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GLBA Compliance Deadline and Challenges in Higher Education

Posted March 17th, 2023

GLBA Compliance Deadline and Challenges in Higher Education 

Institutions of Higher Education have been working hard to comply with the Financial Safeguards Rule in the Gramm-Leach-Bliley Act, and the deadline has been extended by 6 months. The new deadline for complying with some of the updated requirements of the Safeguards Rule is now June 9, 2023

GLBA Compliance and Higher Education

Higher education institutions handle a significant amount of sensitive information, including personal data of students and staff, financial information, and academic records. The Gramm-Leach-Bliley Act (GLBA) is a federal law that requires financial institutions, including colleges and universities, to protect the non-public personal information of their customers. To comply with GLBA and safeguard sensitive information, higher education institutions should take the following steps: 

  1. Develop and implement a comprehensive information security program: This program should address administrative, technical, and physical safeguards to protect sensitive information from unauthorized access, use, disclosure, or destruction.
  2. Conduct regular risk assessments: Higher education institutions should regularly assess the risk of unauthorized access, use, disclosure, or destruction of sensitive information and take appropriate steps to mitigate identified risks.
  3. Train staff and students on information security: Staff and students should be trained on the importance of protecting sensitive information, as well as on the policies and procedures that must be followed to protect this information.
  4. Use encryption to protect sensitive information: Encryption is an effective way to protect sensitive information from unauthorized access, even if the information is intercepted or stolen. Higher education institutions should encrypt sensitive information both in transit and at rest.
  5. Have an incident response plan in place: Having an incident response plan in place is crucial for responding quickly and effectively to data breaches or other security incidents. Institutions should also have a trained and practiced incident response team in place to manage and respond to security incidents.
  6. Managing vendor risk: A formal approach for identifying, reporting, and managing vendor risk should be established. Any vendor that stores or processes sensitive data falls in the scope of the information security program.

By taking these steps, higher education institutions can comply with GLBA and safeguard sensitive information effectively. It’s also important to note that regular review and update of the above steps are essential to ensure the security and compliance of the institution with the regulations. 

GLBA Compliance Challenges in Higher Education

Higher education institutions face several challenges when working to comply with GLBA safeguards: 

  1. Complex and ever-changing regulatory environment: The regulatory environment for information security is constantly changing, and higher education institutions must stay up-to-date with the latest laws and regulations to ensure compliance. 
  2. Limited resources: Higher education institutions often have limited resources, both in terms of budget and personnel, which can make it difficult to implement and maintain robust information security programs. 
  3. Managing third-party vendors: Higher education institutions often rely on third-party vendors to provide services such as financial aid, student housing, and online learning. Managing these relationships and ensuring that vendors are also complying with GLBA requirements can be challenging. 
  4. Balancing security with accessibility: Higher education institutions must balance the need to protect sensitive information with making that information accessible to authorized individuals. This can be challenging, particularly in the case of research data, which may need to be shared with other researchers or made available to the public. 
  5. Cybersecurity risks: Cybersecurity threats are constantly evolving, and higher education institutions must stay vigilant to protect against these threats. This requires ongoing investment in security technologies and staff training. 
  6. Data Governance: Higher education institutions have a wide range of data and data types, some of which are regulated. Managing, classifying, and securing all the data can be a challenge. 
  7. Compliance with multiple regulations: Higher education institutions must comply with not only GLBA but also with other regulations such as HIPAA, FERPA, and CUI regulations, which can be difficult to navigate and comply with. 

Want to make sure you’re up-to-date on the newest compliance requirements? Grab our newest GLBA checklist guide to make sure you’re prepared for the new deadline this year.


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