FERPA
U.S. regulation protecting privacy of student education records
HITRUST CSF
Certifiable framework harmonizing 60+ security standards
Quick Verdict
FERPA mandates student record privacy for U.S. schools via access rights and disclosure limits, enforced by funding cuts. HITRUST CSF offers voluntary certification of harmonized security controls for healthcare and regulated firms, enabling trusted assurance and multi-framework compliance.
FERPA
Family Educational Rights and Privacy Act of 1974
Key Features
- Establishes rights to access, amend, and consent for education records
- Mandates prior written consent for PII disclosures with exceptions
- Defines expansive PII including direct and linkable indirect identifiers
- Requires annual notifications and detailed disclosure recordkeeping
- Applies to federally funded educational agencies institution-wide
HITRUST CSF
HITRUST Common Security Framework (CSF)
Key Features
- Harmonizes 60+ frameworks into single assessment
- Risk-based tailoring with defined factors
- Five-level maturity scoring model
- Tiered certifications (e1, i1, r2)
- MyCSF platform for scoping and evidence
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), codified at 20 U.S.C. § 1232g with regulations at 34 CFR Part 99, is a U.S. federal regulation. It safeguards privacy of personally identifiable information (PII) in education records for institutions receiving federal education funds. FERPA employs a rights-based approach with consent requirements, exceptions, and operational controls.
Key Components
- **Rights triadinspect/review within 45 days, amend inaccurate/misleading records, consent to disclosures.
- Broad definitions of education records and PII (direct/indirect/linkable identifiers).
- Disclosure rules: consent default plus enumerated exceptions (school officials, emergencies, audits).
- Obligations: annual notices, disclosure logs, access methods. Enforced via complaints, no certification.
Why Organizations Use It
- Maintains federal funding eligibility amid enforcement risks.
- Mitigates complaints, investigations, reputational harm.
- Builds trust with students, parents, stakeholders.
- Enables compliant data use for education, edtech, research.
- Drives efficient governance and risk management.
Implementation Overview
Phased program: governance, data inventory/classification, policies/training, RBAC/logging, vendor DPAs. Applies to K-12/postsecondary funded entities. Ongoing monitoring/audits; DOE oversight via Family Policy Compliance Office.
HITRUST CSF Details
What It Is
HITRUST Common Security Framework (CSF) is a certifiable, threat-adaptive control framework that consolidates requirements from 60+ authoritative sources like HIPAA, NIST, ISO 27001, PCI DSS, and GDPR. Its risk-based approach tailors controls via organizational, system, and regulatory factors.
Key Components
- 19 assessment domains (e.g., Access Control, Incident Management, Risk Management)
- Hierarchical structure: 14 categories, 49 objectives, ~156 specifications
- **Five-level maturity modelPolicy, Procedure, Implemented, Measured, Managed
- **Tiered certificationse1 (44 controls), i1 (182 requirements), r2 (tailored, 2-year)
Why Organizations Use It
- Demonstrates unified compliance and third-party assurance
- Reduces audit fatigue via assess once, report many
- Enhances risk management and operational maturity
- Builds stakeholder trust in healthcare and regulated sectors
Implementation Overview
Phased approach: scoping in MyCSF platform, gap analysis, remediation, validated assessment by authorized assessors. Suited for healthcare, finance; requires policies, evidence, certification via HITRUST QA. (178 words)
Key Differences
| Aspect | FERPA | HITRUST CSF |
|---|---|---|
| Scope | Student education records and PII privacy | Comprehensive security and privacy controls |
| Industry | U.S. education institutions only | Healthcare, finance, regulated sectors globally |
| Nature | Mandatory U.S. federal regulation | Voluntary certifiable framework |
| Testing | No formal certification; internal compliance | Validated assessments by external assessors |
| Penalties | Federal funding suspension | Loss of certification, no legal penalties |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about FERPA and HITRUST CSF
FERPA FAQ
HITRUST CSF FAQ
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