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Security
Information Security Program
GLBA-FTC Safeguards-Title IV
Security Awareness Program: Title IV Data
Security Awareness Program: Title IV Data
Tags
TitleIV-GLBA-SafeguardsRule-ComplianceDocumentation
LETU maintains a security awareness program for Title IV data
led by the Senior Director of Student Financial services
that includes:
Annual documented training of all personnel handling Title IV data
Annual review of this program
Review and sign off by the LeTourneau Information Technology department in consultation with the functional area and in compliance with LETU Policy
6.6 Technology Purchases and Support
for any software or system which handles
PII
/ Title IV data and for the administration and maintenance plan for that system including incorporation of LETU's MFA, DLP and other Information Security
Safeguards
and measures.
Implementation of
Data Loss Prevention (DLP)
systems
Training for personnel shall include at a minimum:
Understanding of Student Aid Internet Gateway (SAIG) agreement response to a suspected or known breach (
How do I report a Breach
)
How to ensure that all users are aware of and comply with all of the requirements to protect and secure data from Departmental sources using SAIG
The Student Aid Internet Gateway (SAIG) Agreement requires that as a condition of continued participation in the federal student aid programs Title IV schools report suspected/actual data breaches
Title IV schools must report
on the day of detection
when a data breach is even suspected
The Department has the authority to fine institutions that do not comply with the requirement to self-report data breaches; up to
$54,789 per violation
per 34 C.F.R. ยง 36.2
The Department has reminded all institutions of this requirement through Dear Colleague Letters (
GEN 15-18
,
GEN 16-12
), electronic announcements, and the annual FSA Handbook.
Understanding of PII and the
LETU Data Classification Policy (Policy 6.2)
Acceptable Use of Technology Systems at LETU (Policy 6.1)
Documentation of agreement to all of the above
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Related Articles (1)
Information Security Program: Controls, Safeguards and Compliance (incl Title IV Department of Education requirements)
LeTourneau University Information Security Program: Controls, Safeguards and Compliance
(incl compliance elements for Title IV/GLBA Safeguards: Department of Education Requirements)
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Check out this article I found in the LETU IT Portal knowledge base.<br /><br /><a href="https://servicedesk.letu.edu/TDClient/2460/Portal/KB/ArticleDet?ID=123645&SIDs=10929">https://servicedesk.letu.edu/TDClient/2460/Portal/KB/ArticleDet?ID=123645&SIDs=10929</a><br /><br />Security Awareness Program: Title IV Data