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Under the federal Gramm-Leach-Bliley Act (" referred to as The GLB Act") a financial institution, a term defined in a way that includes institutions of higher education and some private schools, must develop plans and establish policies to protect certain information about individuals, primarily students, faculty and staff. The GLB Safeguards Rule requires covered colleges and universities to take steps to insure the security and confidentiality of non-public personal information of a financial nature, such as bank and credit card account numbers, income and credit histories, and social security numbers. . Colleges and universities and private schools are subject to GLB when they offer certain financial services or products, including: · 1.student loans, such as federal Perkins loans; · 2.mortgages to faculty members; · 3.financial counseling to donors in planned giving programs; · 4.career counseling services to those going into or planning to enter financial service positions. · 5.offering cards that are used in lieu of cash for campus transactions. For additional information in relation to this matter call 800-474-7332 ext 205 and request our brochure on Educational Institution & GLB Compliance

The Gramm-Leach, Biley Act, Enforcement of the Safe Guard Provisions (Pennsylvania, PA, New Jersey, NJ, New York, NY).

Shredding NPI. Dr. Howard Beales joined the Federal Trade Commission in 1977. In June of 2001 he was appointed Director of the FTC Bureau of Consumer Protection. This division of the FTC is responsible for the enforcement of the Gramm- Leach, Biley Act. On September 23rd, 2003 the Safe Guard Provisions of the Act took effect. Dr. Beales has given over 25 speeches on the Act. In a January 24th, 2002 speech, in San Francisco, Dr. Beales provided us with insight as to the priorities of his Directorship. “ In the past the Commission’s privacy program focused primarily on information collection. In contrast, we believe that the focus should be on the misuse of information.” Dr. Beales went on to state his concerns about on line theft as well as off line theft. He sited instances of off line theft resulting in the real danger of Identity Theft. Identity Theft is a reoccurring theme in all of Dr. Beales speeches and points out its growth to the number one fastest growing crime in our country today. As if to emphasize the targeting of information leakage The Commission brought their first action under the new law against the Elli Lilly Corporation. Elli Lilly was cited for unintentionally disclosing the e-mail addresses of 699 users of its Prozac Drug.” This was very sensitive information, where release could have adverse consequences for the consumers involved”, stated Dr. Beales. In a recent work shop on the implementation of procedure for the Safe Guard Regulation there was a question and answer segment. This question was ask of Dr. Beales. Question: What about record destruction companies? How would you be able to opt out a customer from the reports that are shredded? Answer: Sharing customer’s records with a record destruction company for the purpose of having the records shredded and disposed of would be activities that would fall under the exception under _ Section 15. Insuring compliance with this requirement mandates a letter of understanding, which prohibits the third party service provider from disclosing or using any customer’s nonpublic personal information of a financial nature.

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The Gramm-Leach, Biley Act, Enforcement of the Safe Guard Provisions (Pennsylvania, PA, New Jersey, NJ, New York, NY).

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