This document summarizes the comprehensive written financial information security program at Auburn University at Montgomery (AUM) mandated by the Federal Trade Commission’s (FTC) Safeguarding Rule under the Gramm-Leach-Bliley Act (GLBA). The Federal Trade Commission requires that “financial institutions,” which includes most institutions for higher education, establish policies and procedures for safeguarding customer financial information. The GLBA also includes specific requirements regarding the privacy of customer financial information. The FTC has determined that educational institutions that comply with the Family Educational Rights and Privacy Act (FERPA) satisfy the privacy requirement of the GLBA. AUM is entrusted with customer financial information and is continuing to develop ways to address cybersecurity threats and to strengthen its cybersecurity infrastructure.
AUM’s Chief Information Officer is designated as the Program Officer who is responsible for coordinating and overseeing the Program. The Program Officer may designate other representatives of the Institution to oversee and coordinate particular elements of the Program. Questions regarding implementation or interpretation of the Program should be directed to the Program Officer or his or her designee(s).
Customer Information – records containing non-public personal information about a customer, whether in paper, electronic, or another form that is handled or maintained by or on behalf of AUM or its affiliates.
Information Security Program – The administrative, technical, or physical safeguards used to access, collect, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle customer information.
Service Provider – Any person or entity that receives, maintains, processes, or otherwise is permitted access to customer information through its direct provision of service to AUM.
Non-public Personal Information – Personally identifiable financial information and any list, description, or other grouping of customers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available.
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