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GLBA Policy

Gramm-Leach-Bliley Act of 1999 (GLBA)

Overview: This document summarizes Neosho County Community College’s comprehensive written information security policy (the "policy") mandated by the Federal Trade Commission's Safeguards Rule and the Gramm-Leach-Bliley Act ("GLBA"). In particular, this document describes the Program elements pursuant to which the Institution intends to (i) ensure the security and confidentiality of covered records, (ii) protect against any anticipated threats or hazards to the security of such records, and (iii) protect against the unauthorized access or use of such records or information in ways that could result in substantial harm or inconvenience to customers. The policy incorporates by reference, the College’s existing policies and procedures and is in addition to any College policies and procedures that may be required pursuant to other federal and state laws and regulations, including, without limitation, FERPA.

Designation of Representatives: The institution's chief information officer is designated as the program officer who shall be responsible for coordinating and overseeing the policy. The program officer may designate representatives of the Institution to oversee and coordinate particular elements of the policy. Any questions regarding the implementation of the program or the interpretation of this document should be directed to the program officer or his or her designees.

Scope of Policy: The policy applies to any record containing nonpublic financial information about a student or other third party who has a relationship with the Institution, whether in paper, electronic or other form that is handled or maintained by or on behalf of the Institution or its affiliates. For these purposes, the term nonpublic financial information shall mean any information (i) a student or other third party provides in order to obtain a financial service from the Institution, (ii) about a student or other third party resulting from any transaction with the Institution involving a financial service, or (iii) otherwise obtained about a student or other third party in connection with providing a financial service to that person.

Elements of the Policy:
Risk Identification and Assessment
The Institution intends, as part of the policy, to undertake to identify and assess external and internal risks to the security, confidentiality, and integrity of nonpublic financial information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information. In implementing the policy, the program officer will establish procedures for identifying and assessing such risks in each relevant area of the Institution's operations, including: 
Employee Training and Management
The program officer will coordinate with representatives in the Institution's student/financial services and financial aid offices to evaluate the effectiveness of the Institution's procedures and practices relating to access to and use of student records, including financial aid information. This evaluation will include assessing the effectiveness of the Institution's current policies and procedures in this area.

Information Systems and Information Processing and Disposal
The program officer will assess the risks to nonpublic financial information associated with the Institution's information systems, including network and software design, information processing, and the storage, transmission and disposal of nonpublic financial information. This evaluation will include assessing the Institution's current polices and procedures relating to acceptable use policy, information technology security policy, and records retention policy. The program officer will also assess procedures for monitoring potential information security threats associated with software systems and for updating such systems by, among other things, implementing patches or other software fixes designed to deal with known security flaws.

Detecting, Preventing and Responding to Attacks
The program officer will evaluate procedures for and methods of detecting, preventing and responding to attacks or other system failures and existing network access and security policies and procedures, as well as procedures for coordinating responses to network attacks and developing incident response teams and policies.
Designing and Implementing Safeguards.  

Overseeing Service Providers
The risk assessment and analysis described above shall apply to all methods of handling or disposing of nonpublic financial information, whether in electronic, paper or other form. The program officer will, on a regular basis, implement safeguards to control the risks identified through such assessments and to regularly test or otherwise monitor the effectiveness of such safeguards. Such testing and monitoring may be accomplished through existing network monitoring and problem escalation procedures. 
Overseeing Service Providers
The program officer shall coordinate with those responsible for the third party service procurement activities among the department of technology services and other affected departments to raise awareness of, and to institute methods for, selecting and retaining only those service providers that are capable of maintaining appropriate safeguards for nonpublic financial information of students and other third parties to which they will have access.

Adjustments to Program
The program officer is responsible for evaluating and adjusting the program based on the risk identification and assessment activities undertaken pursuant to the program, as well as any material changes to the Institution's operations or other circumstances that may have a material impact on the program.