FERPA
U.S. federal regulation protecting student education records privacy
MAS TRM
Singapore guidelines for financial technology risk management
Quick Verdict
FERPA protects U.S. student records with access and consent rights for schools, while MAS TRM mandates technology risk governance for Singapore FIs. Schools adopt FERPA to retain funding; banks use TRM to avoid fines and ensure resilience.
FERPA
Family Educational Rights and Privacy Act (FERPA)
Key Features
- Grants rights to inspect, amend, and consent to education record disclosures
- Expansive PII definition including indirect identifiers and linkability risks
- Enumerated exceptions for school officials and health/safety emergencies
- 45-day maximum timeline for record access fulfillment
- Mandatory annual notifications and detailed disclosure recordkeeping
MAS TRM
MAS Technology Risk Management Guidelines
Key Features
- Board and senior management accountability
- Proportional risk-based implementation
- Third-party risk management oversight
- Defence-in-depth cyber controls
- Annual pen testing for internet systems
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 establishing privacy protections for student education records. It grants parents and eligible students rights to access, amend, and control disclosures of personally identifiable information (PII). The risk-based approach balances privacy with educational operations via consent rules and enumerated exceptions.
Key Components
- Core rights: inspect/review (45 days), amend inaccurate records, consent to PII disclosures.
- Definitions: broad education records, expansive PII (direct/indirect identifiers), directory information.
- Exceptions (15+): school officials/legitimate interests, emergencies, audits.
- Compliance: annual notices, disclosure logs, vendor controls. No formal certification; enforced via funding withholding.
Why Organizations Use It
Mandated for federally funded education institutions to avoid penalties, protect funding eligibility. Enhances trust, mitigates breach risks, enables safe data sharing. Builds reputation, supports innovation in edtech/analytics.
Implementation Overview
Phased program: governance, data inventory, policies/training, technical controls (RBAC, logging), vendor DPAs. Applies to K-12/postsecondary recipients of federal funds. Involves ongoing audits, no external certification.
MAS TRM Details
What It Is
MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidelines from Singapore's Monetary Authority for financial institutions (FIs). They outline principles-based practices for governing and controlling technology and cyber risks, ensuring confidentiality, integrity, and availability (CIA) of systems and data. The risk-based, proportional approach tailors implementation to FI size, complexity, and exposure.
Key Components
- 15 sections spanning governance, risk frameworks, secure SDLC, IT operations, resilience, access controls, cryptography, data/infrastructure security, cyber operations, assessments, online services, and audit.
- Synthesised 12 core principles: board accountability, asset inventories, third-party oversight, defence-in-depth.
- No fixed controls; focuses on outcomes via continuous monitoring/improvement.
- Supervisory review model, no certification.
Why Organizations Use It
- Essential for MAS-regulated FIs to meet supervisory expectations and avoid fines/enforcement.
- Builds cyber resilience, operational stability, and customer trust.
- Enables secure digital transformation.
- Enhances reputation and competitive positioning.
Implementation Overview
- Phased: governance setup, asset/risk assessment, controls/testing, third-party management, monitoring.
- Targets Singapore FIs (banks, insurers, fintechs); scales by risk profile.
- Involves board oversight, policies, training; audit readiness key.
Key Differences
| Aspect | FERPA | MAS TRM |
|---|---|---|
| Scope | Student education records privacy and access rights | Technology risk governance, cybersecurity, resilience |
| Industry | U.S. education institutions receiving federal funds | Singapore financial institutions across sectors |
| Nature | U.S. federal law with funding-based enforcement | Supervisory guidelines with proportional implementation |
| Testing | Disclosure logging, access request fulfillment | Annual pen testing, vulnerability assessments, DR tests |
| Penalties | Federal funding withholding, enforcement actions | Fines, license conditions, supervisory remediation |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about FERPA and MAS TRM
FERPA FAQ
MAS TRM FAQ
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