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					                    Gramm-Leach-Bliley Act (GLBA) Reference Guide

            Data                          Activity                      GLBA?                    Rationale
1 Address                Non-GLB activity (not associated with           No       Only protected under GLB when this
                         providing a financial service or product)                data is collected along with financial
                                                                                  information, since this allows the
                                                                                  University to tie individuals to their
                                                                                  personal information. 16 C.F.R. §
                                                                                  313.3(n)(1)
2 Name                   Non-GLB activity (not associated with             No     Only protected under GLB when this
                         providing a financial service or product)                data is collected along with financial
                                                                                  information, since this allows the
                                                                                  University to tie individuals to their
                                                                                  personal information. 16 C.F.R. §
                                                                                  313.3(n)(1)
3 Phone Number           Non-GLB activity (not associated with             No     Only protected under GLB when this
                         providing a financial service or product)                data is collected along with financial
                                                                                  information, since this allows the
                                                                                  University to tie individuals to their
                                                                                  personal information. 16 C.F.R. §
                                                                                  313.3(n)(1)
4 Any Sensitive Data *   Credit card transactions not involving a          No     Information not gathered "to obtain",
                         financial product or service                             "resulting from a transaction
                                                                                  involving" or "in connection with
                                                                                  providing" a defined financial
                                                                                  product or service. 16 C.F.R. §
                                                                                  313.3(o)(1)
5 Any Sensitive Data *   Credit card transactions involving a             Yes     Information is gathered "to obtain",
                         financial product or service                             "resulting from a transaction
                                                                                  involving" or "in connection with
                                                                                  providing" a defined financial
                                                                                  product or service. 16 C.F.R. §
                                                                                  313.3(o)(1)
6 Any Sensitive Data *   Extending credit to customers (invoices           No     Information not gathered "to obtain",
                         with payments terms of net 30 days or                    "resulting from a transaction
                         longer) for tangible goods or nonfinancial               involving" or "in connection with
                         services; interest may or may not be                     providing" a defined financial
                         charged                                                  product or service. 16 C.F.R. §
                                                                                  313.3(o)(1)
7 Any Sensitive Data *   Extending credit to customers via layaway         No     Occasional layaway and deferred
                         or deferred payment plans                                payment plans do not create a
                                                                                  GLBA covered activity. 16 C.F.R. §
                                                                                  313.3(k)(4)(i)
8 Any Sensitive Data *   Employee travel advances or advances of           No     The employee receives the advance
                         funds for extended work abroad                           in his/her capacity as an employee,
                                                                                  thus this is not considered the
                                                                                  extension of credit to an individual.
9 Any Sensitive Data *   Payroll advances (or "loans") to                  No     The funds being paid to the
                         employees to ease the burden of a                        employee are really payroll for
                         cancelled payroll payment due to an error                services rendered during the pay
                         in payroll processing                                    period.




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            Data                              Activity                   GLBA?                  Rationale
10 Any Sensitive Data *   9/12 program which, in some cases,              No       The funds being paid to the
                          effectively advances funds to faculty,                   employee are really payroll for
                          particularly if faculty does not begin to                services rendered or to be rendered.
                          teach until September
11 Any Sensitive Data *   Tax preparation services or tax advice,          Yes     Considered to be a financial service.
                          either for a fee or free of charge
12 Any Sensitive Data *   Credit counseling or advice, either for a        Yes     Considered to be a financial service.
                          fee or free of charge
13 Any Sensitive Data *   Financial advisory services, either for a        Yes     Considered to be a financial service.
                          fee or free of charge
14 Any Sensitive Data *   Career counseling services for those             Yes     Technically this is covered under the
                          seeking employment in finance,                           GLBA, but the data collected is
                          accounting or auditing                                   already deemed private under a
                                                                                   higher FERPA standard; the GLBA
                                                                                   imposes no additional requirements.
15 Any Sensitive Data *   Purchasing Card (P-Card)                          No     The purchasing card is used by
                                                                                   employees for University business.
16 Any Sensitive Data *   Employee Assistance Program (EAP), to            Yes     Covered if the service is rendered by
                          the extent it deals with personal financial              the University; at present, EAP
                          advice to an individual                                  refers all staff to an outside agency
                                                                                   (Lutheran Social Services) for
                                                                                   financial advice.
17 Any Sensitive Data *   Financial aid that takes the form of need         No     Because these kinds of financial aid
                          or merit-based scholarships and                          are not loans to be repaid, and do
                          fellowships                                              not involve the charging of interest,
                                                                                   they are not considered a financial
                                                                                   product.
18 Any Sensitive Data *   Fee waivers, wherein tuition or student           No      A waiver, which typically takes the
                          fees are either reduced or not charged at                form of writing off or reducing an
                          all                                                      amount otherwise owed, is not an
                                                                                   extension of credit and thus is not
                                                                                   considered a financial product or
                                                                                   service.
19 Any Sensitive Data *   GE Capital card                                   No     This is a commercial (rather than
                                                                                   consumer) lending situation, thus
                                                                                   the GLBA does not apply.
20 Any Sensitive Data *   Write-offs of amounts owed for non-               No     This does not involve the extension
                          financial products or services                           of credit, per se.
21 Any Sensitive Data *   Loan programs of various flavors                 Yes     In these situations, the University is
                          (mortgages, personal loans, Federal                      either providing a financial product
                          direct lending) where the University is not              directly, or is involved indirectly with
                          the lender, but rather facilitates the                   a third party provider.
                          process (such as putting the lender in
                          touch with the borrower, providing names
                          to a lender, etc.)
22 Any Sensitive Data *   Agency funds                                      No     The GLBA covers individuals, and
                                                                                   because agency funds normally
                                                                                   involve organizations rather than
                                                                                   individuals, this is not a covered
                                                                                   activity.




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            Data                               Activity                    GLBA?                   Rationale
23 Any Sensitive Data *     Insuring, guaranteeing or indemnifying          No       Not a financial product, in the
                            against loss, harm, damage, illness,                     University context of overseeing
                            disability or death                                      medical and dental plans.
24 Any Sensitive Data *     Payroll setup and processing                      No     Not a financial product; normal
                                                                                     payroll processing.
25 Any Sensitive Data *     Guest lecturers: if funds are wired, bank         No     Normal payables processing; no
                            account info may be needed; SSN                          financial product involved.
                            needed for tax purposes
26 Any Sensitive Data *     Student field trips - driver's license info       No     Not a financial product.
                            required for van drivers on field trips
27 Any Sensitive Data *     Contract for Professional Services -              No     Not a financial product.
                            required for non-University contractors; in
                            some cases, income information may be
                            included on a visa application for foreign
                            students
28 Any Sensitive Data *     Laptop leasing program (as currently              No     Laptop leasing activity has been
                            structured by UMC)                                       deemed to be an operating lease
                                                                                     program because the UMC campus
                                                                                     does minimal work on the
                                                                                     computers.
29 Any Sensitive Data *     Tuition and student fees collection activity      No     Information not gathered "to obtain",
                                                                                     "resulting from a transaction
                                                                                     involving" or "in connection with
                                                                                     providing" a defined financial
                                                                                     product or service. 16 C.F.R. §
                                                                                     313.3(o)(1)

             * Sensitive Data includes the following:
                  Account balance
                  ACH number
                  Bank account number
                  Credit card number
                  Credit rating
                  Date of birth
                  Location of birth
                  Driver’s license information
                  Income history
                  Payment history
                  Social security number
                  Tax return information




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