Creating an information security plan isn’t just good practice for colleges and universities but a legal requirement under the Gramm-Leach-Bliley Act (GLBA) and in particular the Safeguards Rule of GLBA.
This federal law mandates that institutions handling financial aid or other sensitive student financial data must implement strong safeguards to protect it from unauthorized access, misuse, or breaches.
But knowing you need a plan is one thing—building a compliant, effective one is another.
So, in this guide, we’ll walk you through the essential components of a GLBA-compliant information security plan.
Step 1: Designate a Security Program Coordinator
The first step in creating a GLBA-compliant information security plan is assigning someone to be in charge. GLBA requires (under 314.4.(a) of the Federal Code of Regulations) institutions to designate a Security Program Coordinator, a person that will implement, enforce and oversee the school’s information security program.
This matters because, without a clear point of accountability, security efforts can become fragmented across departments. The coordinator ensures that all pieces—technical, administrative, and procedural—come together to form a unified plan and can lead the annual report to the Board or Regents, Provosts and/or Presidents of the institution.
For many universities, this responsibility falls under the Chief Information Security Officer (CISO) or someone in IT leadership. However, smaller institutions may delegate it to a qualified IT manager or external consultant.
Step 2: Conduct a Risk Assessment
Once you have a coordinator in place, the next critical step is to conduct a risk assessment. This helps you identify where sensitive financial data is stored, how it’s accessed, and what risks could lead to data breaches or unauthorized exposure.
Why does this step matter? Because GLBA compliance isn’t just about checking boxes—it’s about actively reducing the chances of a security incident while protecting the personal and financial data of students, faculty and other personnel in the institution’s systems. A risk assessment is how you discover your vulnerabilities before threat actors do.
To do it:
- Map your data flow: Identify what data is collected, where it’s stored (servers, cloud, emails, third parties that manage those), and who has access.
- Review internal systems: Evaluate your software, hardware, network security, and authentication methods.
- Assess external threats: Look at phishing risks, social engineering, and external breaches, especially from third-party vendors.
- Train Your Staff/Students (Security awareness training): A vigilant workforce and student body can help report suspicious activities and learn what to look for in phishing attempts.
- Document weaknesses: Note outdated software and hardware, poor password practices, or lack of backup procedures.
In fact, 90% of higher education institutions reported a significant increase in phishing attacks, showing just how real the threats are.
Step 3: Develop and Implement Safeguards
Now that you’ve identified your risks, it’s time to put safeguards in place to protect sensitive financial data. These safeguards align with the Safeguards Rule, and form the backbone of your GLBA-compliant information security plan and should address technical, administrative, and physical vulnerabilities.
Make sure to limit access to financial and student data based on roles. Use role-based permissions and regularly review user access. Moreover, make multi-factor authentication (MFA) a requirement for systems that store or access sensitive data. It’s one of the most effective ways to prevent unauthorized logins.
Store backups offsite or in the cloud, and make sure they’re encrypted and tested regularly. As for the physical aspects, lock the server rooms, control access to sensitive paperwork, and ensure devices are stored securely.
Step 4: Manage Third-Party Service Providers
Colleges often rely on third parties for financial aid processing, cloud storage, learning platforms, student information systems, building electronic security and locking, or payment systems. If these vendors mishandle data or are a victim of a breach, your institution is still held responsible.
Even if your internal systems are secure, a single weak link in a third-party vendor can jeopardize your entire compliance posture. That’s why the GLBA requires institutions to take steps to ensure that service providers with access to student financial data follow their security standards as defined in section 314.4(f)(3) of the Code of Federal Regulations.
On your part, all you need to do is choose partners that follow strong data protection policies and are familiar with GLBA or similar compliance requirements. Moreover, include clauses in contracts requiring them to maintain safeguards that meet or exceed your own.
Step 5: Create an Incident Response Plan
Even the best safeguards can’t eliminate every risk. That’s why a clear and actionable incident response plan (IRP) is required under the GLBA Safeguards Rule. It ensures your institution can react quickly to security breaches, protect student data, and meet legal reporting obligations.
Delays or confusion during a data breach can worsen the damage—both financially and reputationally. A well-structured IRP ensures that everyone knows exactly what to do if something goes wrong.
Here’s everything that should be included in your IRP:
- Roles and responsibilities: Identify who leads the response, who communicates with leadership, and who handles IT recovery.
- Detection and reporting protocols: Create a process for identifying, documenting, and reporting suspected breaches.
- Containment and mitigation steps: Outline how to isolate affected systems and stop the breach from spreading further.
- Communication plans: Include internal alerts, stakeholder notifications, and—if necessary—federal or state breach reporting.
- Post-incident review: Document what happened, evaluate your response, and update the plan to address any weaknesses.
Step 6: Train and Make Your Staff Aware
Technology alone can’t protect sensitive data—your people are your first (and sometimes weakest) line of defense. That’s why the GLBA requires ongoing training for all employees who handle or access student financial information.
According to KnowBe4’s 2023 report, phishing remains the top cause of data breaches in education, with human error involved in over 88% of incidents.
For this step, teach your staff how to spot fake emails, suspicious links, and manipulation tactics. Also, make sure the employees know how to report security issues immediately and who to report them to.
Your training should be role-based, as the IT staff, administrative teams, and financial aid officers all need different specifics.
Step 7: Document and Review Your Security Plan
No matter how strong your controls are, they need to be clearly documented and regularly reviewed to stay compliant with GLBA. Your written information security plan is the core document that auditors, regulators, and internal teams will rely on.
This documentation should include:
- Your full risk assessment, how you addressed each finding and plan/deadlines to address the difficult to remediate findings
- Safeguards in place (technical, administrative, physical)
- Roles and responsibilities, including your security coordinator
- Vendor management protocols
- Training program outlines and frequency
- Monitoring procedures and testing results
- Incident response plan details and any recent breach learnings
The U.S. Department of Education’s GLBA compliance checklist requires institutions to maintain and review written security plans at least once a year.
Ready to Build a Security Plan That Works?
Creating a GLBA-compliant information security plan isn’t just about checking off a regulatory box—it’s about protecting your students, your reputation, and your institution’s future.
But let’s face it: compliance can feel overwhelming, especially when it spans IT, operations, and third-party vendors. That’s where we come in.
FortifyData helps higher education cybersecurity teams achieve GLBA compliance by providing continuous cyber risk assessments, automated compliance management, and third-party risk monitoring. Its platform ensures that internal threats are identified, access controls are enforced, and detailed compliance reports are easily generated.
Ready to see how FortifyData can help automate many of the steps to meeting GLBA Safeguards Rule compliance? Schedule a demo to see how we do it and to discuss your needs and situation.
