OPEM-06

If you maintain remote access to the system, will you handle data in a FERPA-compliant manner?

Explanation

This question is asking whether your organization complies with the Family Educational Rights and Privacy Act (FERPA) when handling educational records remotely. FERPA is a federal law that protects the privacy of student education records. It applies to all schools that receive funds from the U.S. Department of Education. The question specifically focuses on remote access scenarios, which present heightened security risks. When employees or systems access educational data remotely (from outside your primary network), there are additional security considerations to ensure this sensitive data remains protected. This question appears in the PCI DSS category because there may be overlap in handling payment card information and educational records, particularly in educational institutions. The assessor wants to ensure that if you have remote access to systems containing student records, you're handling that data in compliance with FERPA requirements. To best answer this question: 1. Clearly state whether you handle FERPA-regulated data at all 2. If you do, explain your remote access controls and how they comply with FERPA requirements 3. Describe specific technical and procedural safeguards you've implemented 4. Mention any relevant policies, training, or compliance verification processes If you don't handle FERPA data at all, clearly state that fact, as it would make the question not applicable to your organization.

Example Responses

Example Response 1

Yes, our organization maintains FERPA compliance for all remote access to student educational records We implement multiple security controls specifically designed to protect FERPA data during remote access, including: (1) Multi-factor authentication required for all remote access to systems containing student records; (2) End-to-end encryption (TLS 1.2+) for all remote sessions; (3) Role-based access controls limiting data access to only authorized personnel with legitimate educational interests; (4) Comprehensive audit logging of all remote access activities; (5) Automatic session timeouts after 15 minutes of inactivity; and (6) Prohibition of downloading or storing FERPA data on personal devices All employees with remote access privileges receive annual FERPA compliance training, and we conduct quarterly compliance audits to verify adherence to these policies.

Example Response 2

Yes, as an educational technology provider, we handle FERPA-regulated data and maintain strict compliance when remotely accessing any systems containing student information Our remote access infrastructure uses a zero-trust security model with the following controls: (1) VPN with split tunneling disabled to prevent data leakage; (2) Device posture checking before connection is permitted; (3) Just-in-time privileged access management for administrative functions; (4) Data loss prevention tools that monitor and prevent unauthorized transmission of student records; (5) Comprehensive logging and monitoring with alerts for suspicious access patterns Additionally, we maintain a formal FERPA compliance program overseen by our Chief Privacy Officer, who conducts regular assessments of our remote access procedures to ensure ongoing compliance with both the letter and spirit of FERPA regulations.

Example Response 3

No, our organization does not currently have FERPA-compliant remote access procedures in place While we do occasionally handle student records that fall under FERPA protection, our remote access solution was designed primarily for PCI DSS compliance and has not been specifically configured to address FERPA requirements We recognize this as a compliance gap and have initiated a project to implement FERPA-specific controls for remote access scenarios, including enhanced access controls, improved audit logging, and staff training on FERPA requirements We expect to have these controls fully implemented within the next 90 days In the interim, we have implemented a compensating control that requires all remote access to FERPA-protected data to be approved by our security team on a case-by-case basis.

Context

Tab: Case-Specific
Category: Payment Card Industry Data Security Standard (PCI DSS)