Universities collect and store extensive sensitive student data, especially financial information. That’s why understanding GLBA for Universities and Colleges and achieving compliance with it is not just a legal requirement but a crucial responsibility.
Yet, many institutions struggle to keep up with evolving data security standards, leading to significant consequences as well.
So, in this guide, we’ll walk you through how universities can effectively audit their GLBA compliance with the Safeguards Rule, close security gaps, and protect the financial data of their students and staff.
Why Regular GLBA Audits Are Essential
Regular audits of your university’s GLBA compliance aren’t just a checkbox activity; they’re a critical part of protecting your student’s financial information and maintaining your institution’s reputation and funding. Getting in the habit of periodic gap assessments or continuous monitoring of the controls related to GLBA will ensure you are doing your part.
Some benefits of it include:
- Early Risk Detection: Routine audits help identify weaknesses in your data protection systems before they’re exploited.
- Better Preparedness for External Audits: Being proactive ensures you’re ready when the Department of Education or if another federal body reviews your compliance status.
- Safeguards Funding Eligibility: GLBA compliance is a requirement for access to Title IV federal student aid programs.
- Strengthens Student Trust: Transparent data practices and strong security reassure students and their families that their sensitive information is safe.
Step-by-Step Guide to Auditing GLBA Compliance
Here’s how you can audit your GLBA compliance:
1. Review Data Handling Policies
Start by examining your current policies for collecting, storing, accessing, and disposing of sensitive financial data.
What you need to check for includes:
- Are your policies up to date with GLBA’s Safeguards Rule requirements?
- Do they clearly define what constitutes “nonpublic personal information” (NPI)?
- Are all departments handling student financial data (e.g., admissions, financial aid, registrar) following the same protocols?
Action: Ensure all staff are trained to understand these policies and that updates are distributed campus wide.
2. Assess Vendor and Third-Party Risks
Universities often share student information with outside vendors, including payment processors, software providers (file transfer, student information systems, etc.), or loan servicers. These third parties can become weak links if they have a poor cybersecurity posture and don’t meet compliance standards.
A few things to keep in mind are:
- if vendors are contractually required to maintain GLBA-level security
- do they have documented data protection practices
- have you reviewed or audited your controls specific to third parties recently.
To remain compliant with these things, maintain a current vendor risk register and require signed data protection agreements (DPAs) for any service handling student financial data.
In our experience, higher education institutions rely on FortifyData for our capability to conduct non-intrusive external assessments of vendors and in-scope assessments of the specific service (for clients) in addition to maintaining a vendor inventory, risk register and questionnaire exchange (HECVAT, PCI DSS, etc.)
3. Test Access Controls
Controlling who can access student information is a key part of GLBA compliance. Poor access controls are one of the most common weaknesses found in audits.
Things to audit in this step include:
- Is access to financial data limited to only those who need it for their job?
- Are passwords, MFA (multi-factor authentication), and role-based access properly enforced?
- Are user access logs being monitored and reviewed?
After that, perform a user access review at least quarterly and immediately remove access for staff who no longer need it.
4. Evaluate Incident Response Readiness
If a breach happens, your institution must respond quickly and appropriately. GLBA requires that you have an incident response plan in place — and that your team knows how to use it.
Ask yourself a few questions, such as: Do you have a written incident response plan specific to student data? Has the plan been tested, and are the right staff trained and prepared to act? These will help you make your incident response much stronger.
For this to succeed, schedule regular tabletop exercises or breach simulation exercises and clearly define roles for IT, legal, communications, and leadership. This can help uncover lapses in communication, understanding of roles and responsibilities, where to access data, etc.
5. Document Audit Findings and Next Steps
Your audit isn’t complete until it’s fully documented. A clear record shows that your institution takes compliance seriously and allows you to track improvements over time.
What to include:
- Summary of audit activities
- List of gaps or risks discovered
- Action plan with timelines and responsible parties
- Any remediation steps already completed
Action: Share the report with your compliance officer, IT leadership, and legal team — and schedule a follow-up audit date to measure progress.
How FortifyData Helps Higher Education Institutions Meet the Safeguards Rule
At FortifyData, we the tools and expertise to not only understand GLBA for Universities and Colleges but to meet GLBA compliance and safeguard student financial data.
Our platform helps universities and colleges assess, manage, and mitigate cybersecurity risks while ensuring they adhere to the FTC Safeguards Rule (Section 314.4).
Read how we meet the specific sections for GLBA compliance as defined by the Code of Federal Regulations.
Tools and Frameworks Universities Can Use
Here’s a breakdown of some of the most widely used and effective options universities can use:
1. NIST Cybersecurity Framework (CSF)
The National Institute of Standards and Technology (NIST) Cybersecurity Framework is one of the most widely adopted models in higher education. It offers a flexible, risk-based approach to identifying, protecting, detecting, responding to, and recovering from cyber threats.
NIST’s framework aligns well with the GLBA Safeguards Rule and provides a common language for risk assessment and control implementation. Many universities use NIST CSF as a baseline for their information security programs.
2. EDUCAUSE Higher Education Cybersecurity Resources
EDUCAUSE is a nonprofit association focused on technology in higher education. They offer tools, case studies, and peer-reviewed resources tailored to the unique security needs of colleges and universities.
EDUCAUSE’s GLBA compliance toolkit and security community forums help IT and compliance teams stay updated on best practices specific to academia.
3. Third-Party Risk and Audit Platforms
Many modern platforms offer automated compliance monitoring and third-party risk assessment tools such as FortifyData. They help institutions manage security documentation, assess vendor risks, and track ongoing compliance status.
These tools reduce manual effort and ensure continuous monitoring — essential for staying GLBA-compliant year-round, especially when working with multiple vendors or decentralized systems.
4. Penetration Testing & Vulnerability Scanning Tools
Some solutions also allow universities to scan their networks and systems for security flaws that could jeopardize GLBA compliance.
Regular vulnerability scans help identify gaps in firewalls, outdated software, or improperly configured servers, all of which are key risk areas covered under GLBA.
Bonus Tip: Use Your SIS and LMS Securely
Universities rely heavily on Student Information Systems (SIS) and Learning Management Systems (LMS). These systems must also follow strict access controls and encryption protocols to stay compliant.
Read how this college achieved GLBA Safeguards Rule compliance.
Make GLBA Audits a Strategic Advantage, Not a Stress Point
Regular, well-documented audits not only reveal where you stand but also guide you toward building a more resilient and trustworthy data environment. But auditing alone isn’t enough. You need the right tools, risk visibility, and actionable insights to truly manage compliance.
That’s where FortifyData comes in handy.
At FortifyData, we help higher education institutions take control of cyber risk and regulatory requirements with continuous, automated, and prioritized insights.
Ready to see it in action?
Request a Demo and take the first step toward stronger, smarter compliance.
