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Overview Identification and Assessment of Risks to Customer Information Information Security Plan Coordinator Design and Implementation of Safeguards Program Selection of Appropriate Service Providers Continuing Evaluation and Adjustment Footnotes |
1
Covered data and information for the purpose of this policy
includes student financial information (defined below) required to
be protected under the Gramm Leach Bliley Act (GLBA). In addition
to this coverage which is required under federal law, North
Central State College chooses as a matter of policy to also
include in this definition any credit card information received in
the course of business by the College, whether or not such credit
card information is covered by GLBA. Covered data and information
includes both paper and electronic records.
Student financial information is that information that North Central State College has obtained from a customer in the process of offering a financial product or service, or such information provided to the College by another financial institution. Offering a financial product or service includes offering student loans to students, receiving income tax information from a student's parent when offering a financial aid package, and other miscellaneous financial services. Examples of student financial information include addresses, phone numbers, bank and credit card account numbers, income and credit histories and Social Security numbers, in both paper and electronic format. 2 The College Information Committee consists of the Vice-President – Business Services, Executive Director – Information Technology, Director – Human Resources and Dean of Student Services. Back to Information Security Plan Coordinator 3 "Pretext calling" occurs when an individual improperly obtains personal information of college customers so as to be able to commit identity theft. It is accomplished by contacting the College, posing as a customer or someone authorized to have the customer's information, and through the use of trickery and deceit, convincing an employee of the College to release customer identifying information. Back to Design & Implementation of Safeguards Program 4 The Financial Services Modernization Act of 1999 (also known as The Gramm Leach Bliley Act (GLBA) 15 U.S.C. § 6801 5 The Family Education Rights and Privacy Act of 1974 (FERPA) 20 U.S.C. § 1232g 6 Social Security Numbers are kept both for historical purposes and due to the requirements of 26 U.S.C. § 6050S, the tuition payment credit reporting requirements. |
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