Stay Compliant with GLBA Without Breaking Your Budget

GLBA Compliance Made Simple for Higher Education

In recent years, higher education institutions have found themselves under increasing scrutiny when it comes to protecting sensitive financial data. The Gramm–Leach–Bliley Act (GLBA) Safeguards Rule—aimed initially at financial institutions—now applies to colleges and universities that process student financial aid information.
And the stakes are getting higher. The U.S. Department of Education has tightened enforcement and is actively reviewing institutions’ compliance during audits. The risks of falling short are serious: loss of Title IV funding, reputational damage, costly remediation, and possible legal implications.

The Challenge: Compliance on a Limited Budget

While compliance is critical, many higher ed institutions face a difficult reality—limited budgets and stretched IT/security teams. GLBA compliance requires a combination of governance, technical safeguards, training, and vendor oversight. Doing all of that in-house, from scratch, can quickly overwhelm resources.

The Columbia Advisory Group Approach

At Columbia Advisory Group (CAG), we’ve helped colleges and universities across the country navigate GLBA requirements efficiently and affordably. Our Governance, Risk & Compliance (GRC) services are tailored to the unique needs of higher education, helping institutions:
  • Identify gaps in their current GLBA Safeguards Program
  • Implement practical controls that satisfy regulatory requirements
  • Leverage cost-effective solutions that fit budget constraints
  • Reduce audit risk through ongoing compliance monitoring and reporting
We focus on scalable, results-driven solutions—never one-size-fits-all checklists. Our team understands the academic environment and works closely with leadership, IT teams, and compliance officers to deliver security that works in the real world.

Why It Matters Now

GLBA enforcement isn’t slowing down. In fact, with recent updates to the Safeguards Rule, institutions must now demonstrate ongoing compliance—not just point-in-time readiness. The sooner you address any gaps, the lower your risk of penalties, data breaches, and operational disruptions.

Partner with a Trusted Compliance Ally

With CAG, you’re not just buying compliance—you’re gaining a partner who brings deep regulatory expertise and a proven track record of helping higher ed institutions stay secure and compliant without draining budgets.
Take the first step today.
Contact us to discuss how CAG can help your institution meet GLBA obligations, protect sensitive data, and avoid costly penalties—while keeping costs under control.

When Budgets Tighten – Your IT Strategy Matters More Than Ever

Across the higher education and public sectors, a familiar challenge is re-emerging—tightening budgets and rising pressure to reduce IT spend without compromising user experience or core capabilities.
At CAG, our senior team has helped over 100 organizations—from Fortune 500 companies to community colleges and large universities—tackle these challenges head-on. Many higher ed and public institutions are facing meaningful budget reductions for the first time in years. Some have time to plan, others have to move quickly.
One often overlooked opportunity? Making better use of the talent institutions already have. Rather than filling roles with new hires, we help assess whether existing team members have the capabilities to take on those responsibilities—saving money and empowering staff at the same time.

Your Institution Isn’t Generic. Neither Is Our Approach.

IT is central to everything from student services and classroom delivery to administration and research. Cutting spend too aggressively—or in the wrong areas—can lead to operational bottlenecks, user frustration, and security risks. But doing nothing isn’t an option either. Leaders are being asked to find savings—and fast.
That’s why our approach always starts with a conversation. No two institutions face the same challenges, and no template can capture the nuance of your environment. Our recommendations are grounded in industry benchmarks but tailored to your structure, goals, and priorities.
Whether you’re looking to consolidate technology platforms, avoid unnecessary hires by better leveraging internal talent, or reinvest savings into mission-critical areas, our team works directly with yours to define and deliver cost strategies that make sense in your world.

What Makes Our Approach Work?

  • Tailored Assessments: No cookie-cutter templates. We assess your IT environment against both best practices and your internal goals.
  • Real Benchmarks: Our insights come from real-world data across higher ed, public sector, and commercial clients.
  • Operational Focus: We don’t just identify savings, we help you redirect those savings to improve the capabilities that matter most.
  • People Optimization: We evaluate internal staff capabilities to see where roles can be filled or expanded without the need for external hires.
  • Minimal Disruption: Our methods are designed to reduce costs with as little impact to users, services, and uptime as possible.

You Don’t Have to Guess Where to Cut — Let’s Talk

Too often, IT leaders are left to guess which levers to pull. But with the right approach, you can cut costs without cutting capability and come out of a tightening cycle with an IT operation that’s not just leaner, but stronger.
If you’re facing budget pressure or preparing for difficult decisions, you don’t have to go it alone. Let’s set up a conversation with one of our senior experts. We’ll walk you through a custom-tailored assessment designed around your environment—and your goals.
Connect with us today to get started: https://columbiaadvisory.com/contact

Interim CIO Services: Enhancing IT Leadership and Continuity in Higher Education

In higher education, the role of the Chief Information Officer (CIO) is foundational to the success of the institution’s technological infrastructure, aligning IT with academic, operational, and student services. When a CIO position becomes vacant—whether due to retirement, departure, or a transitional phase—ensuring continuity and stability in IT operations is paramount. Columbia Advisory Group (CAG) offers interim CIO services to bridge these critical gaps, providing not just leadership but also strategic direction that keeps IT on course and aligned with institutional goals.

Why Interim CIO Services Are Critical for Higher Education

Columbia Advisory Group has built a reputation for providing Interim CIO services to a diverse array of higher education institutions. Our interim leadership provides institutional resilience during times of change.

IT Leadership and Strategic Continuity

Leadership transitions, particularly in IT, present a unique set of challenges. The departure or retirement of a CIO can create a leadership vacuum that jeopardizes the continuity of critical IT operations. At CAG, our Interim CIOs step into the role with a clear mandate: to maintain momentum, deliver results, and drive strategic initiatives. What differentiates us is that while we assign an Interim CIO to your institution, our clients also gain access to the full breadth of CAG’s senior leadership team, whose collective CIO expertise provides immediate backup and strategic support when needed.

Holistic IT Strategy and Leadership

An Interim CIO from CAG brings a broad strategic perspective, enabling institutions to navigate complex IT challenges while positioning the organization for long-term success. From overseeing the IT budget to managing vendor interactions, our Interim CIOs ensure that every facet of your IT operation is aligned with the institution’s overarching goals. They also facilitate critical communication between senior leadership and department heads, keeping all stakeholders engaged and informed.
Our Interim CIOs also oversee the management of IT performance metrics and capital expenditures, ensuring that investments are aligned with both current needs and future objectives. Furthermore, they evaluate and execute milestones within the IT roadmap, ensuring that strategic initiatives remain on track. With CAG’s Interim CIOs, you gain a partner who helps you define a path forward while maintaining operational excellence during times of leadership change.

Tailored IT Leadership at Every Level

CAG understands that institutions may require leadership not just at the CIO level but across various IT management tiers. Whether your needs call for interim leadership at the Director or Manager level, CAG provides flexible, scalable solutions. Our Interim CIO service is designed to offer support that is tailored to your institution’s specific needs, ensuring that all levels of IT leadership are addressed and that the department remains functional, efficient, and aligned with institutional priorities.

Facilitating Collaboration and Communication Across the Institution

Effective leadership in IT is not just about managing systems—it’s about managing people and processes. An Interim CIO from CAG excels in facilitating communication across your institution, ensuring that both senior leadership and department leaders remain aligned on IT priorities. Our CIOs also run IT steering committee meetings, providing the forum for strategic discussions and decision-making. By managing IT staff and coordinating cross-departmental collaboration, our Interim CIOs ensure that IT issues are addressed proactively and that IT performance continues to support the broader goals of the institution.

Conclusion

Columbia Advisory Group’s Interim CIO services go beyond just filling a temporary gap—they are about providing your institution with the strategic leadership and operational continuity needed to thrive during times of transition. With our Interim CIOs, your institution benefits from seasoned leadership backed by the collective knowledge of CAG’s senior management team. We ensure that your IT department continues to function at a high level while also guiding the institution toward long-term strategic goals.
Our Interim CIO service provides not only the expertise needed to maintain IT excellence but also the strategic vision required to drive your institution forward. Contact us today to learn how we can help you navigate your leadership transition and ensure the continued success of your IT strategy. To learn more, visit columbiaadvisory.com/contact

CAG’s IT Solutions: Powering a Smooth Return to Office in Higher Education

As colleges and universities navigate the shift away from remote work, many institutions are facing significant challenges, especially when it comes to supporting their IT staff. A recent Forbes survey found that nearly 45% of workers would consider changing jobs if forced back into the office, which is a sentiment strongly echoed within IT departments. The return-to-office mandates have put extra strain on these teams, who were already stretched thin, juggling system security, regulatory compliance, and technology implementation. The challenges that arise from this transition are compounded by the need for constant innovation, efficient systems, and responsive support, all while dealing with limited resources.

The Challenges of the Return-to-Office Mandates

The push to eliminate work-from-home (WFH) policies in higher education has left IT departments grappling with several issues. According to a report by Forbes, nearly half of workers say they would consider changing jobs if forced back into the office, and this sentiment is felt strongly in the IT sector. The pressure to maintain productivity, support remote learning tools, and ensure seamless integration between on-campus and online systems has led to an environment of burnout and frustration.
As institutions of higher learning adjust to post-pandemic realities, IT departments are seeing the need for not just physical infrastructure but also an adaptable digital strategy that supports hybrid models, enhances the user experience, and ensures security compliance. This is where strategic, outsourced IT support becomes invaluable.

How CAG Fills the Gap

At Columbia Advisory Group (CAG), we understand these challenges and have tailored our IT consulting and managed services specifically for the higher education sector. With over 350 strategic projects and 100+ outsourcing engagements, CAG provides comprehensive solutions that address these pain points directly, helping higher education institutions transition smoothly while alleviating the burden on their IT teams.

Key Services CAG Offers:

  1. Consulting for IT Planning and Execution: We offer end-to-end support for IT project planning, execution, and vendor management. CAG helps higher education institutions choose the right technology platforms, implement solutions effectively, and manage complex systems without disruption to daily operations.
  2. CRM and Application Implementation: CAG supports institutions in implementing and optimizing CRM systems and critical applications to ensure seamless interactions between faculty, staff, and students. Our expertise in application management helps institutions adopt new technologies that enhance overall functionality and improve the user experience.
  3. IT Assessments: CAG’s detailed IT assessments help identify performance gaps and opportunities for improvement in applications, infrastructure, and operations. Our scalability assessments ensure that technology can grow with the institution’s needs, and our budgetary and health analyses provide valuable insights into cost optimization.
  4. IT Governance, Risk Management, and Compliance: In an era of heightened scrutiny around data privacy and security, CAG excels in ensuring regulatory compliance. Our services include NIST 800-53 and 171 framework assessments, penetration testing, and ongoing ISO services to ensure that IT infrastructure adheres to federal, state, and institutional regulations.
  5. Shared and Managed IT Services: We help institutions optimize their IT operations with flexible, cost-effective managed solutions. From help desk management and network maintenance to application governance and fractional IT leadership (including interim CIO roles), CAG provides support where it’s most needed, enabling IT teams to focus on strategic initiatives rather than routine tasks.
  6. Improved User Experience: CAG’s focus on intuitive systems and seamless interaction ensures that faculty, staff, and students can navigate IT platforms with ease. This user-centered approach fosters greater productivity and satisfaction, even as institutions adapt to a changing work environment.

The Impact of Strategic IT Support

By partnering with CAG, higher education institutions can effectively manage their IT resources, reduce operational costs, and improve overall productivity. Our expertise in compliance frameworks and IT governance ensures that institutions remain secure while also enhancing the experience for end-users.
As the landscape of higher education IT continues to evolve, CAG remains committed to helping institutions stay ahead of the curve with the strategic guidance and managed services they need to thrive.
Eric Olson, Senior Director of Business Development at CAG, states, “We understand the unique challenges faced by higher education institutions in this rapidly changing landscape. Our focus is on providing tailored, actionable IT solutions that not only meet today’s needs but also prepare universities for the future.”
Learn more about how our services in IT planning, compliance, and managed services can streamline your operations and enhance your IT infrastructure: columbiaadvisory.com/contact

Strengthening Cybersecurity in Higher Education with Columbia Advisory Group’s vCISO Services

The digital landscape in higher education is rapidly evolving, bringing increased cybersecurity threats to institutions that manage vast amounts of sensitive student, faculty, and research data. The rise of ransomware attacks, data breaches, and growing regulatory requirements underscores the need for a strategic, proactive approach to cybersecurity.
However, not all institutions have the resources to hire a full-time Chief Information Security Officer (CISO). That’s where Columbia Advisory Group’s Virtual CISO (vCISO) services provide a cost-effective, expert-driven solution—enhancing cybersecurity, ensuring compliance, and reducing risk without the expense of a full-time hire.

Why Columbia Advisory Group’s vCISO Services?

Cybersecurity in higher education presents unique challenges: large, complex networks, multiple stakeholders (students, faculty, and staff), and a rapidly changing regulatory environment. Columbia Advisory Group (CAG) understands these complexities and delivers vCISO services tailored specifically to the needs of colleges and universities.
Here’s how our vCISO services help institutions navigate an increasingly dangerous digital landscape:

1. Governance, Risk, and Compliance (GRC)

Regulatory compliance is a top priority for higher education institutions. Laws such as FERPA, GLBA, and HIPAA mandate strict data protection requirements, making it critical to establish strong security policies and controls.
Columbia Advisory Group’s vCISO services integrate a proactive Governance, Risk, and Compliance (GRC) framework to ensure institutions meet regulatory obligations while staying prepared for audits. We help:
  • Develop and enforce security policies, controls, and compliance strategies
  • Align cybersecurity initiatives with audit readiness and risk management
  • Ensure continuous compliance with evolving regulations
By taking a proactive approach to GRC, institutions can reduce the risk of fines, improve security posture, and build trust with students, faculty, and regulators.

2. Risk-Based Vulnerability Management

Higher education institutions are prime targets for cybercriminals due to their expansive IT environments and diverse infrastructure. But how do you prioritize vulnerabilities effectively?
Our vCISO services identify, assess, and prioritize vulnerabilities based on actual risk, ensuring that critical security gaps are addressed before they can be exploited. We:
  • Conduct comprehensive risk assessments across IT systems and networks
  • Prioritize vulnerabilities based on their potential impact
  • Provide actionable strategies to mitigate threats proactively
By focusing on high-risk vulnerabilities first, we help institutions minimize cyber risks while optimizing resources.

3. Attack Surface Management

As institutions adopt more devices, applications, and cloud services, their attack surface expands—creating more potential entry points for cyber threats.
Columbia Advisory Group’s vCISO services provide:
  • Comprehensive attack surface monitoring to identify security gaps
  • Real-time risk assessments to prevent unauthorized access
  • Advanced security tools to detect, analyze, and reduce vulnerabilities
By continuously managing and securing the attack surface, institutions can mitigate risks and protect critical assets from evolving cyber threats.

4. Audit Readiness and Cybersecurity Maturity

Higher education institutions must be prepared for internal and external audits to maintain compliance with regulatory and industry standards. Our vCISO services help institutions:
  • Align security policies and procedures with audit frameworks
  • Conduct cybersecurity maturity assessments
  • Test and validate security controls to ensure compliance and resilience
By staying audit-ready, institutions avoid penalties, maintain trust, and demonstrate a strong commitment to data protection.

5. Incident Response and Crisis Management

Preventing cyber threats is essential, but so is preparing for the worst-case scenario. Our vCISO services include incident response planning to help institutions:
  • Develop and refine incident response playbooks
  • Identify threat detection and response strategies
  • Establish rapid recovery plans to minimize downtime
Whether it’s ransomware, a data breach, or another cyber event, our team ensures institutions can respond effectively and recover quickly.

6. Strengthening Collaboration with ISO and CIO Leadership

Effective cybersecurity requires collaboration across the institution. Columbia Advisory Group’s vCISO services are designed to work alongside your existing leadership—not replace it.
We partner with:
  • Information Security Officers (ISO) to provide strategic direction, strengthen risk management, and align security initiatives with institutional goals.
  • Chief Information Officers (CIO) to ensure that cybersecurity measures support broader IT initiatives, from infrastructure modernization to emerging technology adoption.
By working in partnership with ISOs and CIOs, we create a unified, strategic cybersecurity approach that enhances resilience while supporting institutional priorities.

Why Higher Education Institutions Choose Columbia Advisory Group’s vCISO Services

Higher education institutions face an increasing volume of cyber threats, making a strategic, multi-layered approach to cybersecurity essential. Columbia Advisory Group’s vCISO services provide:
  • Expert cybersecurity leadership tailored to higher education
  • Comprehensive GRC, risk management, and compliance solutions
  • Integrated security strategies that align with IT and institutional goals
Whether addressing vulnerabilities, securing the attack surface, or preparing for audits, our vCISO services provide a customized cybersecurity strategy that meets the unique challenges of higher education.
By partnering with your ISO and CIO, we ensure that cybersecurity is seamlessly integrated across all operations, creating a more secure, resilient, and future-ready institution.
Contact us today at columbiaadvisory.com/contact to learn how we can help your institution build a stronger cybersecurity posture in an increasingly complex digital world.

Strategic Cloud Transformation in Education: Unlocking Oracle Cloud Infrastructure to Achieve Institutional Goals

For educational institutions running Oracle-based Student Information Systems (SIS) or ERP solutions on-premise, the need to refresh outdated hardware or platforms can pose a significant challenge—especially when applications or customizations are incompatible with SaaS solutions. This is where Columbia Advisory Group (CAG) steps in. Leveraging Oracle Cloud Infrastructure (OCI), CAG offers a strategic path for schools to migrate their existing application stacks to a cloud environment without the need for extensive modifications.
OCI’s unique architecture enables institutions to move their systems to a flexible, secure, and scalable platform, reducing the cost of maintaining on-premise hardware by an impressive 30-50%. This cost efficiency is achieved while maintaining the functionality of the existing applications, allowing schools to maximize their current investments.

Why OCI Is Ideal for Educational Institutions

Educational institutions face distinctive challenges in balancing modern IT demands with limited budgets and regulatory requirements. OCI provides several key benefits tailored to address these needs:
  • High Performance and Consistency: OCI’s enterprise-grade infrastructure offers dedicated, high-performance computing and networking resources that enable schools to run demanding applications, such as SIS or ERP, with low latency. The dedicated compute resources also minimize interference from shared cloud users, ensuring consistent performance across critical applications.
  • Security and Compliance: Designed with built-in security features, OCI includes robust identity and access management, data encryption, and comprehensive monitoring capabilities. OCI’s certifications—such as SOC, HIPAA, and GDPR—make it ideal for educational institutions that handle sensitive student and faculty data and must adhere to strict compliance standards.
  • Cost Savings and Predictable Pricing: Moving to OCI can significantly reduce the costs associated with maintaining on-premise hardware. With no charges for ingress or egress traffic, schools can experience predictable pricing without hidden costs—ideal for budget-conscious educational institutions.
  • Seamless Integration and Flexibility: For schools with applications that require customization, OCI supports hybrid and multi-cloud architectures. This enables institutions to retain their customizations while leveraging a flexible cloud environment that aligns with their unique operational requirements.
  • Future-Ready Scalability: OCI’s flexible compute models, including bare-metal instances, virtual machines, and containers, allow institutions to scale resources up or down based on demand. This elasticity ensures that schools only pay for what they use, providing cost-efficiency as needs evolve.

How CAG Enables a Smooth Transition to OCI

CAG specializes in supporting educational institutions throughout their digital transformation journey, helping schools shift from legacy infrastructure to Oracle Cloud Infrastructure. By offering a targeted, customized migration strategy, CAG ensures institutions can transition to OCI without substantial application changes or disruptions to daily operations. With expertise in handling educational ERP and SIS solutions, CAG aligns OCI’s capabilities with each institution’s goals, maximizing operational efficiency, security, and budget.
Learn more about how Columbia Advisory Group is empowering educational institutions to achieve digital transformation through Oracle Cloud Infrastructure at columbiaadvisory.com.

Restoring Trust in Higher Education Cybersecurity

In the face of increasing cyber threats, higher education institutions are under pressure to secure sensitive data while fostering trust among students, faculty, and stakeholders. The EDUCAUSE 2025 Top 10 IT Issues report highlights the need to restore trust, which often hinges on robust cybersecurity strategies. Columbia Advisory Group (CAG) understands this challenge and partners with institutions to enhance trust through proactive cybersecurity measures that reinforce data integrity and operational resilience.

CAG’s Strategy for Strengthening Trust Through Cybersecurity

Trust isn’t just about mitigating risks; it’s about creating a secure digital environment that supports academic missions. CAG focuses on several key areas to support institutions, including:
  1. Virtual CISO Services: Recognizing the cost challenges of hiring dedicated CISOs, CAG offers virtual CISO services, allowing institutions to implement effective cybersecurity leadership without overextending their budgets. This guidance includes risk assessments, policy setting, and compliance support, all tailored to educational needs.
  2. Continuous Threat Monitoring: With emerging threats constantly evolving, CAG’s 24/7 Security Operations Center (SOC) provides continuous monitoring to detect and respond to threats before they escalate. This approach reassures institutions that they have a dedicated team always safeguarding their sensitive information.
  3. Data Governance and Compliance: Aligning with regulatory frameworks, such as NIST and ISO 27001, CAG’s data governance services enable institutions to manage data transparently and securely, reinforcing institutional integrity and regulatory compliance.

Real-World Applications: CAG’s Impact on Higher Education

CAG’s work demonstrates how tailored cybersecurity solutions restore trust and strengthen resilience. In several case studies, CAG has helped educational institutions create secure, compliant environments, even under challenging conditions:
  • Enhanced Security Roadmaps: By building strategic IT roadmaps, CAG has guided institutions in implementing cybersecurity policies that ensure data safety and compliance, ultimately building confidence among campus stakeholders.
  • ERP and Data Integration Solutions: For complex, multi-campus systems, CAG’s data integration solutions ensure seamless, secure data access, fostering trust by simplifying student and staff interactions while protecting personal information.

Practical Steps for Strengthening Trust

To further enhance security and build trust, CAG recommends that institutions:
  • Invest in Regular Audits and Assessments: Ongoing evaluations keep cybersecurity policies aligned with evolving threats.
  • Promote Security Awareness Training: Educating campus members fosters a community of shared responsibility, which is critical to trust.
  • Adopt Advanced Threat Detection Tools: Leveraging AI-driven tools for threat detection helps institutions proactively manage risks.

Partnering with CAG for a Secure Future

Columbia Advisory Group remains committed to supporting higher education’s security and trust goals. By leveraging expertise in cybersecurity, compliance, and operational resilience, CAG stands as a trusted partner for institutions navigating today’s digital complexities. For more information on CAG’s higher education solutions, explore our case studies and services.

GLBA audit findings will affect an institution’s participation in Title III and Title IV programs

On December 9, 2021, the Federal Trade Commission (F.T.C.) issued final regulations (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule), an essential component of the Gramm-Leach-Bliley Act’s (GLBA) requirements for protecting consumers’ privacy and personal information. Changes to the Safeguards Rule were effective on June 9, 2023.
The regulations use the terms “customer” and “customer information.” For an institution’s compliance with GLBA, customer information is obtained from providing a financial service to a student (past or present). Institutions or servicers offer a financial service when they, among other things, administer or aid in administering the Title IV programs, make institutional loans, including income share agreements, or certify or service a private education loan on behalf of a student.
The Department of Education conducts compliance audits, including the Gramm-Leach-Bliley Act (GLBA). GLBA audit findings will affect an institution’s participation in Title III and IV programs as any other determination of non-compliance. Failure to comply with GLBA will require resolution through a Corrective Action Plan (C.A.P.).
To reduce risk, an institution’s written information security program must include the following nine elements: Columbia Advisory Groups Governance, Risk, Compliance, and vCISO Security Services are equipped to handle all 9 Elements:
Element 1: Designates a qualified individual responsible for overseeing and implementing the institution’s information security program and enforcing the information security program
Element 2: Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks
Element 3: Provides for the design and implementation of safeguards to control the risks the institution or servicer identifies through its risk assessment.
Element 4: Provides for the institution or servicer to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented.
Element 5: Provides for implementing policies and procedures to ensure that personnel can enact the information security program.
Element 6: Addresses how the institution or servicer will oversee its information system service providers.
Element 7: Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the information security program.
Element 8: For an institution or servicer maintaining student information on 5,000 or more consumers, establishing an incident response plan should be addressed.
Element 9: An institution or servicer maintaining student information on 5,000 or more consumers addresses the requirement for its Qualified Individual to report regularly and at least annually to those with control over the institution on the institution’s information security program
For additional information, please review the final regulation:
Please let us know your questions, comments, or concerns. We would be more than happy to set up a meeting to discuss how Columbia Advisory Group. Security Services addresses each element.

About Columbia Advisory Group

Founded in Dallas in 2012, Columbia Advisory Group LLC (CAG) is an established IT consulting firm renowned for delivering cost-effective, meaningful, and practical IT solutions that solve complex business problems. Our seasoned teams offer comprehensive insight across diverse regulatory and economic environments, providing unbiased, straightforward analysis and recommendations. We pride ourselves on our deep understanding of IT while remaining software and hardware-agnostic. Regardless of your organization’s growth trajectory or economic landscape, we at CAG are adept at adapting to your unique needs and complexity, offering tailored solutions to drive your success.

Contact us at info@columbiaadvisory.com.

US DoE Reinforces Compliance with Update Safeguards Rule

On February 9, a significant update was issued by the U.S. Department of Education’s Federal Student Aid (FSA) office. The update pertains to compliance with the Safeguards Rule, a component of the Gramm-Leach-Bliley Act (GLBA) that deals with customer records, information security, and confidentiality. The GLBA, as described by the Federal Trade Commission (FTC), sets out to provide a robust framework for financial institutions to protect their customers’ personal data.

The GLBA applies to institutions of higher education that engage in financial activities such as providing student loans or banking services. Non-compliance with GLBA regulations may lead to the loss of eligibility for federal funding, potentially impacting the institution’s ability to offer financial aid to students. Non-compliance with GLBA regulations may lead to the loss of eligibility for federal funding, potentially affecting the institution’s ability to provide financial assistance to students.

The notice from the FSA emphasized the FTC’s decision to bring the revised Safeguards Rule into effect from June 9, 2023. The update outlines the major points of the Safeguards Rule following modifications made by the FTC in December 2021, highlighting FSA’s expectations for compliance.

A critical aspect of the announcement lies in how it applies the GLBA-defined term “customer information” to higher education, the domain of FSA’s oversight. “Customer information,” as defined under the GLBA, refers to data obtained during the provision of financial services to a student, whether current or past. The scope of financial assistance can include administering Title IV programs, offering institutional loans, including income share agreements, or servicing a private education loan for a student.

The FSA notice zeroes in on two main provisions of the revised Safeguards Rule, set to become effective in June:

  1. The requirement for institutions to encrypt customer data both at rest within institutional systems and during transmission across external networks.
  2. The mandate for multi-factor authentication (MFA) for anyone accessing customer information via institutional systems.

These provisions underscore the FSA’s commitment to enhancing data security and privacy within higher education institutions. However, the notice also alludes to some uncertainties in the enforcement process for Safeguards Rule compliance. It mentions that the FSA will resolve compliance issues linked to the new Safeguards Rule provisions once they come into effect, primarily through institutional Corrective Action Plans (CAPs). It doesn’t clarify what “other means” could lead to a compliance investigation nor provides any framework for the CAPs that institutions need to create and execute.

The reference to “other means” may stir apprehension, echoing a situation years ago when an FSA official sent compliance notices based on media reports of alleged cybersecurity incidents. This necessitates clear communication from the FSA regarding potential triggers for compliance investigations, apart from federal single audit findings.

Concluding the notice, FSA reinforces the importance of institutions adopting the NIST SP 800-171 cybersecurity guidelines concerning federal student financial aid data. The federal government’s controlled unclassified information (CUI) regulations will soon mandate institutional compliance with NIST SP 800-171.

As these changes unfold, CAG is committed to closely collaborating with community members to ensure that FSA’s guidance and enforcement adequately address the regulations and compliance areas.

Where can I find more information? For additional information, see FSA’s electronic announcement: Updates to the Gramm-Leach-Bliley Act Cybersecurity Requirements. If you have questions regarding the Department of Education’s enforcement of GLBA, please get in touch with FSA_IHECyberCompliance@ed.gov. More information is also available on the Federal Trade Commission’s website. Updates to the Gramm-Leach-Bliley Act Cybersecurity Requirements | Knowledge Center

 

About Columbia Advisory Group:
Columbia Advisory Group (CAG) is a leading Information Technology (IT) consulting firm. CAG’s team has assessed and helped improve the performance of more than 300 technology organizations and IT departments, including many higher education institutions, state agencies, and Fortune 50 customers. Practice specialty areas include Infrastructure, IT Service Management, Cybersecurity, and A/V Services. CAG improves business outcomes with IT insights and expert technical support. Based in Dallas, Texas, CAG works extensively with clients throughout the U.S. Contact us at .

Leveraging Wi-Fi Analytics for Effective Space Utilization Planning in Universities

Universities are intricate organisms that continue to expand and evolve. Among the myriad of challenges they face, efficient space utilization stands out. An underappreciated yet invaluable tool for addressing this challenge is Wi-Fi analytics.

What are Wi-Fi Analytics?

Wi-Fi analytics involves the collection and examination of data associated with Wi-Fi usage within a designated area. This can include the number of unique users, their usage frequency and duration, as well as the specific zones within a facility where Wi-Fi usage peaks. When universities harness this data, they can gain insights into how their spaces are being used, which aids in making data-driven decisions about resource allocation and prioritization.

Benefits of Wi-Fi Analytics

Identifying Overused and Underused Spaces

One of the primary advantages of Wi-Fi analytics is its capacity to pinpoint overused and underused areas within a campus. For instance, let’s consider University A where Wi-Fi analytics revealed that a particular lecture hall was constantly filled to the brim. To accommodate the demand, they decided to add extra seats and enhance the sound system. Conversely, when they noticed a rarely used classroom, it was repurposed into a student lounge, increasing its usage significantly.

Optimizing Existing Spaces

Another crucial application of Wi-Fi analytics lies in the optimization of existing spaces. At University B, they found out that students prefer to gather in a specific part of the library. To cater to this preference, they added extra seating and resources in that area, resulting in increased student satisfaction and better space utilization.

Boosting Student Engagement

Understanding the way students use campus spaces and resources, universities can tailor their services to meet their needs and preferences. For example, University C observed through Wi-Fi analytics data that students tend to prefer group studying. In response, they created more collaborative spaces on campus, enhancing both student engagement and satisfaction.

Potential Challenges

While Wi-Fi analytics can bring invaluable insights, it’s essential to be aware of potential challenges, such as data privacy issues, technical difficulties, costs associated with implementation, and the need for staff training. Universities must take steps to ensure that any Wi-Fi analytics solution they implement complies with all relevant privacy regulations and that staff are adequately trained to use it effectively.

An Essential Tool for Space Planning

Wi-Fi analytics is undoubtedly a critical tool in space planning for higher education. It allows universities to improve the efficiency and effectiveness of their campus resources, providing essential insights into how their spaces are being used.

If you’re interested in exploring the potential of Wi-Fi analytics for your university, consider launching a pilot program. Reach out to professionals or organizations with experience in this field to understand what steps you need to take. The insights gained could be a game-changer in optimizing your university’s space and resources.

Ernest Bricker

Infrastructure Practice Lead

About Columbia Advisory Group

Founded in Dallas in 2012, Columbia Advisory Group LLC (CAG) is an established IT consulting firm renowned for delivering cost-effective, meaningful, and practical IT solutions that solve complex business problems. Our seasoned teams offer comprehensive insight across diverse regulatory and economic environments, providing unbiased, straightforward analysis and recommendations. We pride ourselves on our deep understanding of IT while remaining software and hardware-agnostic. Regardless of your organization’s growth trajectory or economic landscape, we at CAG are adept at adapting to your unique needs and complexity, offering tailored solutions to drive your success.

Contact us at info@columbiaadvisory.com.