Case History: GLBA Compliance for Higher Education Institution

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
  • The Outcome

  • 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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