FERPA
U.S. federal regulation protecting student education records privacy
ISO 27018
International standard for PII protection in public clouds
Quick Verdict
FERPA mandates US student record privacy for schools, enforced via funding loss. ISO 27018 voluntarily guides cloud providers on PII protection through auditable controls. Schools comply with FERPA to access funds; CSPs adopt 27018 for procurement trust and GDPR alignment.
FERPA
Family Educational Rights and Privacy Act (FERPA)
Key Features
- Requires prior written consent for PII disclosures
- Mandates 45-day access to education records
- Expansive PII definition with linkable identifiers
- Enumerates exceptions for school officials, emergencies
- Annual notifications detailing rights and procedures
ISO 27018
ISO/IEC 27018:2025 Code of practice for PII in public clouds
Key Features
- Privacy controls for public cloud PII processors
- Subprocessor transparency and location disclosure
- Prohibits PII use for marketing without consent
- Breach notification to customers without delay
- Supports data subject rights like erasure
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), codified at 20 U.S.C. §1232g and 34 CFR Part 99, is a U.S. federal regulation. It protects privacy of education records containing PII for students at federally funded institutions. Core approach balances individual rights with operational exceptions via consent rules and enumerated disclosures.
Key Components
- Rights to inspect/review (45 days), amend inaccurate records, consent to disclosures.
- Definitions: education records, expansive PII (direct/indirect/linkable identifiers), directory information.
- Exceptions (school officials/LEI, emergencies, audits); recordkeeping/logs (§99.32).
- Compliance via annual notices, vendor controls; enforced by fund withholding.
Why Organizations Use It
Mandated for federal funding recipients; mitigates legal risks, builds stakeholder trust. Enables safe data sharing, vendor management; supports analytics with de-identification.
Implementation Overview
Phased: governance, data inventory, policies/training, RBAC/tech controls, vendor DPAs, audits. Applies to K-12/postsecondary; no certification but DOE complaints/enforcement.
ISO 27018 Details
What It Is
ISO/IEC 27018:2025 is a code of practice extending ISO/IEC 27001 and ISO/IEC 27002 specifically for protecting personally identifiable information (PII) in public clouds where providers act as PII processors. It focuses on cloud-specific privacy risks like multi-tenancy and cross-border flows, employing a risk-based approach within an ISMS.
Key Components
- ~25–30 additional privacy controls covering consent, purpose limitation, data minimization, transparency, accountability.
- Aligned with ISO 27001:2022 Annex A (93 controls in Organizational, People, Physical, Technological themes).
- Built on ISO/IEC 29100 principles.
- Integrated into ISO 27001 audits; no standalone certification.
Why Organizations Use It
- Enhances trust, accelerates procurement via Statement of Applicability.
- Supports GDPR Article 28, HIPAA processor duties.
- Mitigates privacy risks, aids cyber insurance.
- Differentiates CSPs, builds reputation.
Implementation Overview
- Gap analysis, integrate into ISMS, update policies/contracts.
- Applies to all CSP sizes processing PII.
- Third-party audits during ISO 27001 certification/surveillance.
Key Differences
| Aspect | FERPA | ISO 27018 |
|---|---|---|
| Scope | Student education records privacy | PII protection in public clouds |
| Industry | US education institutions only | Cloud service providers globally |
| Nature | Mandatory US federal regulation | Voluntary ISO certification guidance |
| Testing | No formal certification; complaints investigated | ISO 27001 audits with annual surveillance |
| Penalties | Federal funding withholding | Loss of certification, no legal penalties |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about FERPA and ISO 27018
FERPA FAQ
ISO 27018 FAQ
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