Colleges and universities handle a lot of sensitive financial data, such as student loan details, payment records, and more. That’s why understanding GLBA for universities and colleges requires them to have clear safeguards in place to protect that information.
But not every institution gets it right. In recent years, several colleges have faced warnings, audits, and even penalties for failing to meet GLBA requirements.
This article looks at real lessons from those failures. You’ll learn what went wrong, why it happened, and how your institution can avoid making the same mistakes.
6 Reasons Colleges Fail to Meet GLBA Standards
GLBA compliance is crucial for colleges and universities now to protect student financial information. Higher education was brought in-scope to adhere to the GLBA Safeguards Rule where the primary goal of GLBA is to reduce fraud, prevent identity theft, and strengthen consumer data protection.
However, many institutions encounter challenges that hinder their compliance efforts.
Below are some of the primary reasons for these shortcomings:
1. Insufficient Staff Training
A well-informed staff is the first line of defense against data breaches. When employees lack proper training on GLBA requirements and data protection protocols, they may inadvertently mishandle sensitive information.
Without regular training, staff may not recognize the importance of safeguarding student financial data or understand the specific protocols required. Moreover, untrained personnel are more susceptible to phishing scams and other social engineering tactics, increasing the risk of data breaches.
2. Weak Access Controls
Unauthorized access to sensitive data is a significant risk factor for non-compliance. Inadequate access controls can allow individuals to view or modify information beyond their clearance level and increase the risk of data exposure.
This happens when there’s:
- Overly Permissive Access: Granting broad access permissions increases the risk of data exposure.
- Lack of Multi-Factor Authentication (MFA): Without MFA, systems are more vulnerable to unauthorized access through compromised credentials.
3. Unmonitored Third-Party Vendors
Colleges often collaborate with third-party vendors for various services, from payment processing to data storage. However, if these vendors lack robust security measures, they can become weak links in the institution’s data protection chain.
Something like this usually happens when institutions don’t have adequate processes to assess and monitor the security practices of their vendors. That’s why even if a breach occurs at the vendor’s end, the educational institution may still be held accountable for non-compliance.
The GLBA Safeguards Rule has a requirement to ‘Monitor Service Providers’ (Section 314.4 (f)(3)) which states “Periodically assess your third-party service providers based on the risk they present and the effectiveness of their safeguards.” Third-party monitoring is not just through contract management, but through evaluation of their security posture and processes.
4. Inadequate Incident Response Mechanisms
Despite preventive measures, security incidents can still occur. And if you don’t have a well-defined incident response plan, you’ll struggle to contain and mitigate breaches effectively.
Common mistakes that happen in this include:
- Delayed Response: Lack of preparedness can lead to slow reactions, exacerbating the impact of a breach.
- Communication Breakdowns: Unclear roles and responsibilities can hinder coordination during incident management.
5. Failure to Encrypt Sensitive Data
Encryption is a fundamental safeguard for protecting data both in transit and at rest. Neglecting to encrypt sensitive information increases the risk of unauthorized access and data breaches.
This unencrypted data transmitted over networks has a higher chance of being intercepted by malicious actions which makes encryption a must. Moreover, if your device is stolen and you never thought about encrypting it, you might regret that decision.
Think of millions of compromised information records sourced from higher education breaches that were ‘useful’ because the information wasn’t encrypted.
6. Lack of Regular Compliance Audits
Continuous monitoring and assessment are vital to ensure ongoing compliance with GLBA standards. Without regular audits, institutions may be unaware of existing vulnerabilities and fall short of complying with the Safeguards Rule of GLBA.
That’s why many higher education institutions are now recommended to use regular audits to help identify and address compliance gaps before they can be exploited.
For reference the requirements related to GLBA are:
- 314.4(d)(2) Monitor and periodically test the effectiveness of the safeguards to include detection of actual and attempted attacks on or intrusions into the information systems
- For information systems this includes continuous monitoring or periodic penetration testing and vulnerability assessments. If continuous monitoring is not an option nor are there systems for detection, changes to the information systems that may create vulnerabilities, entities shall conduct:
- Annual penetration testing
- Vulnerability assessments to identify publicly known vulnerabilities of your systems, at least every six months; and whenever there are material changes to your operations or business, or when there are circumstances, you know or have reason to know may have a material impact on your information security program
- For information systems this includes continuous monitoring or periodic penetration testing and vulnerability assessments. If continuous monitoring is not an option nor are there systems for detection, changes to the information systems that may create vulnerabilities, entities shall conduct:
Lessons Learned from Past Failures
Here are the key takeaways your college or university can apply today to avoid the same mistakes:
1. Training Isn’t Optional — It’s Foundational
Many compliance failures stem from human error, not system flaws. In fact, human errors are accounted for 35% of data breaches in the education sector. Whether it’s a staff member clicking a phishing link or mismanaging sensitive student records, the root cause is often a lack of awareness.
So, make sure to build a culture of compliance from the ground up. Conduct mandatory training for all employees and repair it annually. Also, ensure that every department, from admissions to financial aid, understands how to handle and protect financial information.
Implement ongoing regulatory educational training and cybersecurity awareness programs tailored to specific roles. Cybersecurity awareness training can use simulated phishing campaigns and real-world scenarios to educate employees as to the ‘what’ they should do. Conducting regulatory educational training provides the opportunity to explain ‘the why’ for the activities and training and to discuss the outcome for improved cyber resilience in addition to protecting student and faculty NPI. This can build a strong culture of compliance.
2. You Can’t Protect What You Can’t See
Several institutions that failed GLBA audits lacked a proper data inventory. They didn’t know exactly what sensitive data they had, where it was stored, or who had access to it.
For this, create a centralized, living inventory of all sensitive data — including its storage location, access permissions, and classification level. Make sure to update it regularly, especially when departments adopt new software or processes.
3. Access Should Be a Privilege, Not a Default
In some notable GLBA failures, institutions had weak access controls — giving too many people access to high-risk data. These broad permissions made it easier for breaches to happen internally or through compromised accounts.
Adopt a “least privilege” access model. Only grant access to those who absolutely need it. Review and revoke unused accounts every quarter, and implement multi-factor authentication (MFA) for all systems containing sensitive data.
4. Documentation Is Your Best Defense
One common mistake found in audits was the absence of clear, written policies or outdated security plans. Even institutions that were doing “the right things” failed audits because they couldn’t prove it.
The best way is to maintain up-to-date documentation for all compliance-related procedures — from incident response plans to training logs and access reviews. If it’s not documented, it doesn’t count in the eyes of regulators.
5. Waiting Until an Incident Happens Is Too Late
Some institutions only discovered their weaknesses after a breach occurred. But, by then, the damage, reputational and regulatory, was already done.
So, be proactive and conduct risk assessments and internal audits. Moreover, stimulate breach scenarios to test your incident response plan. Also, fix the gaps before they become front-page news.
6. Leadership Buy-In Matters
GLBA compliance isn’t just an IT issue. Schools that failed to meet requirements often lacked leadership support, which led to underfunded cybersecurity budgets and unclear accountability.
Get executive leadership involved. Compliance should be a priority at the cabinet level, with clear reporting lines and sufficient budget to implement safeguards effectively.
Turn GLBA Compliance Lessons into Lasting Protection with FortifyData
GLBA compliance isn’t just about checking boxes or passing annual audits — it’s about safeguarding your students’ most sensitive financial data and building a culture of trust and accountability.
But every failure holds a lesson. The institutions that take these lessons seriously are the ones that earn the confidence of students, parents, and regulators.
If your college is still rely on outdated systems, FortifyData is here. 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.
