Articles about industry-specific regulations, standards, and legal requirements aimed at ensuring the security, confidentiality, and integrity of sensitive data and systems.

Protecting Student Privacy with GLBA Compliance

By: Brittany Holmes, Corporate Communications Manager

It’s no secret that higher education institutions have become top targets for cybercriminals and ransomware groups. For example, news stories like those about cyberattacks disrupting classes at Clackamas Community College where classes were cancelled, making this the second attack against schools in the Portland area this year, add to the growing statistics. Microsoft reported the education industry makes up 80% of enterprise malware encounters.

To help mitigate the risk of student’s personal data, compliance regulations are becoming stricter when it comes to cybersecurity, starting with recent changes to how the Gramm-Leach-Biley Act (GLBA) applies to higher education. While GLBA is often associated with financial institutions, its relevance extends far beyond that. For higher education institutions handling financial aid, student loans, and other financial activities, compliance with GLBA is important.

The GLBA compliance checklist focuses on safeguarding students’ personal data and fostering trust within the education community. Failing to comply puts students at risk of identity theft and financial fraud and exposes institutions to penalties and reputational harm. Ensuring GLBA compliance is not just a legal requirement but a measure to protect students and institutional security amid increasing cyberthreats.

This blog details how the GLBA compliance checklist applies to higher education, security program requirements, and opportunities.

Understanding GLBA in Higher Education: A Brief Overview

Originally enacted in 1999 under the Federal Trade Commission (FTC), GLBA mandates transparency in information-sharing practices and protection of sensitive data within financial institutions. To comply with GLBA, higher education institutions must tell their students and employees how they share their data and follow specific parameters to protect it.

While GLBA has existed for years, its impact on higher education institutions has become more pronounced within the last four years. Specifically, GLBA applies to colleges and universities in terms of collecting, storing, and utilizing student financial records containing personally identifiable information.

In July 2019, the Office of Management and Budget (OMB) Compliance Supplement introduced a new audit objective to evaluate institutional compliance with the Safeguards Rule, a key component of GLBA. Subsequently, in December 2021, the FTC revised its Safeguards Rule, with specific provisions taking effect 30 days later and others becoming enforceable by December 9, 2022. To allow institutions enough time for adaptation, the FTC granted a six-month extension, extending the compliance deadline to June 9, 2023.

What Higher Education Needs to Know

Universities and colleges have significant responsibilities when it comes to managing sensitive financial data, including student aid, loans, tuition payments, and payroll information. The Safeguards Rule includes nine elements that higher education’s cybersecurity programs must consist of.

Below are elements from the GLBA compliance checklist that higher education must include in their security program:

  1. Designate a qualified individual for information security oversight: Appoint an individual knowledgeable in cybersecurity, beyond just IT, to lead the institution’s security efforts. This person should understand the complexities of safeguarding student data and coordinating with various departments and service providers. Even if a service provider or affiliate helps, the institution remains responsible for compliance.
  2. Conduct periodic risk assessments: Regularly assess the risks associated with student data, research information, and institutional assets. This includes evaluating internal and external threats to data integrity, confidentiality, and availability, aligning with frameworks like NIST, and tailoring them to higher education needs.
  3. Implement safeguards based on risk assessments: Deploy encryption for sensitive data, enforce multi-factor authentication, regularly review access controls, maintain asset inventories, securely dispose of data, and anticipate network changes. Employ a Security Operations Platform to detect and respond to threats effectively.
  4. Train employees on cybersecurity awareness: Develop a proactive security awareness program tailored to the higher education environment. Educate faculty, staff, and students on recognizing and reporting suspicious activities to bolster the institution’s security posture.
  5. Maintain oversight of third-party service providers: Evaluate service providers with expertise in securing educational data. Utilize Security Operations platforms and Managed Detection and Response (MDR) services to monitor vendor access and activities for compliance.
  6. Conduct regular vulnerability scanning and penetration testing: Schedule routine vulnerability scans and penetration tests to identify weaknesses in the IT infrastructure. Utilize progressive penetration testing to simulate different attack scenarios, ensuring critical data remains protected.
  7. Keep security programs current: Continuously update security programs to adapt to evolving threats and operational changes within the institution. Employ Security Operations Platforms to provide real-time insights into network health, compliance, and at-risk programs.
  8. Develop a written incident response plan: Establish a comprehensive incident response plan outlining roles, responsibilities, and steps to mitigate cyberattacks. Conduct tabletop exercises to ensure stakeholders are prepared to respond effectively to security incidents.
  9. Provide an annual security program report: Deliver a comprehensive report to the Board of Trustees or relevant governing body detailing the institution’s security posture, compliance status, risk assessments, incident response activities, and recommended improvements. Utilize specialized reporting tools to streamline compliance reporting processes.

Compliance with GLBA is not just a legal obligation, it is a commitment to protecting sensitive data, upholding student privacy, and safeguarding institutional integrity. Embracing GLBA compliance mitigates risks and fosters a culture of security consciousness essential in today’s digital landscape. For more details, the FTC outlines all nine elements here.

What Happens to Non-Compliant Institutions?

Significant repercussions exist if a higher education institution fails to comply with the GLBA. First, if discovered during the annual audit, the institution’s access to Department of Education information systems may be restricted by the Federal Student Aid’s Postsecondary Institution Cybersecurity Team. Repeated or serious breaches could lead to fines or other administrative actions.

In addition, penalties outlined in the GLBA include fines of up to $100,000 for institutions and individuals. However, the most severe consequence of non-compliance is the risk of a security breach. In such an event, sensitive student data could be compromised, leading to potential ransom payments to recover the information without guaranteeing its return. The higher education’s reputation would suffer, impacting its ability to attract prospective students who may question its ability to safeguard their personal information.

An Opportunity to Strengthen Your Cybersecurity Posture

Higher education institutions have a unique opportunity to enhance their security measures while simultaneously complying with GLBA regulations. By proactively adhering to GLBA standards, these institutions protect sensitive financial information and strengthen trust and reputation within their communities.

Compliance ensures legal adherence and mitigates risks, fostering a culture of transparency and integrity. It also secures funding, supports financial stability, and enables investments in cybersecurity infrastructure, ultimately preserving accreditation and academic excellence. Through efficient compliance management, institutions optimize resources and focus on core educational objectives while safeguarding data and enhancing overall security posture.

Many rely on a Security Operations platform to help with their journey toward compliance. Their proactive approach to threat detection and response aligns seamlessly with the demands of GLBA regulations, ensuring constant vigilance against cyber threats. XDR alleviates the burden on internal teams, streamlining compliance management processes. By harnessing the power of XDR, higher education institutions can navigate the complexities of regulatory compliance more efficiently, safeguarding data integrity and elevating their overall security posture.

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RMISC 2024

Join Adlumin at the Rocky Mountain Information Security Conference (RMISC) for an immersive experience in cybersecurity excellence. Dive into cutting-edge content, with insights on the latest trends, technologies, and best practices shaping the industry’s future. Learn from world-class speakers, gain invaluable knowledge, and network with peers and potential collaborators from around the globe.

Stay ahead of the curve with access to sponsor exhibits showcasing innovative products and solutions. Whether you’re a seasoned professional or an aspiring enthusiast, RMISC provides unparalleled opportunities for learning, networking, and growth within a vibrant cybersecurity community.

Don’t miss out on RMISC—the cornerstone event for staying ahead in today’s rapidly evolving cybersecurity landscape.

Dates: June 11-13, 2024
Location: Denver, CO


2024 Central Ohio InfoSec Summit

The Central Ohio InfoSec Summit celebrates collaboration, innovation, and the pursuit of excellence in information security. Explore diverse cybersecurity solutions, network with industry experts, and gain insights into emerging industry trends.

Come meet the Adlumin team and learn about our Security Operations Platform can provide visibility across endpoints, users, and the perimeter and contextual insights for rapid, informed decision-making.

Don’t miss this opportunity to expand your knowledge and enhance your organization’s security posture.

Dates: May 23-24, 2024
Location: Columbus, OH


Boise ISSA Conference

Join Adlumin during the 21st Annual Boise ISSA InfoSec conference, an immersive experience set against the scenic backdrop of downtown Boise, Idaho.

This event includes three dynamic keynote speakers who will illuminate the latest trends and developments in the cybersecurity realm. Delve deeper into the intricacies of information security through a wide range of educational sessions tailored to accommodate varying levels of expertise.

Dates: April 25, 2024
Location: Boise, Idaho


Decoding Cyber Threats: Translating Binary into Industry Impact

Event details:

Monday, March 25, 2024
11:00 AM PT / 2:00 PM ET


Mark Sangster, VP, Chief of Strategy, Adlumin

Sean McSpaden, Senior Fellow, Center for Digital Government (Moderator)

About this talk:

The crucial distinction between a minor cyber incident and a major organizational disruption often gets lost in translation. Technical practitioners focus on technology, while agency leaders prioritize industry value and reputation, but in critical moments, mutual understanding is paramount.

Join Government Technology and Adlumin for a live webinar where our panel of experts will explore what effective leadership looks like during a cyber crisis.

Cybersecurity expert and author Mark Sangster will draw on lessons from actual ransomware incidents to construct a Cyber Rosetta Stone, facilitating communication to avert cyber disasters.

You’ll Learn:

  • The best practices for maintaining sound decision-making during an active cyber crisis
  • How to navigate the interpersonal side of cyber attacks – like human biases, office politics and perceived personal fears
  • Practical knowledge of building a comprehensive incident response strategy

7 Reporting Considerations to Enhance Your Security Operations

A critical component of any organization’s security operations is the ability to automatically generate reports that offer valuable insights into the effectiveness of security measures. These reports help identify potential threats and vulnerabilities and play a crucial role in meeting compliance requirements.

This proactive approach enables security teams to quickly address issues, make informed decisions, and enhance the organization’s security posture, ultimately saving valuable time when reporting to leadership during incidents.

This blog details recommended key reports to share with your board and leadership team along with ways to make the most of your cybersecurity solution.

7 Key Reports Your IT Team Should Use

Being able to grab reports instantly plays a crucial role in saving time and ensuring that when the latest ransomware or breach headlines hit, your leadership team has the answers they need. Below are examples of compliance, board, admin, and IT reports that your IT team should regularly review and incorporate into your security program:

1. One-Touch Compliance Reporting: Ensuring that security measures align with industry standards and regulatory requirements, such as GDPR or HIPAA, is crucial for maintaining data privacy and protecting against legal repercussions. Below are a few examples:

  • National Credit Union Association, Automated Cybersecurity Evaluation Toolbox (NCUA ACET)
  • Federal Financial Institutions Examinations Council (FFIEC)
  • FBI’s Criminal Justice Information Services Division (FBI CJIS)
  • Payment Card Industry Data Security Standard (PCI DSS)
  • Ransomware Self-Assessment Tool (R-SAT)
  • Information Technology Risk Examination Program (InTREx CU)
  • Health Insurance Portability and Accountability Act (HIPAA)

2. Detection Analysis: By analyzing detection reports, IT teams can identify trends, patterns, and anomalies in network activity that may signify a breach or potential threat.

3. Darknet Monitoring: Monitoring the darknet for any compromised credentials or sensitive data belonging to the organization can help preemptively address potential security risks.

4. Privileged Account Activity: Tracking and analyzing privileged account activities can help detect unauthorized access or unusual behavior that may signal a security breach.

5. VPN Activity Report: Examining VPN usage and access logs can provide insights into who is accessing the network remotely and identify suspicious or unauthorized activities.

6. Network Health Report: Regularly assessing the overall health of the network, including performance metrics, system vulnerabilities, and security gaps, is important for maintaining a secure and efficient IT infrastructure.

7. Board and IT Steering Committee Report: Providing executive stakeholders with a high-level overview of the organization’s cybersecurity posture, including key metrics, incident response updates, and strategic recommendations, is essential for aligning business objectives with security priorities.

Incorporating these reports into your daily operations will automate the collection, analysis, and reporting of security data. This also allows analysts to focus on more operational tasks, such as threat hunting and incident response, rather than spending time manually compiling and analyzing data. By streamlining these processes, reports help improve overall productivity.

Closing the Reporting Gap with Leadership

Regardless of which report you are looking to pull, having access will play a crucial role in bridging the gap between security teams and leadership by providing an overview of the organization’s cybersecurity posture. These reports offer insights into the efficiency of cybersecurity investments, helping leadership understand and make informed decisions regarding resource allocation.

By tracking security incidents and trends, reports enable organizations to identify gaps in their defenses and prioritize security efforts based on risk assessment. This continuous monitoring enhances communication between different stakeholders and helps build a strong security posture that can withstand evolving cyber threats. Ultimately, reports assist in understanding the security environment and ensuring proactive measures are in place to safeguard the organization’s assets.

Enhance Your Security Posture with One-Touch Reporting

Taking advantage of complete access to one-touch reporting can significantly enhance your organization’s security posture and by working with a Security Operations Platform like Adlumin, you can streamline the process of generating these reports and gain access to expert analysis and recommendations.

This partnership enhances your security capabilities and helps you effectively communicate with leadership and gain a deeper understanding of your security environment. Make the most of automatic reports to stay ahead of threats so you always know where your security posture stands.

Explore the Platform

Adlumin XDR ensures swift setup, unrivaled visibility spanning endpoints, users, and the perimeter, and provides contextual insights for rapid, informed decision-making.

Explore the Platform

Adlumin XDR ensures swift setup, unrivaled visibility spanning endpoints, users, and the perimeter, and provides contextual insights for rapid, informed decision-making.

Institute of Internal Auditors (IIA) Audit Seminar

Led by leaders in internal auditing, the 2024 IT Audit Seminar is a multi-day in-person Instructor-Led Training, providing a personalized learning experience that adjusts to your needs and skill levels. You will gain a better understanding of the latest audit industry best practices, proven techniques, and trending issues through exercises and group discussions.

Date: April 18, 2024
Location: Williamsville, NY

The Balancing Act: Security vs. Budget in Community Banking

Event details:

On-Demand Webinar


Mark Sangster, Chief of Strategy at Adlumin
Charles Potts, Executive Vice President & Chief Innovation Officer, ICBA Innovation

About this talk:

Community banks are the lifeblood of local economies, but they often face unique challenges, especially when it comes to juggling extensive compliance regulations with limited resources. Spend 15 minutes with Adlumin’s Vice President, Chief of Strategy, Mark Sangster, and Executive Vice President & Chief Innovation Officer, ICBA Innovation, Charles Potts, to gain the knowledge and tools to protect your bank and your community!

The Compliance Tightrope

Event details:

Wednesday, April 17, 2024
2:00 PM CDT


Mark Sangster, Chief of Strategy at Adlumin

About this talk:

Balancing Security with Budget in Community Banking

Community banks are the lifeblood of local economies, but they often face unique challenges, especially when it comes to juggling extensive compliance regulations with limited resources.

Join Adlumin’s Vice President, Chief of Strategy, Mark Sangster, in this insightful webinar as he explores:

  • The growing compliance burden on community banks.
  • Effective strategies and tools to navigate compliance demands.
  • Gain access to resources and support for a comprehensive defense.
  • Protecting your community: Ensure security without sacrificing growth and agility.

Don’t miss this opportunity to learn proven strategies to strengthen your bank’s compliance posture while optimizing your budget. Sign up today and gain the knowledge and tools to protect your bank and your community!

The ABCs of Cyber: Assets, Budget, and Consolidation


The ABCs of Cyber: Assets, Budget, and Consolidation

Cyber experts Mark Sangster, VP at Adlumin, and Dave Grubber, Principal Analyst at Enterprise Strategy Group (ESG), outline a rapid roadmap to successful cybersecurity using consolidation to drive efficiency and manage cost.

Download to learn:

  • Network protection must-haves
  • How to navigate compliance
  • Best practices for streamlining your security operations using artificial intelligence and machine learning
  • How to thoughtfully approach your cybersecurity budget and make the most of every dollar

Thought Leadership Webinar

Adlumin’s on-demand webinar, “The ABCs of Cyber: Assets, Budget, and Consolidation,” provides actionable advice on consolidating resources to improve efficiency and control expenses in response to ever-changing cyber threats.