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Institutional GLBA Information Security Plan

Definitions

Customer: A customer is any individual who receives a financial service from the institution and who, in the course of receiving that financial service, provides the institution with nonpublic financial information about themselves. Customers may include, but are not limited to, students, parents, faculty, staff and other third parties with whom the institution interacts.

Customer information: Customer information means any nonpublic financial information that is handled or that is maintained by or on behalf of the institution or its affiliates. The definition of customer information is very broad and may include records containing social security numbers, bank account numbers, account balances, credit card numbers, credit history or rating, or tax return information of individual customers.

Nonpublic financial information: Nonpublic financial information means any information:

Financial Product or Service: Offering a financial product or service includes, but is not limited to, offering or processing student loans; granting emergency or long term loans to students or faculty; 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 management consulting activities on any subject to a financial institution and on financial, economic, accounting or audit matters to any company.

Service Providers: Service providers refer to all third parties who, in the ordinary course of institutional business, are provided access to customers' covered data and information. Service providers may include, but are not limited to, businesses retained to store, transport or dispose of covered data; collection agencies; and technology systems support providers.


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