Standards Comparison

    FERPA

    Mandatory
    1974

    U.S. federal regulation protecting student education records privacy

    VS

    MAS TRM

    Mandatory
    2021

    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.

    Student Privacy

    FERPA

    Family Educational Rights and Privacy Act (FERPA)

    Cost
    €€€
    Complexity
    High
    Implementation Time
    6-12 months

    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
    Technology Risk Management

    MAS TRM

    MAS Technology Risk Management Guidelines

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    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

    Scope

    FERPA
    Student education records privacy and access rights
    MAS TRM
    Technology risk governance, cybersecurity, resilience

    Industry

    FERPA
    U.S. education institutions receiving federal funds
    MAS TRM
    Singapore financial institutions across sectors

    Nature

    FERPA
    U.S. federal law with funding-based enforcement
    MAS TRM
    Supervisory guidelines with proportional implementation

    Testing

    FERPA
    Disclosure logging, access request fulfillment
    MAS TRM
    Annual pen testing, vulnerability assessments, DR tests

    Penalties

    FERPA
    Federal funding withholding, enforcement actions
    MAS TRM
    Fines, license conditions, supervisory remediation

    Frequently Asked Questions

    Common questions about FERPA and MAS TRM

    FERPA FAQ

    MAS TRM FAQ

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