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Gramm-Leach Bliley Act Compliance Services | Case History

Wilson Consulting Group assisted a private research university which needed to create its GLBA program to ensure compliance to protect confidentiality and security of “nonpublic personal information” (NPI).

Scenario

Title IV schools are financial institutions per Gramm-Leach-Bliley Act (GLBA, 2002). Per FSA PPA & SAIG agreements, these schools must have GLBA safeguards in place. Otherwise they may be found administratively incapable (unable to properly administer Title IV fund).

A private research university needed to create its GLBA program. This is to ensure compliance to protect confidentiality and security of “nonpublic personal information” (NPI).

  • Tile IV School: An institution that processes U.S federal student aid
  • NPI: any “personally identifiable financial information” that a financial institution collects about an individual in connection with providing a financial product or service, unless that information is otherwise “publicly available”

WCG Strategies

WCG was contracted to develop a GLBA compliance program that would assist the university in implementing correct policies, processes, standards, techniques and technologies to securely collect, handle and transmit NPI.

WCG developed and implemented a tailored GLBA compliance program. This program was consisted of:

  • Compliance Program plan
  • Data maps of all processes that transmit, process, and store PII
  • Policies, processes, and standards
  • Awareness, training, and education plan
  • Service providers agreement and process evaluation

WCG Results

WCG assisted the university in determining their level of compliance within the GLBA by designing systems, processes, and procedures to achieve compliance. A comprehensive GLBA program was created by WCG and validated by the university management. The new program ensured compliance with GLBA and, thereby, improved its security posture.

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