Data Safeguards Generally. (a) Servicer shall establish and maintain safeguards against the disclosure, destruction, loss or alteration of Navient Data in the possession of Servicer, Servicer Agents or Servicer Personnel that are no less rigorous than those set forth in Exhibit F, and that are no less rigorous than those maintained by Servicer for its own information of a similar nature or for other student loan servicing customers of Servicer. Servicer Personnel shall not attempt to access, and shall not access or allow access to, Navient Data to which it is not entitled or beyond that which is required for the performance of the Services by Servicer Personnel. Servicer shall institute industry “best practices” systems security measures to guard against the unauthorized access, alteration, destruction or loss of Navient Data.
Data Safeguards Generally. 2.2.1 Design-Builder personnel shall not attempt to access, and shall not access or allow access to, Customer Data to which it is not entitled or that is not required for the performance of the Services by Design-Builder personnel. Design-Builder shall implement security measures consistent with its responses to the “Cybersecurity Risk Assessment Survey” (Exhibit B hereto) to guard against the unauthorized access, alteration, destruction and loss of Customer Data. Design-Builder shall review Exhibit B on at least a quarterly basis to assess updates that are necessary thereto to align Exhibit B with Industry Standards. Except with respect to updates necessary to align with Industry Standards, with respect to which Design-Builder shall promptly notify Owner in writing prior to effecting, Design-Builder shall not take any action or omit to take any action that would be inconsistent with its responses in Exhibit B or cause such responses to be untrue without Owner’s prior written consent.
