Great Lakes Privacy Policy for Customer Information

GREAT LAKES PRIVACY POLICY FOR CUSTOMER INFORMATION

It is the policy of Great Lakes Educational Loan Services, Inc. ("Great Lakes") to maintain the confidentiality of all information regarding the student loans ("Loans") and the student loan borrowers ("Borrowers") of its customers, its customers' business information and the personal information (including but not limited to the Social Security Numbers) of its employees ("Confidential Information"). Great Lakes uses and discloses the Confidential Information of its customers only in connection with providing the services they have requested ("Services") and as permitted by law. Great Lakes uses and discloses the Confidential Information of its employees only in connection with the employment relationship, to provide employee benefits, and as permitted by law. The unlawful disclosure of Social Security Numbers by any employee is strictly prohibited. Great Lakes will comply with the Gramm-Leach-Bliley Privacy Act, the Fair Credit Reporting Act and all other applicable federal and state privacy laws.

Great Lakes maintains physical, electronic and procedural safeguards designed to protect against the unauthorized disclosure of Confidential Information that is in its possession or control. Great Lakes limits access to Confidential Information (including but not limited to Social Security Numbers) to protect against its unauthorized use. Employees are given access to Confidential Information (including, but not limited to, Social Security Numbers) only as necessary to perform their jobs. Confidential Information is disposed of in a way that destroys, erases or makes unreadable the information prior to disposal.

Great Lakes may use a third party to perform services such as printing payment coupons and sending ACH transmissions. When it does so, it gives the third party only the information needed to perform the requested service. The third party will be required to enter into a confidentiality agreement with Great Lakes before any Confidential Information is provided to the third party or the contract with the third party will include provisions requiring the third party to maintain the confidentiality of all Confidential Information that Great Lakes provides to the third party, to safeguard such information from unauthorized access, and to dispose of such information in a secure manner.

Great Lakes obtains consumer reports in connection with certain Loans. Great Lakes will maintain the confidentiality of these consumer reports and take reasonable measures to protect against unauthorized access to or use of the consumer reports in connection with their disposal.

All employees receive privacy and security training from time to time and not less than annually.

Privacy Policy 07/12/10

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