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With identity theft on the rise, it is crucial that financial
aid administrators take responsibility for safeguarding the confidential
information of students and parents. Colleges and universities
are required to develop, implement and maintain a comprehensive
written information security program. Here are a few best practices:
- Designated employee(s) to coordinate the institution’s
information security program.
- A risk assessment to identify reasonable, foreseeable internal
and external risks to the security and integrity of customer
information. At a minimum, the risk assessment should include
consideration of risks in each of the following operational
areas: (1) employee training and management, and (2) information
systems detecting, preventing and responding to attacks, intrusions,
or other system failures.
- Information safeguards that are designed and implemented
to control the risks identified through the risk assessment
and that regularly test and monitor the effectiveness of the
safeguards, systems and procedures.
- A contractual arrangement that requires service providers
to implement and maintain appropriate safeguards for customer
information.
- Periodic evaluation and adjustment in the information security
system program, based on results of testing and monitoring.
Along with these elements, it is pertinent to recognize the importance
of staff training and the oversight of enforcing the procedures
for safeguarding information in daily staff contact with students.
Following are some tips that will help minimize the risk of confidential
information falling into the wrong hands:
- Make available the school’s information security policies
and procedures to all staff.
- Train staff, including temporary staff and work-study students,
on safeguarding confidential information.
- Create an information security and confidentiality agreement
that is signed by all employees and work-study students.
- Restrict access to confidential data to only staff needing
it to perform their job functions. Unauthorized users should
not have access to the data. View California Civil Code, Information
Practices Act, Section 1798.24 and other state-specific civil
codes, for criteria on disclosure of personal information to
the public.
- Avoid the use of Social Security numbers as passwords and
general identifiers on documents visible to the general public.
Select longer, difficult-to-guess passwords, keep them in a
secure area and change them frequently.
- Log off unattended workstations to ensure that confidential
data is not left displayed. Screensavers with timeout and password
features and the use of encryption are effective tools to reduce
the risk of unauthorized individuals acquiring confidential
information. Encryption uses a mathematical formula to scramble
your data into a format that is unreadable by anyone who is
not the authorized user.
- Include identity of staff completing transactions as a feature
on the school system.
- Secure confidential paper records and shred promptly when
no longer needed. At a minimum, school procedures must follow
the record retention requirements outlined in the Code of Federal
Regulations.
- Immediately delete system access (to either internal or external
systems) for former employees and have their computer hard drives
re-formatted. Requests to delete access to external systems
(i.e., National Student Loan Data System, Department of Education
and EDFUND) must be sent in a timely manner to each agency.
Each agency has its own policy on timely notification. EDFUND
requires institutions to provide notification within five working
days of the change.
- Educate students and parents on safeguarding personal information
to avoid identity theft. The Department of Education’s
Web source, www.ed.gov/misused,
provides a handout that can be used by students and parents.
We hope this reminder to those who handle institution records
that it is important to take every precaution possible to protect
others’ confidential information. The standard for handling
confidential information should be to treat it the same way you
would treat your own personal information!
©2006 EDFUND – REPRINT BY PERMISSION
ONLY.
FOR MORE INFORMATION ON EDFUND PRODUCTS AND SERVICES, CONTACT
MICHAEL AMALOO, SENIOR CLIENT RELATIONS MANAGER AT: 17011 LINCOLN
AVENUE, PMB 504, PARKER, CO 80134 – TELEPHONE: TOLL FREE
1.866.299.1741 – FAX: 303.840.2851- MAMALOO@EDFUND.ORG
- WWW.EDFUND.ORG.
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