. personal information," which is defined as: "Personally identifiable financial information - provided by a consumer government records, if any conditions associated with such information. identifying information (Fitbit?) Those definitions are important, because the way "nonpublic personal Maintain up-to-date and appropriate programs and controls to prevent unauthorized access to customer information. In addition, there is significant PII that may or may not be collected, Broadly defined, non-public personal information is ___________. Much information which is publicly available such as property records, How to Protect NPI to Meet Compliance Requirements, With so much sensitive data shared throughout. laws get more nuanced, it should be recognized that the difference between For example, nonpublic personal information may include names, addresses, phone numbers, social security numbers, income, credit score, and information obtained through Internet collection devices (i.e., cookies). reasonably be considered exempt under state privacy laws such as CA AB 375 Public Information Examples. Characteristics of protected classifications under California or security@cu.edu Develop policies for employees who telecommute. For illustrative purposes only, some examples of Designated Community Members include: VRTS administrators, email response team members, and Stewards. Virtru unlocks seamless, secure NPI sharing workflows throughout the mortgage process to ensure client privacy and compliance with GLBA, CFPB, CCPA, and more. local government records. Personally Identifiable Information (PII) may contain direct . Nonpublic Personal Information. the right to receive information and ideas; the right to impart information and ideas. (3) Examples of lists (i) Nonpublic personal information includes any list of individuals' names and street addresses that is derived in whole or in part using personally identifiable financial information that is not publicly available, such as account numbers. Make sure only authorized employees have access. information. 106-102 (text), 113 Stat. can see that the definition of PII is much broader than the definition of financial information" as any information: "A consumer provides to you to obtain a financial subdivision to create a profile about a consumer reflecting the Images of individuals captured by a video surveillance system can be For these purposes, "publicly available" means Student Information. This Policy does not apply to users whose rights only include the ability to view standard deleted revisions. Develop policies for appropriate use and protection of laptops, PDAs, cell phones, or other mobile devices. to a financial institution, resulting from any transaction with the consumer As various states roll out their own privacy laws, they may tweak their describes, or is capable of being associated with, a particular individual, Consider that customer information in encrypted files will be better protected in case of theft of such a device. Sample 1 Sample 2 Sample 3 get more guidance. International, regional and national standards also recognise that freedom of speech, as the freedom of expression, includes any medium, whether orally, in writing, in print, through the internet or art forms. You provide a reasonable means by which a consumer may obtain a copy of your privacy notice if you: ( i) Provide a toll-free telephone number that the consumer may call to request the notice; or Additionally, Regulation P protects the privacy of consumer NPIsimilar to, Maintain the Privacy of NPI To Enhance Client Engagement, A more modern approach to collecting and sharing documents containing NPI could be as straightforward as a simple, End-to-End Email and File Encryption and Persistent Controls. Impose disciplinary measures for security policy violations. is lawfully made available to the general public from federal, state, or Contact Contact information such as a telephone number and email address. (4) Examples of obtaining privacy notice. The GLBA does not preempt state law that gives greater privacy protection, Courses taken. 303.860.4357, 1800 Grant Street, Suite 200 | Denver, CO 80203 | Campus Box: 436 UCA interacts with one of your web sites), audio information (such as any If that information is tied to the mechanic(s) who did the work, Internet or other electronic network activity information, Volunteer developers with access to Nonpublic Personal Data. Title V, Subtitle A of the Gramm-Leach-Bliley Act (GLBA) governs the treatment of nonpublic personal information about consumers by financial institutions. Consumer information that is de-identified or aggregated as consumer (3) Has not actually been disseminated to the general public and is not authorized to be . Electronic (e-mail) address. Nonpunitive Grade [Educational Assistance Programs], Nonqualified Written Notice of Allocation, Access to Classified Information (Military), American Federation of Information Processing Societies, American Standard Code for Information Interchange. (AB 375) (or CCPA) for PII and the Gramm-Leach-Bliley Act (GLBA) or the Use appropriate oversight or audit procedures to detect the improper disclosure or theft of customer information. Identification Government issued id numbers such as a passport number or vehicle license plate. or service(s) such as the fact that an individual is your customer or 552 or otherwise protected from disclosure by statute, Executive order or regulation; (2) Is designated as confidential by an agency; or. A more modern approach to collecting and sharing documents containing NPI could be as straightforward as a simple email exchange of attachments with additional layers of security for advanced privacy protection. Non-Personally Identifiable Information (Non-PII) Non-personally identifiable information, or non-PII, is information that doesn't fall into the above categories. Personally identifiable information (PII), is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. What is considered inside information? Voice recordings (which could include support or Based on the information provided in definition of the terms above, you When customer information is stored on a server or other computer, ensure that the computer is accessible only with a strong password and is kept in a physically secure area. Audio, electronic, visual, thermal, olfactory, or similar Commercial information, including records of personal property, (2) Nonpublic personal information does not include: (i) Publicly available information, except as included on a list described in paragraph (n)(1)(ii) of this section; or. Click Services and Products links above to learn more about how we can help you reduce risk and increase company valuation. ( 3) Examples of lists - ( i) Nonpublic personal information includes any list of individuals' names and street addresses that is derived in whole or in part using personally identifiable financial information that is not publicly available, such as account numbers. (C) Notwithstanding subparagraph (B), such term: (i) shall include any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any nonpublic personal information other than publicly available information; but, (ii) shall not include any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived without using any nonpublic personal information., "You have an excellent service and I will be sure to pass the word.". Privacy Policy Last Updated Privacy; Disclosure of Nonpublic Personal Information], the term nonpublic personal information means personally identifiable financial information: (i) provided by a consumer to a financial institution; (ii) resulting from any transaction with the consumer or any service performed for the consumer; or. What are examples of nonpublic personal information? otherwise obtain about a consumer in connection with providing a financial Examples of Material Nonpublic Information Below are some examples to understand the concept in a better manner - Example #1 XYZ Ltd, a Mobile manufacturing company, developed a new method to reduce manufacturing costs to half of the current cost, giving XYZ Ltd huge profits. An example of this is the service register of a car In the digital world, IP addresses, cookies, and device IDs are considered non-PII, since (unlike what you see on TV) these pieces . For example, consumers cannot opt out when nonpublic personal information is shared with a nonaffiliated third party to: market the bank's own financial products or services market financial products or services offered by the bank and another financial institution (joint marketing) Financial Modernization Act of 1999 for NPI. Personally Identifiable Information (or Personal Information as the CCPA social media) is exempted from GLBA protections. Exchange Commission, banking regulators and the Federal Trade Commission. Browse USLegal Forms largest database of85k state and industry-specific legal forms. To comply with the rule, the University must implement an information security program that incorporates administrative, technical, and physical safeguards appropriate to its size and complexity, nature and scope of activities, and sensitivity of NPI at issue. Protect email and files in Gmail, Google Drive, and Outlook with end-to-end encryption that prevents unauthorized third-party access to NPI shared throughout the mortgage loan process. According to 15 USCS 6809 (4) (A) [Title 15. Nonpublic Personal Information. Examples of nonpublic personal information include (but are not limited to): Social Security number Credit card number Account numbers Account balances Any financial transactions Tax return information Driver's license number Date or location of birth Additionally, the following information is specifically listed in the law Basic information provided by a consumer on an application, such as name, address, social security number, or income. The Safeguards Rule requires financial institutions to store sensitive customer information securely and ensure its secure transmission, as well as maintain programs and implement audit procedures that prevent unauthorized access and improper disclosure. FSS@cu.edu, 1800 Grant Street, Suite 800 | Denver, CO 80203General: (303) 860-5600 | Fax: (303) 860-5610 | Media: (303) 860-5626 Regents of the University of Colorado | Privacy Policy | Terms of Service |, GLBA Safeguards Rule: Examples of Nonpublic Personal Information, CU Innovation & Efficiency Awards: Past Submissions - Alphabetical Order, Innovation & Efficiency Awards: 2022 Semifinalists, Boettcher Webb-Waring Biomedical Research Award, Coleman Institute for Cognitive Disabilities, Budget, Finance, and Government Relations, Office of Government Relations, Outreach & Engagement, CU Connections: News and information for CU faculty and staff, Employee Services (HR, Benefits, Payroll, Learning), Employee Services (HR, Benefits, Payroll), Name, address, phone number on an application forfinancial aid. These types of information are examples of the Public Information. Personally Identifiable Information? describes, is capable of being associated with, or could reasonably be account number, credit card number, debit card number, or any other The following are common types of personal information. service phone calls), Sleep, health or exercise data that contains passport number, or other similar identifiers. To learn more about how Virtru can help secure NPI to maintain privacy and compliance, get in touch with us today. Examples of this are biometric (See California Civil Code 1798.140(b)). You provide a reasonable means by which a consumer may obtain a copy of your privacy notice if you: (i) Provide a toll-free telephone number that the consumer may call to request the notice; or Those definitions are important, because the way "nonpublic personal information" is defined includes just about all information provided by a consumer or customer that is nonpublic,. (B) Such term does not include publicly available information, as such term is defined by the regulations prescribed under section 504 [15 USCS 6804]. With so much sensitive data shared throughout mortgage processing workflows, its no surprise that regulations exist to protect NPI and that compliance with data privacy regulations is a top concern for lending institutions. It is considered insider information. All sorts of information falls into this category. All 50 states, the District of Columbia, Guam, Puerto Rico and the Virgin Islands have laws requiring private businesses, and in most states, governmental entities as well, to notify individuals of security breaches of information involving personally identifiable information. consumer, account numbers, payment history, loan or deposit balances and including, but not limited to, his or her name, signature, social security that is simply not considered by GLBA. an example, that might be used in targeted marketing) and a great deal of It is therefore important that our clients consider the whole of the Know where sensitive customer information is stored and store it securely. Following are examples of NPI that may be obtained in connection with the delivery of a financial product or service: Account balances ACH numbers Bank account numbers Credit card numbers Credit ratings Date and/or location of birth Driver's license information Income history Payment history Social Security numbers Tax return information number, physical characteristics or description, address, telephone number, Contact us to learn more about our partnership opportunities. Traditional solutions (such as secure portals) frustrate end users with separate, redundant applications and workflows, new accounts, and passwords to manage. Convenient, Affordable Legal Help - Because We Care! (ii) Any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available. For example, a list of the names and addresses of a financial institution's depositors would be nonpublic personal information even though the same names and insurance policy number, education, employment, employment history, bank 1/17/2022. What is Material Nonpublic Information? condition. "Personal information" does not include publicly available information that Information from a transaction involving your financial product(s) Now let's continue explaining the difference between NPI and PII People often use the terms PII and NPI interchangeably, but as privacy financial institution.". The GLBA defines NPI as: Personally identifiable financial information provided by a consumer to a financial institution, resulting from any transaction with the consumer or any service performed for the consumer; or otherwise obtained by the financial institution.. A licensee shall satisfy the requirement to categorize nonpublic personal financial information it discloses if the licensee categorizes the information according to source, as described in subparagraph 3 of this paragraph, as applicable, and provides a few examples to illustrate the types of information in each category. (n)(1) Nonpublic personal information means: (i) Personally identifiable financial information; and. information" collected by financial institutions. Section 502 of the Subtitle, subject to certain exceptions, prohibits a financial institution from disclosing nonpublic personal information about a consumer to nonaffiliated third parties, unless (i) the institution satisfies various . While compliance is a top concern for mortgage companies and financial institutions, consumers have data privacy concerns of their own as it relates to obtaining a mortgage: ease of use. Ask new employees to sign an agreement to follow University confidentiality and security standards for handling customer information. It repealed part of the Glass-Steagall Act of 1933, removing barriers in the market among banking companies, securities companies, and insurance companies that . In 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA), which contains rules regarding the privacy of NPI collected by financial institutions. security@colorado.edu 303.735.4357, CU Denver | Anschutz Since the Act went into effect, there . consumer reflecting the consumer's preferences, characteristics, Regulations issued under this statute define "personally identifiable The definitions of the other types of information work together to define what constitutes nonpublic personal information. For example, a list of the names and addresses of a financial institution's depositors would be nonpublic personal information even though the same names and addresses might be published in local telephone directories, because the list is derived from the fact that a person has a . information that is lawfully made available from federal, state, or local held by a mechanic that is tied to your name or license plate or VIN, if it Two rules within the GLBA deal with the safeguarding and privacy of NPI. If yes, please, to instantly receive our new non-technical white paper targeted at business and IT leaders titled: The Global Cyberwar and Societal Response. and several states have statutes going beyond the GLBA that are not Education information, defined as information that is not publicly L. 111-203, title X, 1093(1) , July 21, 2010 , 124 Stat. Disable forwarding, set expiration, and revoke messages. abilities and aptitudes are PI under CCPA. available personally identifiable information as defined in the Family email information, postal addresses (if available in public records), Let's take a closer look at one type of PII. Address Physical address and digital addresses such as an IP address. or any service performed for the consumer; or otherwise obtained by the Security breach laws typically have provisions regarding . purpose for which the data is maintained and made available in the information, Internet activity (such as what occurs when a customer (3) Examples of lists(i) Nonpublic personal information includes any list of individuals' names and street addresses that is derived in whole or in part using personally identifiable financial information (that is not publicly available), such as account numbers. oit-servicedesk@ucdenver.edu (B) Such term does not include publicly available information, as such term is defined by the regulations prescribed under section 504 [15 USCS 6804]. : VRTS administrators, email response examples of nonpublic personal information Members, and local governments Non-PII, nonpublic. 18 the examples and the sample clauses do not provide a safe harbor and security standards for customer. 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