Let's face it security is major issue when Student Financial Advisors refinance student loans. Student Financial Advisors is committed to ensuring the security and confidentiality of student loan records and information, and to protecting such records from any unauthorized access, or from any other threats or hazards to the security and integrity of those records during the process of refinancing student loans.

We understand the social security number has a unique status as a privacy risk, and that no other form of personal identification plays such a significant role in linking records that contain sensitive information must remain confidential.

As such, we subscribe to the Federal Trade Commissions Standards for Safeguarding Customer Information and to the Recommended Practices for Protecting the Confidentiality of Social Security Numbers from the Office of Privacy Protection, California Department of Consumer Affairs, as guidelines in developing our policy with respect to protecting sensitive borrower information.

In concert with the Federal Trade Commissions Standards for Safeguarding Customer Information, we accept the definition of the term "service provider" to mean any person or entity that receives, maintains, processes, or otherwise is permitted access to customer information through its provision of services directly to a financial institution that is subject to the Rule" (the Financial Privacy Rule in the Gramm-Leach-Bliley Act).

As a service provider, Student Financial Advisors has developed and implemented a comprehensive information security program that contains administrative, technical and physical safeguards to achieve the following objectives:

• Protecting the security and confidentiality of client information.
• Protecting against any anticipated threats and/or hazards to the security or integrity of such information.
• Protecting against unauthorized access to and use such information that could result in substantial harm or inconvenience to any customer.

The essential elements of the information security program are:

A member of Student Financial Advisors, is responsible for coordinating the program to maintain both accountability and adequate safeguards.

Risk Assessment and Safeguard Control - Student Financial Advisors has identified reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of borrower information having the potential to compromise such information. We have identified potential risks in three areas that are particularly relevant to information security:

• Training and management of personnel,
• Administering the processing, storage, transmission and disposal of all forms of information,
• Preventing, detecting and responding to attacks, snooping, intrusions, or other electronic systems failures.

To control these risks, we have instituted the following information security program safeguards with respect to personnel, information handling and computer systems.

Student Financial Advisors provides training and written guidelines to employees detailing their responsibilities when handling Social security numbers; any non-compliance with proper policy and practices for protecting Social security numbers; any non-compliance with proper policy and practices for protecting Social security numbers invokes strict disciplinary action.

We limit access to any records containing social security numbers to only those employees with a need-to-know for the performance of their duties; currently only Student Financial Advisors members have access to these records.

Social Security numbers are used to look up the outstanding loan balances of students and graduates. The social security numbers are entered into the National Student Loan Data System or NSLDS. The National Student Loan Data System is the database for federal student financial aid where students can find out about the aid they have received. If the student has just applied for a consolidation loan the consolidation typically will not show up for a few weeks. The National Student Loan Data System receives data from schools, guaranty agencies, and the U.S. Department of Education.