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A mortgage broker discovers that their computer system has been logging and storing customers' Social Security numbers in plain text in system backup files that are accessible to IT staff who don't normally handle customer information. Under GLBA's Safeguards Rule, this situation represents:

Correct Answer

B) A violation requiring immediate remediation and access controls

Under GLBA's Safeguards Rule, financial institutions must implement access controls that limit access to customer information to those employees who need it to perform their job functions. Storing sensitive information like SSNs in plain text accessible to unnecessary personnel violates the principle of least privilege and requires immediate remediation.

Answer Options
A
Acceptable practice since IT staff are employees
B
A violation requiring immediate remediation and access controls
C
Compliance as long as the IT staff sign confidentiality agreements
D
A minor issue that can be addressed in the next system upgrade

Why This Is the Correct Answer

Under GLBA's Safeguards Rule, financial institutions must implement access controls that limit access to customer information to those employees who need it to perform their job functions. Storing sensitive information like SSNs in plain text accessible to unnecessary personnel violates the principle of least privilege and requires immediate remediation.

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