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Posted June 19, 2020
In 1999, Congress passed the Gramm-Leach-Bliley Act, also known as the Financial Modernization Act of 1999. This act applied new privacy rules to financial institutions, designed to ensure the safety of customers’ private information.
Primarily, the act applies to banks, credit unions, lenders, etc. However, it also applies to any organization that regularly handles financial information. Given most students need loans to afford school, the GLBA also applies to higher education.
In 2020, GLBA compliance is more important than ever.
The Gramm-Leach-Bliley Act requires financial institutions to have specific security measures in place and to document how they protect financial information and with whom they share it. Customers have the right to opt-out of having any data shared with third parties. You have to have a written security plan. Compliance with the GLBA benefits institutions and their customers, helping institutions secure financial information and avoid potentially costly data breaches.
Non-compliance can also cause institutions to face fines of $100,000 per violation, and specific individuals responsible can be imprisoned for up to 5 years. The GLBA contains two key elements, the GLBA privacy rule and the GLBA safeguards rule.
The GLBA privacy rule is one of the two core requirements institutions must follow. It requires institutions to provide each customer with a privacy notice at the time the relationship is established and annually thereafter. This notice must include what information they collect, how it is shared and used, how it is protected, and how they can opt out of their information being shared with other parties.
Essentially this means that a privacy notice must be sent to all new students at the time they apply for financial aid and every year until graduation (at which point it becomes the responsibility of the lender). The privacy notice should be clearly readable and should be reviewed with the institution’s legal authority.
The second core requirement is the safeguards rule. The safeguards rule requires multiple elements. The first is that the institution must have a written information security plan. Additionally, the institution must do a risk assessment on each department that handles private information, and develop and test controls to address any deficiencies found in the risk assessment. The plan must be updated if there are any changes. For most institutions, acquiring a program from a third-party vendor is the best course of action.
The increasing importance of GLBA compliance stems primarily from the sheer amount of money handled by a modern university. There are other reasons, though. Data breaches and cybersecurity incidents cannot be swept under the rug in today’s landscape of transparency and rapid communication.
The final reason is that institutions are going to be facing audits. The Office of Management and Budget issued required audit requirements related to GLBA in July, 2019. These guidelines apply to non-federal entities that expend $750,000 or more in federal funds (such as federal student loans and Pell grants) in a year. Smaller community colleges may not be affected, but larger institutions can easily hit this limit and come under the audit. While institutions are already required to follow the GLBA safeguards rule to get Title IV funding, the audit may come as a shock to many, and the findings may be made public. This might affect the willingness of students and families to consider your university.
Even if the requirements don’t apply to you, they make a good set of guidelines to ensure cybersecurity for your students and their families, and thus avoid a data breach that could be embarrassing, put your students at risk, and affect future enrollment.
You need to follow best practices, which include:
As many institutions do not have the internal knowledge of cyber security, seeking out expert GLBA compliance services for higher education is often the answer.
The compliance requirements for GLBA include:
The first three of these started to be included in the planned audits of institutions starting in the fiscal year ending June 30, 2019, whilst the second three may well be added moving forward. With the high penalties for non-compliance, it’s vital that all colleges and universities have a proper GLBA compliance program in place. Even if the audit will not be conducted at your institution, meeting these standards will help to prevent a data breach that can affect your reputation and student enrollment, as well as the generosity of your alumni giving
Because of this, Colleges and Universities should seek expert help to ensure that they are compliant with the law and providing the highest levels of privacy for their students and their families. If you are looking for assistance in GLBA compliance, contact GreyCastle Security today. We have the experience and expertise you need to ensure that you do not become the next victim of a high-profile data breach.
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Ho Chin is Chief Financial Officer at GreyCastle Security. In this role, Ho leads Finance, HR, IT and Professional Development. As part of the executive leadership team, Ho works to establish the company’s overall strategy and ensure proper execution of the supporting initiatives pertaining to the above areas of responsibility.
Prior to joining GreyCastle Security, Ho led finance and administrative functions at multiple private equity and venture-backed portfolio companies across multiple industries. Ho holds a bachelor’s degree in Accounting from Pennsylvania State University in Centre County, Pennsylvania and a master’s degree in Business Administration from the Wharton School of Business at the University of Pennsylvania in Philadelphia, Pennsylvania.
Dan Kalil is Chief Executive Officer (CEO) and Board Chairman at GreyCastle Security. In this role, Dan provides vision, leadership and strategies that drive GreyCastle Security’s position as an industry leader. With an emphasis on customer success, Dan’s profitable growth model leverages a customer-centric business approach that balances employee wellbeing and social responsibility.
Prior to becoming CEO, Dan served as the company’s Chief Strategy Officer, during which he supported multiple acquisitions and helped the organization achieve substantial sales growth. In addition to serving as CEO at GreyCastle Security, Dan continues to hold the position of Chief Commercial Officer (CCO) at Assured information Security (AIS) in Rome, New York, a company he co-founded in 2001.
Over the course of the last 22 years, Dan has been committed to advancing the state of cybersecurity and has played an instrumental role in the identification and development of critical, next-generation cyber capabilities. He has held positions in almost every facet of cybersecurity, beginning as a computer forensic examiner and progressing through the management and executive leadership ranks. In addition to co-founding AIS, Dan has facilitated multiple cybersecurity startups, raised investment capital and has served in various lead and support roles toward the acquisition of five companies in the last eight years.
Dan has a bachelor’s degree in Cybersecurity and a master’s degree in Cybersecurity from Utica College in Utica, New York.
Michael Stamas is an entrepreneur, board member, Vice President and a founder of GreyCastle Security. With more than two decades of experience in the technology sector, Mike pairs his management and business development skills with a deep understanding of cybersecurity. Mike brings a unique brand of risk-based advising to GreyCastle clients and prospects.
Mike holds certifications in numerous security and technology related areas, including the Department of Homeland Security and other security technologies like Symantec, Cisco and Microsoft.
Mike plays an active role in his community and serves as a board member and Vice President of InfraGard Albany as well as an advisory board position with the Capital Region YMCA.
Mike has been recognized for his numerous achievements through various honors including the Albany Business Review’s prestigious 40 Under 40 award.
Dan Maynard serves as GreyCastle Security’s Chief Operating Officer, where he currently leads Sales, Marketing and Legal.
Dan has enjoyed a 30+ year career in the Information Technology and Telecommunications industry, during which time he has held various leadership positions for organizations such as Rochester Tel/RCI, Citizens Communications (Frontier), PAETEC Communications, IntegraOptics, tw telecom/Level3 and Centurylink.
In addition to various voice and data technology platforms, he possesses a strong background in leadership development, sales and marketing leadership, transformational leadership and strategic planning. Dan has a thirst for knowledge and as a committed lifelong learner, he encourages and supports professional development initiatives for his teams and continues his involvement with Vistage International.
Dan holds a bachelor’s degree in Biology from Lafayette College in Easton, Pennsylvania, where he was selected as a member of their Athletic Hall of Fame in 2016.
When not at work, Dan enjoys traveling, golfing, attending Utica Comets hockey games and relaxing in the Adirondacks on beautiful Canada Lake with family and friends.
Dan Didier is the Vice President of Solutions and board member at GreyCastle Security.
Dan has been a cybersecurity practitioner for more than 20 years and uses his knowledge and experience to develop cybersecurity solutions that ensure readiness and preparedness.
Dan received his bachelor’s degree in Telecommunications from SUNY Polytechnic Institute in Utica, New York, and graduated Summa Cum Laude with a master’s degree in Information Assurance from Norwich University in Northfield, Vermont.
Our Computer Incident Response Teams (CIRTs) have responded to hundreds of breaches, intrusions, malware infections, thefts, employee investigations, fraud cases and other incidents. Our highly-certified experts have extensive experience in command, coordination and correction of incidents in nearly every industry throughout North America, from local businesses to Fortune 500 international conglomerates.
800-403-8350Francesca LoPorto-Brandow is Director of Culture at GreyCastle Security. In this role, Francesca leads all social responsibility efforts and partnerships and develops effective strategies that promote organizational-wide behaviors and attitudes consistent with a culture of safety, inclusion, teamwork, motivation and high-performance.
Prior to this role, Francesca was Director of People & Culture at GreyCastle and with her leadership, the company’s culture has been recognized by Inc. Magazine as a Nationally recognized Best Workplace, Albany Business Review Best Places to Work and Albany Times Union Top Workplaces.
Before joining GreyCastle Security, Francesca worked as an OD consultant and focused on strategic culture change at The Kaleel Jamison Consulting Group, Inc. for more than six years. There, she facilitated client education sessions, coached leaders and teams, developed and executed consulting interventions and served as strategy project leader on various client engagements. Her work has taken her into Fortune 100 companies and across borders including Panama, Singapore and beyond.
Francesca is a Lean Six Sigma–certified Green Belt, a proud YWCA-GCR board member and in 2013, she coordinated and emceed the inaugural TEDx Troy—a livestream of TEDCity 2.0. Since 2012, she has coordinated and emceed the Troy 100 Forum, a biannual forum for government, religious and community leaders to discuss issues vital to the future of Troy, New York.
Bilingual in English and Italian, Francesca holds a bachelor’s degree in Management and Technology from the Rensselaer Polytechnic Institute’s Lally School of Management & Technology. She was awarded Cybersecurity Recruiter of the year North America in 2017 by the Cybersecurity Excellence Awards.
Jamie Aiello is Senior Vice President of Services and Product Management at GreyCastle Security. In this position, Jamie is responsible for leading a high performing and well-balanced team that is ultimately responsible for the identification, selection, execution and successful performance of our company’s diverse portfolio of cybersecurity offerings.
Prior to joining GreyCastle Security, Jamie has held leadership positions with Annese and Associates, ConvergeOne and BlueSky IT Partners with a focus on delivering cost effective information technology solutions for companies across multiple verticals.
Jamie holds a bachelor’s degree in Political Science from Le Moyne College in Syracuse, New York, a master’s degree in Business Administration from Gardner-Webb University in Boiling Springs, North Carolina and a master’s degree in Computer Information Systems from University of Phoenix in Phoenix, Arizona.
