The Gramm Leach Bliley Act (GLBA) requires financial institutions to take steps to ensure the privacy, security and confidentiality of student records containing non-public customer 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). The FTC considers the University to be a financial institution based on its student loan processing activities.
This rule enforces several requirements related to the handling of non-public customer information.
The University is considered to be in compliance with the Privacy Rule through its adherence with the Family Educational Rights and Privacy Act (FERPA). Information about FERPA is available on the University’s Registrar’s website: https://registrar.virginia.edu/ferpa.
The Safeguards Rule applies to non-public customer information the University receives as well as other confidential financial information the University may choose to include within its scope.
Under the GLBA Safeguards Rule, the University is required to:
- Ensure the security and protection of customer information
- Protect against any anticipated threats or hazards to the security or integrity of such information
- Protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer
The University has adopted the following information security measures relative to the GLBA Safeguards rule requirements:
- Designating an employee to coordinate an information security program
- Conducting risk assessments of information systems containing covered data to identify risks to customer information
- Implementing appropriate safeguards based upon identified risks
- Taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards for covered data and ensuring they do so
- Periodically evaluate and adjust the information security plan to ensure ongoing protection of confidential information
Student Financial Services (SFS) works closely with UVA Information Security and business owners who maintain, store, transmit and process covered data to ensure compliance with all required components of GLBA.
Risk assessments are the foundation upon which informed security management decisions are made. As a result, business owners who maintain, operate, or manage information systems containing GLBA covered data are expected to conduct periodic risk assessments. In addition to performing risk assessments, business units are expected to implement mitigation strategies to reduce or eliminate identified risks.
GLBA Risk Assessment Q & A
1. Question: How often will we have to complete a risk assessment?
Answer: GLBA requires the University to regularly assess risks in all systems that contain student financial information. As a result, you may be asked to conduct a risk assessment on an annual basis on all identified systems.
2. Question: How was the risk assessment designed?
Answer: The questions in the risk assessment were selected and customized using NIST SP 800-171 to meet the requirements of the GLBA Safeguards Rule. Specifically, the risk assessment aims to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student financial information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information.
3. Question: Why do we have to complete a risk assessment?
Answer: Risk assessments are required under 16 CFR Part 314.4(b)(2), Standards for Safeguarding Customer Information, which implements sections 501 and 505(b)(2) of GLBA.
4. Question: What should be included in a remediation plan.
Answer: Your remediation plan should be written and should describe how each identified risk will be mitigated and the timeline for remediating the risk.
5. Question: Will we be provided with a template or guidance on the remediation plan?
Answer: Development of the remediation plan will be the responsibility of the department or business unit that maintains or manages the system with the identified risks. You may need to work with your department or business unit’s leadership to prioritize and implement a mitigation strategy.
6. Question: What should we do if we have technical questions about implementing the remediation plan?
Answer: ITS Services can answer questions and assist you with the technology (e.g. networks and WiFi, storage, access) required to implement your remediation plan.
7. Question: What happens if we do not develop or implement a remediation plan?
Answer: Your remediation plan contributes to the University’s compliance with GLBA. If you do not develop and implement a remediation plan, your system may be disabled or disconnected from the network by ITS in accordance with IRM-004: Information Security of Technology Resources.
In addition, if the University is not able to meet GLBA audit requirements, it may be subject to an audit finding. According to the Department of Education (ED), audit findings will be referred to the FTC and to Federal Student Aid’s Postsecondary Institution Cybersecurity Team (Cybersecurity Team). If the Cybersecurity Team determines that the University poses substantial risk to the security of student information, the University’s access to ED’s information systems may be temporarily or permanently disabled and the University will not be able to award or disburse federal student aid.
The terms listed here and their corresponding definitions apply to the GLBA compliance program.
Any University unit, department, area or employee who maintains, stores, transmits or processes covered data.
Non-public customer information required to be protected under GLBA. This also includes any data or information the University chooses to include even if not covered by GLBA. This information may be in paper, electronic, or other form.
Any person who is provided financial services by the University, such as obtaining a loan from the University or having a loan for which the University has servicing rights or responsibilities.
Financial Product or Service
Includes student loans, employee loans, activities related to extending credit, financial and investment advisory activities, management consulting and counseling activities, community development activities and other miscellaneous financial services (12 CFR 225.28).
Any location where covered data resides, including servers, networks, and computing stations.
Non-Public Customer Information
Any financial information or record given by a consumer to a financial institution for the purpose of obtaining a financial product. This information may be in paper, electronic, or other form. (16 CFR 313.3(n))
Nonpublic personal information means:
- Personally identifiable financial information.
- 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 personal information include but are not limited to:
- Social Security Number
- Credit Card Number
- Account Numbers
- Account Balances
- Any Financial Transactions
- Tax Return Information
- Driver's License Number
- Date/Location of Birth
Examples of services or activities that the university may offer which result in the creation of customer information could include but are not limited to:
- Student (or other) loans, including receiving application information, and the making or servicing of such loans
- Credit counseling services
- Collection of delinquent loans and accounts
- Check cashing services
- Real estate settlement services
- Issuing credit cards or long term payment plans involving interest charges
- Obtaining information from a consumer report
Any person or entity that maintains, stores, transmits or processes customer information through its provision of services directly to the University.
This ends information relevant to Gramm-Leach-Bliley Act compliance.