Policies and Procedures Manual

Chapter 4: Business & Administration

04:50:00   Safeguarding of Customers' Nonpublic Financial Information

(TBR Guideline B-090, Gramm-Leach-Bliley Act)

Federal law requires that financial institutions, the definition of which includes Northeast State Community College, comply with the Gramm-Leach-Bliley Act and, in so doing, safeguard the confidentiality of nonpublic financial information of its constituents. Nonpublic financial information is any record that an institution obtains from a customer in the process of offering a financial product or service, or such information provided to the institution by another financial institution.

The term nonpublic financial information means any information:

  1. that a student or other third party provides in order to obtain a financial service from the institution; about a student or other third party resulting from any transaction with the institution involving a financial service; or otherwise obtained about a student or other third party in connection with providing a financial service to that person, and 
  2. any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available.

Examples of nonpublic financial information include, but are not limited to, mailing addresses, phone numbers, bank credit card account numbers, income tax and credit histories, and Social Security numbers.

Offering a financial product or service includes, but is not limited to, offering/processing student loans; granting emergency or long-term loans to students or employees; receiving income tax information from a student’s parent when offering a financial aid package; offering career counseling services to individuals who seek employment at financial institutions and on financial, economic, accounting, or audit matters to any company.

Northeast State has developed a comprehensive written Information Security Program (the Program”) as mandated by the Gramm-Leach-Bliley Act (GLBA”) Standards for Safeguarding Customer Information Rule. Northeast State’s Program includes components pursuant to which Northeast State intends to:

  1. protect the security and confidentiality of customers’ nonpublic financial information;
  2. protect against any anticipated threats or hazards to the security or integrity of such information; and
  3. protect against unauthorized access or use of such records or information in ways that could result in substantial harm or inconvenience to customers.

To promote uniform compliance with the Program by all personnel employed by Northeast State and to achieve the institution’s duty to safeguard the confidentiality of customers’ nonpublic financial information, Northeast State disseminates the Program in accordance with the institution’s standard distribution policy. Northeast State’s Program is located in the Human Resources Office. The Program is available upon request for review and copy at any time between the hours of 8:00 a.m. and 4:30 p.m. Monday through Friday.



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Divisional Review Responsibilities Checklist: Finance

Revision History: Implemented: July 2004