Personal data at higher education institutions is constantly at risk, many institutions grapple with the complexities of regulatory compliance. A common concern is aligning internal systems and protocols with the standards of the Gramm-Leach-Bliley Act (GLBA), which higher education was brought in-scope for in June 2023.
With 74% of colleges and universities experiencing a data breach in the last two years, it’s now more important than ever to have strategies in place to prevent it and that is why higher educaiton was brought in-scope to adhere to the GLBA Safeguards Rule. The primary goal of GLBA is to reduce fraud, prevent identity theft, and strengthen consumer data protection.
A report by Comparitech found that since 2005, there have been 2,691 data breaches in educational institutions, exposing at least 32 million individual records, making GLBA compliance not only a legal obligation but also a critical measure for institutional trust and security.
We discuss the challenges and solutions for GLBA compliance in higher education and our experience with the most frequent GLBA compliance challenges and offer actionable strategies to overcome them. If you’re responsible for information security or compliance, read on for practical insights and tools to strengthen your organization’s defenses.
Understanding GLBA Compliance
The Gramm-Leach-Bliley Act (GLBA), enacted in 1999, mandates financial institutions to protect sensitive customer information. If your institution handles Title IV financial aid data, you’re required to meet new cybersecurity regulations under the FTC’s GLBA Safeguards Rule.
This involves ensuring the confidentiality, integrity, and availability of nonpublic personal information (NPI) through a comprehensive information security program. GLBA compliance requires continuous monitoring, updating, and auditing. Many institutions, particularly in higher education, struggle to keep pace.
Explained below are the most common hurdles faced during GLBA compliance and effective strategies to tackle them head-on.
Common GLBA Compliance Challenges and How to Overcome Them
Achieving GLBA compliance is an opportunity to leverage the requirements to bolster your cybersecurity risk management program and foster relationships across institutional departments to build trust around your concerted activities to keeping student information safe. Challenges will come up, but they can be handled. With the right tools, proper training, and strong leadership, your school can stay on track and meet the requirements with confidence.
1. Lack of Awareness and Training
A major barrier to GLBA compliance is the lack of awareness across staff and departments. Faculty and administrative staff often don’t receive adequate training on how to handle sensitive data or recognize cybersecurity threats.
Solution
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 way’ for the activities and training and to discuss the outcome for improved cyber resilience in addition to protecting student and faculty NPI. Incorporating training into onboarding processes and scheduling annual refreshers can build a strong culture of compliance.
Also, add mandatory GLBA-specific modules to your internal Learning Management System (LMS) and track participation.
2. Incomplete GLBA Security Checklist Implementation
Institutions often implement GLBA requirements in fragments, leading to gaps in data protection. Key elements like risk assessments, incident response plans, or third-party management are sometimes overlooked.
Solution
Use a comprehensive GLBA security checklist as provided in the Code of Federal Regulations which the GLBA Safeguards Rule is based on (Section 314). This includes all critical components—such as risk assessments, employee training, encryption practices, vendor oversight, and data access controls. Regularly audit systems to ensure all checklist items are addressed and up-to-date.
Many organizations use governance, risk, and compliance (GRC) software, like FortifyData, to automate this process and track progress against the requirements.
3. Inadequate Risk Assessments
Risk assessments are foundational to GLBA compliance, but many institutions either don’t have a complete scope for them or perform them irregularly. This can lead to unidentified vulnerabilities and noncompliance.
Solution
Conduct annual risk assessments that include all asset inventory that identify potential threats to customer data, evaluate existing safeguards, and determine whether additional measures are needed. Ensure that vulnerability scans cover both internal and external threats, including third-party vendors.
Create a risk register and update it regularly to reflect changes in the digital environment and institutional structure.
4. Failure to Follow Cybersecurity Best Practices
Outdated software, weak passwords, and poor network configurations remain prevalent issues in many institutions, increasing the risk of a data breach and GLBA violations.
Solution
Establish and enforce cybersecurity best practices, including multi-factor authentication (MFA), routine software updates, strong password policies, and regular network monitoring. Double check your mitigating controls designed to reduce the risk of legacy systems that you won’t be transitioning from.
Invest in endpoint detection and response (EDR) tools, next generation firewalls, and intrusion detection systems (IDS). Implement automatic patch management tools to ensure timely software updates across all systems.
5. Vendor Management and Third-Party Risks
Many colleges and universities rely on third-party vendors for services such as cloud storage or financial processing. The GLBA Safeguards Rule has a specific requirement to Monitor Service Providers – not just through contract management, but through evaluation of their security posture and processes.
Solution
Establish a robust vendor third-party management program that includes due diligence, external attack surface assessments, security assessment reviews (HECVAT, SOC 2, recent PenTest, etc.), and contractual clauses requiring compliance with GLBA. Evaluate vendors more frequently than annually and request proof of cybersecurity practices and certifications. Always include third-party risk management as a critical section in your GLBA security checklist.
6. Weak Incident Response Planning
Even with strong preventive measures, breaches can still occur. Institutions that lack a defined incident response plan (IRP) often struggle to mitigate damage and notify affected parties on time, risking both financial penalties and reputational harm.
Solution
Develop a formal IRP that includes roles, responsibilities, communication protocols, and timelines. Conduct tabletop exercises and simulated data breaches to ensure readiness.
Align your IRP with federal guidelines and ensure it includes a clear data breach prevention strategy. ON-Demand Webinar: FortifyData Capabilities to Help Achieve GLBA Safeguards Rule Compliance.
Challenges with Higher Education Regulatory Compliance
Unlike corporations, educational institutions face layered compliance obligations, not only from GLBA compliance but also from FERPA, CMMC/NIST 800-171, HIPAA, and PCI DSS. Managing these overlapping requirements can overwhelm IT and compliance teams.
Solution
Form an interdisciplinary compliance committee that includes legal, IT, academic, and administrative representatives. Use a unified compliance framework to map GLBA requirements alongside other regulations, identifying overlaps and reducing redundancy. Consider adopting the NIST Cybersecurity Framework (CSF) to align various regulatory requirements into a centralized structure.
Limited Resources and Staffing
Many higher education institutions operate with tight budgets and limited cybersecurity staff. This can make it difficult to stay current with compliance updates, conduct risk assessments, and implement robust data protection measures.
Solution
Leverage trusted third-party vendors and cloud-based security services, like FortifyData, to supplement internal capabilities. Look for solutions that offer automated compliance reporting, continuous monitoring, and technical support.
We often hear that clients that use FortifyData feel we are a ‘force multiplier’ to their team as we automate many of the processes and analysis to make your team more efficient and able to work on more strategic items or finally being able to get to other projects that end up on the back burner.
Additionally, seek grant opportunities and collaborative partnerships to expand access to resources without overburdening internal teams.
Strengthening GLBA Compliance with Strategic Tools and Trusted Solutions
Meeting the challenges and solutions for GLBA compliance in higher education is essential for protecting sensitive student and financial data in higher education institutions. However, achieving and maintaining compliance can be complex without the right support in place.
Adopt a strategic, checklist-driven approach. Regularly assess and refine your security posture. Stay proactive with vendor management and incident response planning. Most importantly, fosters a culture of cybersecurity awareness across all departments.
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.
