How higher education leaders can navigate evolving GLBA requirements

Colleges and universities are facing increasing regulatory and operational pressure to demonstrate mature, well-governed cybersecurity programs. A key driver is the Gramm-Leach-Bliley Act Safeguards Rule (GLBA), a U.S. regulation that requires organizations handling sensitive financial information to implement and maintain appropriate safeguards. As a result, a growing number of institutions are reevaluating their cybersecurity programs. They’re turning to the NIST Cybersecurity Framework as a structured way to translate GLBA requirements into a measurable and defensible security program.

This article outlines how GLBA requirements apply to higher education institutions, where gaps commonly emerge, and why the NIST Cybersecurity Framework is becoming a preferred operating model. It then explores how institutions can strengthen their GLBA posture through structured risk assessments, governance and accountability, documentation practices, third-party risk management, and development of a strategic cybersecurity roadmap.

Institutions that fail to evolve their programs risk increased audit findings, operational disruption, costly remediation efforts, and lost trust. Those that adopt a structured framework can build more resilient, sustainable cybersecurity programs that achieve even more than just compliance.

Understanding GLBA expectations for higher education

Under GLBA, institutions that handle student financial information must maintain a written information security program (WISP) aligned to their size, complexity, and risk profile. Current requirements include: 

• Designating a qualified individual to oversee the information security program
• Conducting a risk assessment that identifies reasonably foreseeable internal and external threats
• Implementing safeguards to protect customer information (administrative, technical, and physical)
• Regularly testing and monitoring controls
• Overseeing service providers with access to sensitive data
• Adjusting the program based on testing results and changes in risk

While institutions have had flexibility in how they meet these requirements, expectations are tightening. Regulators increasingly expect clear governance, execution, and documentation.

Why the NIST Cybersecurity Framework is gaining traction

While GLBA does not mandate a specific cybersecurity framework, many institutions are increasingly aligning their programs with the NIST Cybersecurity Framework because it provides a clear structure for managing cybersecurity risk.

The framework organizes security programs into five functions that reflect the cybersecurity risk management lifecycle: 

• Identify – understanding your systems, data, and risks
• Protect – implementing safeguards such as access controls, data protection, and user awareness
• Detect – continuously monitoring systems and identifying cybersecurity events
• Respond – managing incidents
• Recover – restoring operations when disruptions occur

This structure provides a practical method for translating GLBA’s general expectations into a comprehensive and measurable security program.

Strengthening GLBA programs using the NIST framework

Institutions seeking to improve their GLBA posture can begin with several practical steps.

Conduct a structured risk and control assessment.

A structured assessment helps institutions evaluate how existing safeguards align with the NIST framework. While many already perform activities that support these functions, they’re often undocumented or implemented inconsistently. A formal assessment identifies gaps and establishes a baseline for improvement.

Establish clear governance and accountability.

Effective programs require defined ownership and governance. Institutions should clearly assign and document responsibility for key controls. Leadership oversight and buy-in are also essential for managing cybersecurity risk.

Strengthen documentation and evidence.

Policies alone don’t demonstrate compliance. Auditors and regulators increasingly expect evidence that security controls operate as intended. Institutions should maintain evidence such as quarterly access reviews, incident response test results, vendor due diligence records, and system configuration baselines.

Enhance third-party risk management.

Vendor oversight is essential due to their access to financial aid systems, student information systems, and other sensitive data. Institutions should maintain an inventory of service providers and implement consistent processes to evaluate and monitor their security practices. This extends beyond traditional IT vendors and includes any third party with access to sensitive information.

Develop a strategic security roadmap.

Cybersecurity maturity cannot be achieved through isolated projects. A multi-year roadmap helps institutions prioritize improvements based on risk, operational impact, and available resources. An effective roadmap also contains a list of items to address immediately to improve cybersecurity posture, along with more medium- and long-term objectives.

Common audit findings

Most GLBA findings come down to gaps in structure, accountability, and traceability – not missing controls. These are governance and execution issues, not technical ones. Controls often exist but can’t clearly show that they’re defined, consistently performed, and supported by evidence. Common findings include:

• Undocumented risk assessments: Risk activities may occur, but there’s no defined methodology, formal documentation, or clear linkage to controls.
• Unclear control ownership: Control owners aren’t defined, leading to inconsistent execution and gaps in accountability. 
• Weak evidence practices: Evidence is incomplete, outdated, or doesn’t clearly demonstrate that the control is operating as intended.
• Policy and practice misalignment: Policies exist but are outdated, too high level, or don’t reflect how processes actually operate.
• Limited ongoing oversight: Organizations rely on point-in-time activities instead of continuous monitoring and governance.

Why waiting increases risk

Delaying cybersecurity governance improvements can lead to audit findings, particularly in areas such as incomplete risk assessments, insufficient documentation, and unclear ownership of security responsibilities. These issues frequently surface during financial aid program reviews or external compliance assessments, resulting in costly, time-constrained, and disruptive remediation efforts.

Institutions that begin aligning their programs with structured frameworks can improve their security posture over time while maintaining operational stability.

Moving from compliance to resilience

The GLBA Safeguards Rule was designed to protect sensitive financial information through sound security practices. Institutions that approach these requirements strategically can achieve far more than regulatory compliance. As cyber threats continue evolving and regulatory expectations continue rising, this level of maturity is becoming essential.

By aligning with the NIST framework, colleges and universities can build structured, defensible, and resilient cybersecurity capability that actually work in practice – providing protection rather than just checking a box.

Whether preparing for an upcoming audit, reassessing your GLBA posture, or planning for future regulatory shifts, early action with expert guidance can significantly reduce risk and cost.