The Gramm-Leach-Bliley Act, (GLBA) effective May 23, 2003, addresses the safeguarding and confidentiality of
customer information held in the possession of financial institutions such as banks and investment companies.
GLBA contains no exemption for colleges or universities. As a result, educational entities that engage in financial
activities, such as processing student loans, are required to comply. GLBA and other emerging legislation could
result in standards of care for information security across all areas of data management practices both electronic
and physical (employee, student, customer, alumni, donor …etc.). Therefore, the University has adopted a
Customer Information Security Program for certain highly critical and private financial and related information.
This security program applies to customer financial information (covered data) the University receives in the course
of business as required by GLBA as well as other confidential financial information the University has voluntarily
chosen as a matter of policy to include within its scope.
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