The Gramm Leach Bliley Act (GLBA) enacted by the United States Congress became effective in 2003 and applies to financial institutions and institutions of higher education and established privacy and security provisions that are designed to protect consumer (students treated as a consumer) financial data. GLBA mandates how higher education institutions collect, store, and use student financial records (e.g., records regarding tuition payments and/or financial aid) containing personally identifiable information. GLBA regulations include both a Privacy Rule (16 CFR 313) and a Safeguards Rule (16 CFR 314), both of which are enforced by the Federal Trade Commission (FTC) for higher education institutions. Colleges and universities are deemed to be in compliance with the GLBA Privacy Rule if they are in compliance with the Family Educational Rights and Privacy Act (FERPA). The Safeguards Rule was promulgated in 2002, with compliance documentation required in May 2003.
The objectives of GLBA are to insure the security and confidentiality of student financial information, protect this information from any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information that could result in substantial harm to any student. While there is overlap with FERPA, GLBA Safeguards Rule still applies. FERPA covers students’ educational records including their right to access and inspect and what information can be disclosed. GLBA focuses on nonpublic personal information which is usually limited to individual’s financial information obtained in connection with a financial product or service.
The types of information covered as nonpublic personal information that may be required in connection with a financial product or service offered or serviced by or on behalf of SAU can include:
Account Balances, Account Numbers, and Social Security Number
Student Financial Aid Information (application through award)
Debit/credit card numbers, payment history, and credit score or rating
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