GLBA compliance is essential for educational institutions that collect and manage financial and personal information. An analysis by Sophos found “over 85% of ransomware attacks on higher education in 2024 were due to an exploited vulnerability, compromised credentials, or a malicious email.”
With cyber threats rising, GLBA compliance isn’t optional, especially for higher education institutions that handle sensitive financial information as the scope was expanded to include higher education in an effort to better protect the financial and personal information of students and faculty that may be affected with any compromise.
This guide will walk you through preparing for a GLBA compliance audit, outlining key steps, tools, and considerations. Let’s get your organization audit-ready. Keep reading.
Why GLBA Audits Are Important
Here’s why GLBA audits are necessary for educational institutions:
- A GLBA compliance audit checks if your school is properly protecting financial data.
- Audits review both technical systems and staff procedures for handling sensitive information.
- Preparing for an audit strengthens your data breach prevention efforts.
- Demonstrates your school’s commitment to cybersecurity, building trust with students and families.
- Among many of the features in FortifyData, institutions can conduct an internal gap assessment or audit to see how many of the GLBA requirements they meet; helping efficiency and saving costs with auditors.
- Helps reduce legal risks and potential penalties in case of a data incident
Step-by-Step Guide to Prepare for a GLBA Audit
Below are some essential steps to prepare for a GLBA audit.
1. Learn the GLBA Safeguards Rule
Start by understanding what the GLBA Safeguards Rule requires from your institution. One requirement is to appoint someone responsible for your information security program. Another is to create a written plan that’s based on a detailed risk assessment and includes protections to reduce potential threats. There are other administrative, operational and technical requirements, as defined by the Code of Federal Regulations section 314 (the Standards for Safeguarding Customer Information section) to understand which can be challenges and solutions for GLBA compliance in higher education.
You also need to test your safeguards regularly to make sure they still work as threats, and your IT environment changes over time. This plan should be reviewed often and updated as new risks are discovered, and system changes are deployed. Understanding these basic rules gives your school a solid base to build on for full compliance.
2. Do a Risk Assessment
A risk assessment involves looking at how and where your institution stores sensitive financial data. You’ll need to identify which systems hold this information, who has access to it, and where your current technology stack and processes might be weak.
It’s important to involve both IT staff, department heads and a Board stakeholder so you get a full view and understanding of the possible risks affecting the institution. Document your findings in detail because auditors will ask to see proof that you’ve taken this step; this is where a comprehensive and automated platform can store and log findings, policies for audit readiness. Reviewing risks regularly can also help you stay ahead of potential threats.
3. Use Cybersecurity Best Practices
Using strong cybersecurity best practices is essential for protecting your systems and financial data beyond the requirements in GLBA Safeguards Rule. These practices include encrypting data both when it’s stored and when it’s being shared, using multi-factor authentication to verify users, frequently/regularly conducting user access reviews, and regularly updating software to fix security holes.
Access to data should also be limited to only those who need it, reducing the chances of internal misuse. Firewalls, antivirus tools, and threat detection systems can further strengthen your defenses. These actions are not just helpful for compliance but also make your institution safer overall.
4. Follow a GLBA Security Checklist
A GLBA compliance security checklist helps keep your audit preparation on track. The checklist should confirm that you’ve assigned someone to manage your security program, listed every system that stores financial information, outlines the other requirements and trained employees to handle data securely.
You should also include testing your incident response plan and checking that your vendors follow proper security protocols. Reviewing this list regularly helps you catch anything you might have missed before the official audit. It’s a simple but powerful tool for staying organized and compliant.
See what GLBA Safeguards Rule requirements that FortifyData addresses for clients.
5. Train Your Staff
Staff training is one of the most important parts of protecting your data. Having a “security aware” personnel can really increase your posture as everyone improves their vigilance. Everyone in your organization should know how to spot phishing attempts, handle sensitive data correctly, and report anything that seems suspicious.
Make training a regular part of your calendar, not just a one-time event. Include real-life examples in your sessions to help staff understand the risks. A well-informed team plays a key role in stopping security issues before they become serious problems.
6. Manage Vendor Risks
Many schools use third-party vendors for IT services, payment systems, or data storage, and these vendors can pose risks. Make sure you carefully choose vendors that follow strong security practices and include clear data protection rules in your contracts with them.
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.”
You should also check in with your vendors regularly to make sure they’re still following the rules. Ask for proof of their security practices or audits if needed. This kind of risk management is a key area auditors look at, so don’t overlook it.
7. Keep Clear Records
Auditors want to see documented proof of your GLBA compliance efforts, so keep detailed records of everything. This includes your security plan, results from your risk assessments, and reports on any incidents.
Also, include employee training logs and any agreements with vendors that handle financial data. Good recordkeeping not only helps during the audit but also allows your school to review and improve its security over time. It shows that your institution takes its responsibilities seriously.
8. Do Regular Internal Audits
Before the official audit, it’s a good idea to do your own internal checks. Look over your security systems, test your response to a simulated data breach, and review your policies to make sure they’re up to date.
These practice audits can uncover small problems before they turn into big ones. Make sure to involve different departments in these checks so everyone knows their role in keeping data safe. It’s also a great way to build confidence before the real audit happens.
9. Stay Updated
GLBA rules and enforcement can change, so it’s important to stay informed. You can follow updates from the Federal Trade Commission (FTC), sign up for higher education security newsletters, or attend webinars on compliance.
Make sure your team knows about any changes that affect your responsibilities which can present challenges and solutions for GLBA compliance for higher education. Updating your policies and training materials regularly will help your school stay ahead. Staying current shows that your institution is committed to continuous improvement.
Simplify GLBA Compliance with FortifyData
Getting ready for a GLBA compliance audit may seem challenging, but following a clear process makes it much easier. With a strong risk assessment, updated cybersecurity practices, and a complete GLBA security checklist, your school will be well-prepared.
Take action early, stay organized, and protect the people who trust you with their data.
FortifyData can streamline your GLBA compliance efforts by providing comprehensive, automated risk assessments tailored to educational institutions.
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.
