorithms, and key sizes.
- At rest: èAV encrypts student data at rest using the industry-standard AES-256 encryption algorithm.
4. Application security by design
Building the right roles into applications
Permissions within èAV applications are designed on the principle that school districts control access to all student data. To facilitate this, èAV applications are designed so that roles and permissions flow from the district to the individual user. For example, applications that offer schools a way to collect and report on assessment results have a web interface that requires district administrators to authorize individuals to view student data.
Security controls within applications are used to ensure that the desired privacy protections are technically enforced within the system. For example, if a principal is supposed to see only the data related to his or her school, èAV ensures that, throughout the design and development process, our products restrict principals from seeing records for any students outside his or her school.
To make sure èAV applications properly enforce permissions and roles, our development teams conduct reviews early in the design process to ensure roles and permissions are an essential component of the design of new applications.
Building security controls into applications
èAV applications are also developed to minimize security vulnerabilities and ensure industry-standard application security controls are in place.
As part of the development process, èAV has a set of application security standards that all applications handling student data are required to follow, including:
- Student data is secured using industry standard encryption when in transit between end-users and èAV systems.
- Applications are built with password brute-force attack prevention.
- User sessions expire after a fixed period of time.
We also conduct manual and automated static code analysis as well as dynamic application security testing to preemptively identify vulnerabilities published by industry leaders such as OWASP (Open Web Application Security Project)
5. Proactive security
Risk assessments
èAV periodically engages a security consulting firm to conduct risk assessments, aimed at identifying and prioritizing security vulnerabilities. The Information Security Committee coordinates remediation of the vulnerabilities. The security consulting firm also provides ongoing advice on current risks and advises on remediation of vulnerabilities and incident response.
Penetration testing
èAV engages third-party firms to continually conduct application penetration testing. The purpose of this testing is to test for application security vulnerabilities in the production environment. We work with third party penetration testing program partners. Third-party testing involves a combination of automated and manual testing.
Vulnerability management
èAV ensures that its systems are free of known vulnerabilities in several ways. Every production server runs vulnerability detection software that compares the installed software against a global database of known vulnerabilities. Secondly, we employ real time network monitoring that reports on any potentially malicious traffic. In addition, a third-party security firm continually reviews all of our system logs for potential security breaches. Lastly we continually test our applications against common malicious internet traffic. Violations in any of these areas will alert one of our operations teams, who are available around the clock.
In addition, èAV participates in a private bug bounty program through HackerOne, working with the security community to find security vulnerabilities and support our efforts to keep our data and systems safe and secure.
Endpoint security
Access to production systems at èAV is restricted to a limited set of internal èAV users to support technical infrastructure, troubleshoot customer issues, or other purposes authorized by the district. In addition, èAV requires multi-factor (MFA) authentication methods for access to all production systems. MFA involves a combination of something only the user knows and something only the user can access. For example, MFA for administrative access could involve entering a password as well as entering a one-time passcode sent via text message to the administrator’s mobile phone. The use of MFA reduces the possibility that an unauthorized individual could use a compromised password to access a system.
Infrastructure security
Network filtering technologies are used to ensure that production environments with student data are properly segmented from the rest of the network. Production environments only have limited external access to enable customers to use our web interfaces and other services. In addition, èAV uses firewalls to ensure that development servers have no access to production environments.
Other measures that èAV takes to secure its operational environment include system monitoring to detect anomalous activity that could indicate potential attacks and breaches.
Security training
At èAV, we believe that protecting student data is the responsibility of all employees. We implemented a comprehensive information security awareness training program that all employees undergo upon initial hire, with an annual refresher training. We also provide information security training and annual social engineering tests for specific departments based on role.
6. Reactive security
Monitoring
Intrusion detection and prevention systems (IDS/IPS) are in place to analyze the network device logs, monitor the network and report anomalous activity for appropriate resolution.
Incident response
èAV maintains a comprehensive Security Incident Response Policy Plan, which sets out roles, responsibilities and procedures for reporting, investigation, containment, remediation and notification of security incidents. èAV works with reputable firms for incident response and digital forensics support, as well as annual table-top exercises in coordination with cybersecurity experts.
Business Continuity Planning and Disaster Recovery
èAV maintains a comprehensive Business Continuity Planning and Disaster Recovery Plan (BCP/DR), to guide personnel in procedures to protect against business disruptions caused by an unexpected event. The plans and related operations processes are tested on a semiannual basis, with ensuing operations improvement and remediation work.
7. Compliance
Audits
In addition to penetration testing and other proactive security testing and monitoring outlined above, èAV undergoes annual SOC 2 Type 2 examinations of controls relevant to security. The examination is formally known as a Type 2 Independent Service Auditor’s Report on Controls Relevant to Security. The most recent examinations were conducted by Schellman & Company, LLC and covers the period from April 1, 2023–March 31, 2024 for èAV, and October 1, 2023–March 31, 2024 for Desmos Platform. The report states that èAV’s systems meet the criteria for the security principle and opine on management’s description of the organization’s system and the suitability of the design of controls to protect against unauthorized access, use, or modification.
The Type 2 report also opines on the operating effectiveness of controls over the review period. This means that our auditors confirmed that we have continued to follow established security controls over the period of time of the review.
Certifications
SOC 2: èAV successfully completed the SOC 2 Type 2 examination of controls relevant to security (see above, under “Audits”).
Privacy
èAV’s products are built to facilitate district compliance with applicable data privacy laws, including FERPA and state laws related to the collection, access and review and disclosure of student data. èAV’s describes the types of information collected and maintained on behalf of our school district customers and limitations on use and sharing of that data. èAV is also an early adopter and proud signatory of the , an industry-wide pledge to safeguard privacy and security of student data.
8. Supporting documentation
In the course of customer security assessment, the following documentation can be provided by èAV upon customers’ request:
- Penetration Testing Report
- Risk Assessment Report
- SOC 2 Type 2 Report
9. Report a vulnerability
To report a security vulnerability, click here.