This article provides an overview of Skill Struck's cybersecurity policy, including security features, data privacy details, and more.
Overview
Skill Struck’s mission of promoting equity in computer science education relies on the security and efficiency of our systems. We want our partner schools and their administrators, teachers, and students to know that Skill Struck is a trustworthy guardian of sensitive data.
This document details our information and cyber security program. Principles of an effective security program include being threat-driven, using automation to scale, and balancing the investment between prevention and response. We regularly adjust our security practices to align with the NIST Cybersecurity Framework.
Our program has three focus areas: product security, infrastructure security, and IT security. The following sections describe each focus area and the set of security activities we practice within each.
Product security
The goal of Skill Struck’s product security efforts is to clarify the security and privacy impact of new features as they are being created to let Skill Struck engineering continuously improve the Skill Struck product safely.
Secure Software Development Lifecycle
We have an application security review process that applies to all new development projects. It includes threat modeling and code review. Security design reviews occur for any major change. We have a secure code review process that identifies high-risk code for manual review by our software engineers. We use automation in our software development build pipeline that analyzes code for potential vulnerabilities through unit tests.
Our engineer portal includes application security training material with secure coding guidelines specific to our technology stack, which all new engineering hires review.
We have an active bug-finding program that includes a team reviewing the Skill Struck platform daily to ensure that all reported bugs are fixed in a timely manner. We’re responsive to security inquiries sent to support@skillstruck.com.
Security Features
Skill Struck does not give log file information or student usage information to third parties, except (i) those service providers engaged to support and assist in administering Skill Struck’s Site, or (ii) in a sanitized form disassociated from IP address or other personal data, or (iii) as authorized or directed by the school. Skill Struck stores, transmits, and displays student data only via secure and FERPA-compliant methods. Only selected members of the Skill Struck staff have access to student data, and are required to be FERPA certified and must log in to the platform using 2-factor authentication.
Skill Struck protects against password brute forcing by rate-limiting login attempts. After 5 failed login attempts, then the following guesses require ReCAPTCHA each time. Skill Struck salts and hashes passwords using SHA256, a high-cost hashing function recommended by NIST. Skill Struck requires two-factor authentication for administrator, teacher, and student account access.
We use Content Security Policy (CSP) to detect and prevent unauthorized Javascript from running in the context of our applications.
Infrastructure security
Our infrastructure security efforts focus on accelerating the pace of our development teams by providing the underlying tools, systems, processes, and knowledge resources to build secure and privacy-protecting systems.
All of Skill Struck’s infrastructure runs in the cloud. Our primary cloud provider, AWS, conforms to security standards including PCI-DSS, HIPAA/HITECH, FedRAMP, GDPR, FIPS 140-2, and NIST 800-171. See https://aws.amazon.com/compliance/ for more details.
Change Management
We have a change management process for our infrastructure that includes source code control, peer code review, logging, and alerts for unusual behavior. All production changes are deployed with an automated system that detects reliability issues and reverts problematic deploys. Our automation allows us to safely and reliably deploy code to production dozens of times per day.
Availability and Disaster Recovery
Our availability is 99.9% or higher.
We have established a set of practices and tools to defend against automated Denial of Service (DoS) attacks against Skill Struck’s infrastructure. Skill Struck uses Cloudfront to defend against these attacks.
Since our service is based entirely in the cloud, our disaster recovery plan is based on best practices from AWS for maintaining resiliency in the case of disaster. We use multiple AWS availability zones to safeguard against single data-center issues.
Skill Struck generates data backups regularly and stores them securely with our cloud provider. All backups stored offsite are encrypted and deleted securely when they become obsolete - in no case longer than 60 days. Skill Struck’s production systems are housed in a tier-1 hosting facility that is monitored 24 hours a day, 7 days a week. Access to these systems requires prior written approval from Skill Struck management and all access is logged and monitored. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Skill Struck cannot guarantee its absolute security.
Data Encryption in Storage and Transit
We encrypt all Personally Identifiable Information (PII) in transit outside of our private network and at rest in our private network. All data is encrypted via SSL in transit and by rest by Amazon Web Services. We use industry-standard cryptography (AES-256) and access control keys that are regularly audited and rotated. Read more about our security encryption with AWS by referring to their Encryption Reference Guide.
Data Isolation
Skill Struck uses logical separation to process data in a multi-tenant environment. The code controls are tested before every production deployment. Data processing occurs in containerized environments with limited access to external resources. Services use ephemeral credentials for services to access data stores. All data is stored in the USA.
Network Isolation
Skill Struck limits external access to network services by running them inside of a Virtual Private Cloud (VPC) and blocking all unnecessary ports from external traffic. Access to our production network is limited to necessary personnel, logged, and secured using multiple-factor authentication. We use a bastion SSH host to gate all system-level access to production infrastructure.
Logging
Skill Struck maintains a centralized log for product and infrastructure events and metrics. Tightly access-controlled and integrity protected log backups are persisted to access-controlled archival stores on S3. All system-level actions performed in production environments with elevated permissions (sudo) are logged.
Threat Detection
We have monitoring, alerting, and response processes for suspicious activity occurring in our infrastructure.
Secret Storage
No secret data (passphrases, API keys, QR Codes for 2-factor, etc) are sent using tools like Gmail, Dropbox or Slack. We have purpose-built tools for storing and transferring this data in accordance with our security requirements.
Patching
We regularly update our operating systems images, container images, language runtimes, and language libraries to the latest known supported versions.
IT security
Policies and Standards
Our information security policy is documented in our Employee Portal. We have a Skill Struck Data Classification standard that describes the different types of data that our employees work with and how that data should be handled.
Device Policies
Our device policy describes best practices for device configuration and software usage for Skill Struck devices. It mandates full disk encryption for all devices that have access to sensitive data, the use of screen locks after a period of inactivity, and remote wipe capabilities. It also describes our permitted software and software update practices.
Account Policies
Our account policies state that all passwords should be securely stored and generated with a password manager, and mandates the use of 2FA for sensitive accounts. It also defines the OAuth authorization policies for accounts with sensitive data access (e.g. GSuite) and the techniques to avoid phishing.
Accounts are activated when an employee joins and deactivated when an employee leaves, using automated processes where possible.
Security Training
We create a culture of security for all Skill Struck employees through activities like security awareness training, which is completed during onboarding. Our security program that details each of these components is documented in our Employee Portal. All new hires must read the information security policy and undergo information security training, and existing employees have regular refresher training.
Third-Party Software
We have a third-party software security review process that must be completed before using new services at our organization on official, company-owned devices. The level of verification varies based on the risk profile of the service in question.
Background Checks
All Skill Struck employees undergo criminal background checks and sign agreements barring any use of confidential information outside of the scope of their work with the company.
Cyber Insurance
We have cyber liability insurance with coverage of 1 million US dollars. We also cater our cyber insurance coverage to specific schools and districts as needed.
Other Security Practices
External Security Assessment
We conduct an annual external security assessment of our applications. We make the reports associated with these assessments available for our users, upon request.
Cyber Incident Management and Response Plan
In the event that Skill Struck management discovers that student data or personal information has been accessed or obtained by an unauthorized individual, Skill Struck shall provide notification to the school’s representatives within a reasonable amount of time of the incident, not to exceed 48 hours. Immediately following the discovery of the breach, Skill Struck’s security team will address and resolve the security deficiency accordingly. Such notification will be provided via email and a phone call to the school’s authorized student data privacy representative, and will include the following:
- The security breach notification shall be written in plain language, shall be titled “Notice of Data Breach for Skill Struck,” and shall present the information described herein under the following headings: “What Happened,” “What Information Was Involved,” “What We Are Doing,” “What You Can Do,” and “For More Information.” Additionally, information may be provided as a supplement to the notice.
- The security breach notification shall include, at a minimum, the following information:
- The name and contact information of the authorized school representative.
- A list of the types of personal information that were or are reasonably believed to have been the subject of a breach.
- If the information is possible to determine at the time the notice is provided, then either (1) the date of the breach, (2) the estimated date of the breach, or (3) the date range within the breach occurred. The notification shall also include the date of the notice.
- Whether the notification was delayed as a result of a law enforcement investigation if that information is possible to determine at the time the notice is provided.
- A general description of the breach incident, if that information is possible to determine at the time the notice is provided.
- At the school’s discretion, the security breach notification may also include any of the following:
- Information about what the agency has done to protect individuals whose information has been breached.
- Advice on steps that the person whose information has been breached may take to protect himself or herself.
- Skill Struck will also adhere to all requirements in applicable state and federal law with respect to a data breach related to the student data, including, when appropriate or required, the required responsibilities and procedures for notification and mitigation of any such data breach.
- Skill Struck will not directly contact the parent, legal guardian, or eligible pupil unless expressly requested by an authorized school representative. If requested by an authorized school representative, the head Skill Struck IT manager will contact the legal guardian of the pupil via email or phone call. If requested by the school, Skill Struck shall reimburse the school for costs incurred to notify parents/families of a breach not originating from the school’s use of our service, upon the school providing proof of those expenses.
- In the event of a breach originating from the school’s own use of our platform, Skill Struck shall cooperate with the school to the extent necessary to expeditiously secure student data.
In addition to following this plan, Skill Struck will address each data security breach on a case-by-case basis, as well as conduct an inspection of its data security measures to improve them, directed by Skill Struck’s security director.
Parents’ Bill of Rights for Data Privacy and Security
Skill Struck is committed to protecting the confidentiality of information about your child that identifies him or her. Such information, which includes student‐specific data, is known as “personally identifiable information.” Under Skill Struck’s Cyber Security and Privacy Policy (aligned with New York state’s education law), if you are a parent of a child in any school district, you have the following rights regarding the privacy and security of your child’s personally identifiable information and data:
- Your child’s personally identifiable information cannot be sold or released for any commercial purposes.
- If your child is under age 18, you have the right to inspect and review the complete contents of your child’s education records.
- Safeguards must be in place to protect your child’s personally identifiable data when it is stored or transferred. These safeguards must meet industry standards and best practices. Examples of such safeguards include encryption, firewalls, and password protection.
- You have the right to make complaints about possible breaches of student data and to have such complaints addressed.