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2006 Spring MASFAP CONFERENCE Ginny D’Angelo Vice President of Student Loans Commerce Bank Leo Hertling Associate Director St. Louis College of Pharmacy
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2006 Spring MASFAP CONFERENCE
Ginny D’Angelo
Vice President of Student Loans
Commerce Bank
Leo Hertling
Associate Director
St. Louis College of Pharmacy
GRAMM-LEACH-BLILEYGLB ACT
Financial Modernization Act of 1999
Gramm-Leach-Bliley Act
GLB is a federal law, which includes provisions in requiring financial institutions to take steps ensuring the security and confidentiality of a consumers/customers personal information.
In 2003, the Federal Trade Commission (FTC) confirmed that higher education institutions are considered financial institutions under this law.
Gramm-Leach-Bliley Act
Colleges and universities must be in compliance with provisions of the GLB Act that relate to the Safeguards Rule.
Colleges and universities that already comply with FERPA will be deemed to be in compliance with FTC privacy rules under the GLB Act.
Gramm-Leach-Bliley Act
The law requires that institutions must protect information collected about individuals:
NamesAddresses and phone numbersBank and credit card accountsSocial Security numbers Income and credit histories
Gramm-Leach-Bliley Act
According to the Safeguards Rule, financial institutions must develop a written information security plan that describes their program to protect customer information. Privacy notices explaining an institution’s information-sharing practices must also be provided to each customer.
Gramm-Leach-Bliley ActExperts suggest that three areas of operation
present special challenges and risks to information security:
Employee training and management Information systems (network and
software),storage,transmissions and retrievals
Security management, including prevention, detection and response to attacks, intrusions or other system failures
Gramm-Leach-Bliley Act
Quick Tips for Safeguarding information: Identify what is considered sensitive
informationProtect all sensitive information from
unauthorized access or usePut safeguarding into practiceReport suspicious activity
How does this apply to you?
Privacy of Information – FERPA
Safety of Information
Which Units are Most Affected by GLB?
Registrar
Financial Aid Office
Bursar
Development Office
IT
Academic Departments
Privacy of Information
FERPA – Family Educational Rights & Privacy Act (1974)If you are FERPA-compliant, you are meeting GLB criteria to protect information privacyFERPA protects privacy of all student educational records and financial information
FERPA Policies
Written policy – College CatalogueStaff training; i.e., memos from Registrar’s Office to faculty & staff regarding FERPA policyInformation is shared on a “need to know” basis, i.e.:
AuditsLaw enforcement officials (must have proper documentation and credentials)Contracted services (loan, collection agencies)
Development Office
Rights Guaranteed under FERPA
Right to inspect and review educational records
Right to seek amendment of educational records
Right to have control over the disclosure of educational records
Right to file a complaint with ED for alleged failures of an institution’s compliance
What Can Be Shared?
MAY SHARE Name Address telephone # Major DOB and location Photo Dates of attendance School activities Enrollment status Most recent previous school attended
MAY NOT SHARE Social Security # Student ID # Race Ethnicity Nationality Gender
Dealing with Parents
Major differences between FAO policies and those of the RegistrarFor the Registrar Parents may have access to student records if:
They have obtained a SIGNED AND WRITTEN CONSENT or the student
If the student is under the age of 24 and was claimed by the parent in the prior tax year, the parent may access the students records after the student has been advised of the institution’s intention to release information to the parent. You must give the student adequate time to respond.
You must return the tax return to the parent. You do not have the right to keep it. Simply document that you checked it and that the student was claimed.
If the student objects, the parent must obtained a signed written consent before records may be released.
School must maintain records of the request and ANY disclosures
The FAO and Parents
Parents of dependent students are afforded the right to access a student’s financial records.
This applies for Dependent students in terms of IRS dependency. NOT TIV aid terms.
FAOs may have student sign an annual waiver granting the parents access on an annual basis.
Dealing with Spouses
FERPA does not recognize spouses therefore they must be treated as unrelated 3rd parties
As such, spouses have NO rights to a student’s educational or financial aid records.
Period end of discussion.
GLB extends FERPA
If your institution makes loans to parents and other individuals, you must also protect their privacy
These loans can include:
PLUS
Alternative Parent Loans
Safeguard Rule
Institutions must develop a written information security plan to protect customer information
Institutions must send privacy notices explaining the information-sharing practices to each customer
Safeguards Rule Expanded
Must include plans to safeguard information against:Natural DisasterHuman ErrorFraudData corruptionTheft (hardware, software, reports)Unauthorized access
Safeguards Rule (cont)
Natural Disaster (Earthquake, hurricane, flood, tornado, etc.) Is your data backed up in a remote
location?Do you lock your computer when you leave
your work station during fire alarms – or any other time, for that matter!?
Safeguards Rule (cont)
Deliberate FraudMust maintain a separation of duties Conflict of interest policies must be
observed
Human ErrorDo you have audit trails and reports that
can be used to reconstruct data
Safeguards Rule (cont)
Data CorruptionProtect and secure access to data, i.e.,
limit query vs. update capability on a “need-to-do” basis, limit student worker access as needed
Anti-virus software must be maintained and applied
Institution must erect firewalls and develop protection against hackers
Safeguards Rule (cont)
Must secure against theft of hardware, software and reportsSecure during non-business hours: offices
locked, keys securedApproved shredder: eliminates guess work
in how to feed in documents
More Safeguards
Must protect against unauthorized accessFrequent password changes should be
systematically requiredReports sent on a “need-to-know” basisComputer privacy shieldsStudent ID card readers – prevents
inappropriate overhearing of SIDs or SSNs
More Safeguards
Communicating to students via e-mail: Use student’s institutional e-mail address Respond to non-institutional e-mail that an answer has been
sent to the student’s institutional e-mail address Respond to parent inquiries through student’s institutional e-
mail and ask student to forward to parent
• Mass e-mail communication to students should take student’s to a secure web site that protects their individual information
Whose Responsible Anyway?
Identify and involve all offices involved with loans or collection of dataFAOBusiness Office IT/Computer SystemsDevelopmentAcademic departments (scholarship
applications)
Who’s the Compliance Officer?
Someone must be designated the institutional Compliance Officer
This function is usually assumed by the Business and Finance DivisionAt STLCOP our registrar is our CO
FAO responsibility rests in informing potential units of GLB responsibility
FAO GLB Policies
Shred all student-specific documents
Policy for identifying students and parents before sharing data
Refer non-student/parent requests (3rd party) to appropriate staff
Report computer problems immediately
Additional FAO Policies
Don’t share passwords. Problem: What do you do when an employee is absent and you need to access information on his/her computer?Lock computers when leaving work areaComputer screens shielded from other studentsNo visitor left behind – or unattended!
Resources
US Department of Education http://www.ed.gov/policy/gen/guid/fpco/ferpa/index
.htmlFSA Handbooks 05-06 Recordkeeping and Disclosure Chapter 2 156-164
The Blue Book Chapter 7 Record Keeping and Disclosure pp 1-93
– 1-104Ramirez, Clifford (2002) Managing the Privacy of Student Records, LRP Publications, Horsham PA
CONTACT INFORMATION
Ginny D’Angelo(800) 666-3910
Fax: (314) [email protected]
Leo Hertling314/446-8321
fax# 314/[email protected]
