What is the primary objective of **FERPA**?

**FERPA’s primary objective is to protect the privacy of parents and students by regulating access to and disclosure of personally identifiable information (PII) in education records.** Enacted in 1974 as section 444 of the General Education Provisions Act (20 U.S.C. § 1232g), with regulations at 34 CFR Part 99, it grants rights to inspect records within 45 days (§99.10), seek amendments for inaccurate or misleading content (§99.20), and require written consent for disclosures unless exceptions apply (§99.30).

Who is legally or professionally required to comply with **FERPA**?

**FERPA applies to educational agencies or institutions receiving federal funds under programs administered by the U.S. Secretary of Education.** This includes public K-12 schools, most private K-12 schools receiving funds, and postsecondary institutions via student aid like Pell Grants (§99.1). Coverage extends institution-wide to all components maintaining education records (§99.1(d)); non-recipients are exempt (§99.1(b)).

Does **FERPA** require an external audit or third-party certification?

**No, FERPA does not mandate external audits or third-party certification.** Compliance is demonstrated through internal policies, annual notifications (§99.7), disclosure recordkeeping (§99.32), and response to Department of Education investigations by the Family Policy Compliance Office (§99.60). Institutions must maintain auditable records but self-certify adherence.

How often should an assessment for **FERPA** be performed?

**FERPA requires annual notification of rights to parents or eligible students (§99.7(a)), but does not specify periodic assessments.** Institutions should conduct ongoing reviews of policies, access controls, and vendor contracts, with regular internal audits of disclosure logs (§99.32) and data practices to ensure compliance, especially after system changes or incidents.

What are the consequences of non-compliance with **FERPA**?

**Non-compliance can result in Department of Education enforcement, including withholding federal funds, cease-and-desist orders, or termination of funding eligibility (§99.67(a)).** The Family Policy Compliance Office investigates complaints filed within 180 days (§99.63-64); third-party violators face five-year PII access bans (§99.67(c)-(e)). No private right of action exists.

Can **FERPA** be mapped to other international frameworks?

**FERPA is a U.S.-specific statute with no official mappings to international frameworks provided in its regulations.** While concepts like PII protection and consent align conceptually with laws like GDPR, 34 CFR Part 99 contains no cross-references; institutions must address overlaps independently through internal governance.

What is the first step to begin implementing **FERPA**?

**The first step is to publish an annual notification of FERPA rights to parents of students in attendance or eligible students (§99.7(a)).** This must detail rights to inspect/review records, seek amendments, consent to disclosures (with exceptions), and file complaints, plus procedures and school official criteria if used (§99.7(a)(3)).

What is the primary objective of **APRA CPS 234**?

**APRA CPS 234 requires regulated entities to maintain an information security capability commensurate with vulnerabilities and threats to minimise the likelihood and impact of information security incidents on the confidentiality, integrity or availability (CIA) of information assets.** This includes assets managed by related parties and third parties, enabling continued sound operation of the entity (paragraphs 1, 15-16). Boards hold ultimate responsibility (paragraph 13).

Who is legally or professionally required to comply with **APRA CPS 234**?

**APRA CPS 234 applies to all APRA-regulated entities, including authorised deposit-taking institutions (ADIs), general insurers, life companies, private health insurers, and RSE licensees.** For Heads of groups, it applies group-wide, including non-regulated entities (paragraph 4). Foreign ADIs, Category C insurers, and eligible foreign life insurance companies comply only for Australian branch operations (paragraph 3). Effective 1 July 2019, with third-party assets from the earlier of contract renewal or 1 July 2020 (paragraph 6).

Does **APRA CPS 234** require an external audit or third-party certification?

**APRA CPS 234 does not mandate external audits or third-party certifications.** It requires internal audit to review design and operating effectiveness of information security controls, including those maintained by related parties and third parties, by appropriately skilled personnel (paragraphs 32-34). Where relying on third-party assurance for material-impact assets, internal audit must assess its adequacy (paragraph 34). Systematic testing must use functionally independent, skilled specialists (paragraph 30).

How often should an assessment for **APRA CPS 234** be performed?

**APRA CPS 234 requires the testing program to be reviewed at least annually, or upon material change to information assets or the business environment (paragraph 31).** Testing frequency of controls must be commensurate with the rate of change in vulnerabilities/threats, asset criticality/sensitivity, incident consequences, exposure to untrusted environments, and asset changes (paragraph 27). Incident response plans must be reviewed and tested annually (paragraph 26).

What are the consequences of non-compliance with **APRA CPS 234**?

**Non-compliance with APRA CPS 234 exposes entities to APRA's prudential enforcement powers, including directions, remediation requirements, increased supervision, and potential penalties under enabling Acts.** Entities must notify APRA within **72 hours** of material incidents (actual/potential material impact on entity/customers; paragraph 35) and within **10 business days** of material control weaknesses not remediable timely (paragraph 36). APRA may adjust requirements in writing (paragraph 11).

Can **APRA CPS 234** be mapped to other international frameworks?

**Yes, APRA CPS 234's outcomes-based requirements for governance, controls, testing, and third-party management can be mapped to frameworks like ISO 27001 and NIST Cybersecurity Framework.** It aligns with ISO 27001's ISMS structure for policies/controls and NIST's functions (Identify, Protect, Detect, Respond, Recover), enabling proportional implementation while meeting CPS 234's board accountability, systematic testing (paragraphs 27-31), and notification timelines (paragraphs 35-36).

What is the first step to begin implementing **APRA CPS 234**?

**The first step to implement APRA CPS 234 is for the Board to assume ultimate responsibility and approve a governance framework defining information security roles and responsibilities (paragraphs 13-14).** This includes maintaining a commensurate information security capability (paragraph 15), followed by classifying information assets by criticality and sensitivity to drive controls (paragraph 20).

FERPA vs APRA CPS 234

Standards Comparison

FERPA

Mandatory

1974

U.S. federal regulation protecting student education records privacy

APRA CPS 234

Mandatory

2019

Australian prudential standard for information security resilience.

Quick Verdict

FERPA protects US student records with access rights for schools receiving federal funds, while APRA CPS 234 mandates cyber resilience for Australian financial firms. Schools comply to retain funding; banks ensure operational continuity and avoid sanctions.

Student Privacy

FERPA

Family Educational Rights and Privacy Act of 1974

Cost

€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Grants rights to inspect, amend, and consent for disclosures
Requires prior written consent for PII from education records
Applies to institutions receiving federal education funds
Defines expansive PII including linkable indirect identifiers
Mandates annual notices and disclosure recordkeeping logs

Information Security

APRA CPS 234

APRA Prudential Standard CPS 234 Information Security

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

Board ultimate responsibility for information security
72-hour notification for material incidents to APRA
Third-party assets and capability assessments required
Systematic risk-based control testing program
Internal audit assurance of all controls

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

FERPA Details

What It Is

FERPA (Family Educational Rights and Privacy Act of 1974, 20 U.S.C. §1232g; 34 CFR Part 99) is a U.S. federal regulation safeguarding student education records privacy. It applies to educational agencies/institutions receiving federal funds, granting parents/eligible students rights to access, amend, and control PII disclosures. Approach is rights-based with consent requirements and enumerated exceptions.

Key Components

Core rights: inspect/review within 45 days, amend inaccurate records, prior consent for disclosures.
Definitions: education records (directly related to student, maintained by institution), expansive PII (direct/indirect/linkable identifiers), directory information.
Disclosure rules: consent default + exceptions (school officials/legitimate interest, emergencies, audits).
Compliance obligations: annual notices, disclosure logs, hearings. No certification; enforced by funding leverage.

Why Organizations Use It

Mandatory for federal funding preservation.
Mitigates enforcement risks, lawsuits, reputational harm.
Builds stakeholder trust, enables secure vendor/data sharing.
Strategic governance for privacy, analytics innovation.

Implementation Overview

Phased program: governance setup, data inventory/classification, policies/training, RBAC/technical controls, vendor DPAs, monitoring/audits. Targets K-12/postsecondary institutions; ongoing self-compliance via DOE complaints/investigations.

APRA CPS 234 Details

What It Is

APRA Prudential Standard CPS 234 (Information Security) is a binding Australian regulation for APRA-regulated financial entities. Effective from 1 July 2019, it requires maintaining an information security capability commensurate with threats and vulnerabilities to minimize impacts on confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties. It adopts a risk-based, assurance-driven approach emphasizing governance and resilience.

Key Components

Board accountability (para 13), defined roles (para 14), policy framework (paras 18-19)
Asset classification by criticality and sensitivity (para 20)
Lifecycle controls (para 21), incident detection/response (paras 23-26)
Systematic testing (paras 27-31), internal audit assurance (paras 32-34)
72-hour notification for material incidents, 10 business days for control weaknesses (paras 35-36) No fixed controls; proportional to risk.

Why Organizations Use It

Mandatory for ADIs, insurers, super funds to avoid penalties, enforcement
Reduces cyber risks, ensures operational continuity
Strengthens third-party oversight, builds customer/stakeholder trust
Provides competitive resilience in finance

Implementation Overview

Phased: gap analysis, asset inventory, governance/policies, controls/testing, assurance. Applies to all sizes in banking/insurance/super; group-wide. APRA supervision, no formal certification but notifications/audits required. (178 words)

Key Differences

Aspect	FERPA	APRA CPS 234
Scope	Student education records privacy and access	Information security and cyber resilience
Industry	US education institutions receiving federal funds	Australian financial services (banks, insurers)
Nature	Federal privacy law with funding enforcement	Mandatory prudential standard with board accountability
Testing	No systematic testing; recordkeeping audits	Systematic independent control testing annually
Penalties	Loss of federal funding, complaints process	Regulatory directions, funding restrictions, sanctions

Scope

FERPA

Student education records privacy and access

APRA CPS 234

Information security and cyber resilience

Industry

FERPA

US education institutions receiving federal funds

APRA CPS 234

Australian financial services (banks, insurers)

Nature

FERPA

Federal privacy law with funding enforcement

APRA CPS 234

Mandatory prudential standard with board accountability

Testing

FERPA

No systematic testing; recordkeeping audits

APRA CPS 234

Systematic independent control testing annually

Penalties

FERPA

Loss of federal funding, complaints process

APRA CPS 234

Regulatory directions, funding restrictions, sanctions

Frequently Asked Questions

Common questions about FERPA and APRA CPS 234

FERPA FAQ

APRA CPS 234 FAQ

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FERPA

APRA CPS 234

Quick Verdict

FERPA

Key Features

APRA CPS 234

Key Features

Detailed Analysis

FERPA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

APRA CPS 234 Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

FERPA FAQ

What is the primary objective of FERPA?

Who is legally or professionally required to comply with FERPA?

Does FERPA require an external audit or third-party certification?

How often should an assessment for FERPA be performed?

What are the consequences of non-compliance with FERPA?

Can FERPA be mapped to other international frameworks?

What is the first step to begin implementing FERPA?

APRA CPS 234 FAQ

What is the primary objective of APRA CPS 234?

Who is legally or professionally required to comply with APRA CPS 234?

Does APRA CPS 234 require an external audit or third-party certification?

How often should an assessment for APRA CPS 234 be performed?

What are the consequences of non-compliance with APRA CPS 234?

Can APRA CPS 234 be mapped to other international frameworks?

What is the first step to begin implementing APRA CPS 234?

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Run Maturity Assessments with GRADUM

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TISAX vs GRI

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