Skip to main content

Element451 & the Gramm-Leach-Bliley Act

Learn More About Your Element451 Data and GLBA

Written by Eric Range
Updated yesterday

Overview

Element451’s platform is designed primarily to manage student engagement, admissions, enrollment and retention data, including limited financial metadata such as payment status and financial aid award summaries.

These native data elements generally fall under education record protections rather than GLBA financial information requirements.

Institutions remain responsible for determining what data they choose to store within custom fields or integrations and ensuring compliance with applicable regulations. Element451 supports customers with a SOC 2 Type II–validated security framework designed to safeguard sensitive information stored within the platform.


Element451 Native Data Models

Element451 is an enrollment and success CRM & AI workforce platform designed to manage student engagement, admissions, retention and communications. The platform may store limited financial-related metadata in support of admissions and enrollment processes.

Native data elements that may exist in Element451 include:

  • Application fees, event fees and form payment metadata

    • transaction amount

    • processor transaction ID

    • success/failure status

  • Financial aid award summaries

    • scholarship awards

    • grant awards

    • loan award amounts

  • Student identifiers

    • which may include Social Security Numbers where institutions use them for identity matching

Element451 does not natively store or process:

  • credit card numbers or payment credentials

  • bank account or routing numbers

  • financial aid application data (FAFSA or ISIR)

  • tax return or income documentation

  • financial verification documents

Any payment data, card holder data and credit card details are handled through PCI complaint third-party payment processors, and financial aid application processing typically occurs in institutional financial aid systems.

Because of this design, the data stored in Element451 generally consists of education records and operational metadata, not Nonpublic Personal Financial Information (NPI) as defined under the Gramm-Leach-Bliley Act (GLBA).


Financial Aid Award Data

Financial aid information stored in Element451 natively represents award outcomes, such as:

  • scholarship amounts

  • grant awards

  • loan award values

This information reflects institutional aid decisions communicated to students, rather than the underlying financial eligibility data used to determine those awards.

As such, these records are generally treated as student education records governed by FERPA, rather than GLBA-regulated financial information.


Custom Defined Fields and Data Entry

Element451 allows institutions to create custom fields and store additional data within the platform

Institutions may choose to store information that could fall within GLBA-regulated financial information, such as:

  • income information

  • tax transcript data

  • FAFSA-derived financial eligibility data

  • bank account details

  • financial aid application materials

If such information is stored in the platform through institution-defined fields, uploads, integrations, or policy the institution remains responsible for determining the appropriate regulatory treatment and compliance obligations associated with that data, although Element451 strong encourages partners to keep that information in a platform natively designed to store such sensitive data.

Ultimately, customers are responsible for ensuring that data entered into the platform aligns with their institutional compliance policies and regulatory obligations, particularly those outside of the scope of native fields and Element451 functionally.


Security Safeguards

Element451 maintains a SOC 2 Type II audited security program, which includes safeguards designed to protect sensitive data and ensure strong operational security.

These protections include controls such as:

  • access controls and role-based permissions

  • encryption of data in transit and at rest

  • security monitoring and logging

  • vulnerability management and penetration testing

  • incident response procedures

  • vendor risk management

  • secure infrastructure and change management processes

While Element451 is not designed as a GLBA-regulated financial system, many of the technical and operational safeguards required under the GLBA Safeguards Rule are already addressed through the platform’s SOC 2 Type II security controls.

Did this answer your question?