Scope of Practice and Definitions

Scope of Practice

The Program applies to (i) any record containing nonpublic personal information about a student or other third party who has a continuing relationship with the College, whether in paper, electronic or other form, which is handled or maintained by or on behalf of the College and (ii) any record containing nonpublic personal information pertaining to customers of other financial institutions that have provided such information to the College. For these purposes, the term nonpublic personal information shall mean:

  • Personally identifiable financial information, defined as any information (i) a student or other third party provides in order to obtain a financial product or service from the College, (ii) about a student or other third party resulting from any transaction with the College involving a financial product or service, or (iii) otherwise obtained about a student or other third party in connection with providing a financial product or service to that person.
  • Any list, description or other grouping that is derived using any personally identifiable financial information that is not publicly available.

For the purpose of this policy, offering financial products and services includes offering student loans, receiving income tax information from a student's parent when offering a financial aid package, and other miscellaneous financial services. Examples of student financial information include without limitation, information a student provides to obtain a loan or other financial product or service, bank and credit card account numbers, income and credit histories and social security numbers, in both paper and electronic format. The fact that a student or third party has obtained a financial product or service from the College is also financial information.

Pursuant to this Program, administrative, technical and physical safeguards will govern access, collection, distribution, processing, protection, storage, use, transmittal, disposal or other handling of information covered under GLBA.

Definitions

Covered Data and Information

  • Student financial information required to be protected under the Gramm‐Leach‐ Bliley Act (GLB). In addition to this coverage which is required by federal law, Platt College chooses as a matter of policy to also define covered data and information to include any credit card information received in the course of business by the college, whether or not such credit card information is covered by GLB. Covered data and information includes both paper and electronic records.

Student Financial Information

  • Information Platt College has obtained from a student in the process of offering a financial product or service, or such information provided to the college by another financial institution. Offering a financial product or service includes offering student loans to students, receiving income tax information from a student/student's parent when offering a financial aid package, and other miscellaneous financial services. Examples of student financial information include addresses, phone numbers, bank and credit card account numbers, income and credit histories and social security numbers, in both paper and electronic format.

Financial Institution

  • An institution significantly engaged in financial activities, which include:
    • lending, exchanging, transferring, investing for others, or safeguarding money or securities. These activities cover services offered by lenders, check cashers, wire transfer services, and sellers of money orders.
    • providing financial, investment or economic advisory services. These activities cover services offered by credit counselors, financial planners, tax preparers, accountants, and investment advisors.
    • brokering loans.
    • servicing loans.
    • debt collecting.
    • providing real estate settlement services.
    • career counseling (of individuals seeking employment in the financial services industry).

Financial Product or Service

  • A financial product or service covered under the GLB Act includes the following:
    • offering student, faculty or staff loans;
    • making, acquiring, brokering, or servicing loans or other extensions of credit;
    • real estate and personal property appraising;
    • arranging commercial real estate equity financing;
    • collection agency services; and
    • credit bureau services.

Consumer

  • Someone who obtains or has obtained a financial produce or service from a financial institution that is to be used primarily for personal, family or household purposes, or that person’s legal representative. Examples include:
    • making a wire transfer; or
    • applying for a loan, whether or not the individual actually obtains the loan.

Customer

  • Customers are consumers who have a continuing relationship with a financial institution. Examples include:
    • opening a credit card account with a financial institutions; or
    • using the services of a mortgage broker to secure financing.

Non-Public Personal Information

  • Any personal 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. Examples include:
    • any information an individual gives to get a financial product or service (for example, name, address, income, Social Security number, or other information on an application);
    • any information received about an individual from a transaction involving an institution’s financial product(s) or service(s) (for example, the fact that an individual is a consumer or customer, account numbers, payment history, loan or deposit balances, and credit or debit card purchases); or
    • any information received about an individual in connection with providing a financial product or service (for example, information from court records or from a consumer report).