Gramm-Leach-Bliley Act (GLBA) Information Security Program Templates Free Download


Download Free Gramm-Leach-Bliley Act Information Security Program Templates. This templates covers:

1. Risk Identification and Assessment.
The Institution intends, as part of the Program, to undertake to identify and assess external and internal risks to the security, confidentiality, and integrity of nonpublic financial information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information. In implementing the Program, the Program Officer will establish procedures for identifying and assessing such risks in each relevant area of the Institution's operations, including:

"Employee training and management.
The Program Officer will coordinate with representatives in the Institution's [Human Resources and Financial Aid offices] to evaluate the effectiveness of the Institution's procedures and practices relating to access to and use of student records, including financial aid information. This evaluation will include assessing the effectiveness of the Institution's current policies and procedures in this area, including [list here any relevant employee manuals or student record information policies and procedures].

"Information Systems and Information Processing and Disposal.
The Program Officer will coordinate with representatives of the Institution's [Department of Information Technology or other relevant department] to assess the risks to nonpublic financial information associated with the Institution's information systems, including network and software design, information processing, and the storage, transmission and disposal of nonpublic financial information. This evaluation will include assessing the Institution's current polices and procedures relating to [Acceptable Use of the Institution's network and network security, document retention and destruction]. The Program Officer will also coordinate with the Institution's [Department of Information Technology] to assess procedures for monitoring potential information security threats associated with software systems and for updating such systems by, among other things, implementing patches or other software fixes designed to deal with known security flaws.

"Detecting, Preventing and Responding to Attacks.
The Program Officer will coordinate with the Institution's [Department of Information Technology and other relevant units] to evaluate procedures for and methods of detecting, preventing and responding to attacks or other system failures and existing network access and security policies and procedures, as well as procedures for coordinating responses to network attacks and developing incident response teams and policies. In this regard, the Program Officer may elect to delegate to a representative of the [Department of Information Technology] the responsibility for monitoring and participating in the dissemination of information related to the reporting of known security attacks and other threats to the integrity of networks utilized by the Institution.

2. Designing and Implementing Safeguards.
The risk assessment and analysis described above shall apply to all methods of handling or disposing of nonpublic financial information, whether in electronic, paper or other form. The Program Officer will, on a regular basis, implement safeguards to control the risks identified through such assessments and to regularly test or otherwise monitor the effectiveness of such safeguards. Such testing and monitoring may be accomplished through existing network monitoring and problem escalation procedures.

3. Overseeing Service Providers.
The Program Officer shall coordinate with those responsible for the third party service procurement activities among the [Department of Information Technology] and other affected departments to raise awareness of, and to institute methods for, selecting and retaining only those service providers that are capable of maintaining appropriate safeguards for nonpublic financial information of students and other third parties to which they will have access. In addition, the Program Officer will work with the [Office of General Counsel or other designated institutional official] to develop and incorporate standard, contractual protections applicable to third party service providers, which will require such providers to implement and maintain appropriate safeguards. Any deviation from these standard provisions will require the approval of the [Office of General Counsel or other designated institutional official]. These standards shall apply to all existing and future contracts entered into with such third party service providers, provided that amendments to contracts entered into prior to June 24, 2002 are not required to be effective until May 2004.

4. Adjustments to Program.
The Program Officer is responsible for evaluating and adjusting the Program based on the risk identification and assessment activities undertaken pursuant to the Program, as well as any material changes to the Institution's operations or other circumstances that may have a material impact on the Program.

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