Higher education institutions are a growing target for cybercriminals due to the high volume of sensitive information and data they collect and use. From enrollment to matriculation, colleges and universities utilize student data for everything from financial aid packages to determining eligibility for coursework. According to a report by Check Point Research, the education sector (specifically higher education) has experienced significantly more cyber attacks than any other industry in recent years.
Institutions must enhance their information security and third-party risk management programs as data breaches grow throughout the higher ed sector.
Alongside general student data, many higher education institutions also collect and use sensitive student health data, which third-party vendors may utilize for daily business operations. This blog explores the sensitive student health data used by higher education institutions, the types of third-party vendors interacting with it, and TPRM strategies to secure and protect sensitive data.
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Types of Student Health Data in Higher Education
In higher education, students' health data is paramount to promoting their well-being and academic success. However, collecting and managing such data requires careful attention to privacy laws and ethical considerations, particularly in the United States, where regulations such as the Health Insurance Portability and Accountability Act (HIPAA) and the Family Educational Rights and Privacy Act (FERPA) are in place.
Types of sensitive student health data higher education institutions use include:
- Medical records: Information about student visits to campus health centers, including diagnoses, treatments, and prescriptions
- Emergency medical information: Critical data such as contact information, blood type, known allergies, and other pertinent health details can be vital in emergencies
- Immunization records: Data regarding student vaccinations, which is particularly important for preventing outbreaks of diseases on campus
- Mental health information: Details from counseling and psychological services, including usage rates, types of issues addressed (like anxiety, depression, stress), and outcomes of interventions
- Accommodation and accessibility information: Details about students with disabilities or those requiring special medical accommodations which help institutions ensure equal access to facilities and learning opportunities
- Insurance information: Details about student health insurance coverage, which is used for billing and ensuring students receive necessary care without undue financial burden
In 2015, the University of California at Los Angeles Health System experienced a significant data breach exposing the personal and health data of 4.5 million individuals. The breach was the result of cybercriminals hacking into parts of the computer network that were not properly secured. In response, UCLA worked with FBI investigators and hired private computer forensic experts to further secure information on network servers. However, the exposed data remained, leaving affected individuals at risk of further security incidents and identity theft.
Third-Party Service Providers in Higher Education
Higher education institutions often collaborate with third-party service providers to manage and enhance student health services, which may involve digitally or physically sharing student health data. The process of outsourcing business operations to third-party vendors is increasing, necessitating the need for robust TPRM processes to protect personal data and prevent data breaches.
Some examples of third-party service providers that may interact with sensitive student health data include:
- Electronic Health Records (EHR) systems: Providers like Epic, Cerner, or Mediware offer platforms for efficiently managing electronic health records, ensuring that health information is accessible to authorized users while maintaining privacy and security
- Telehealth service providers: Companies such as Teladoc, Amwell, or MDLive facilitate virtual health consultations, expanding access to medical and mental health care for students, especially those in remote areas or with mobility constraints
- Health insurance and benefits management: Firms like UnitedHealth, Aetna, and Blue Cross Blue Shield manage student health insurance plans and process claims requiring access to personal health information
- Mental health platforms and apps: Providers such as Talkspace or BetterHelp, which offer online counseling services, may handle sensitive mental health data to provide personalized support
- Survey and research organizations: Entities like the American College Health Association or independent research firms that conduct health surveys and studies involving student data to track health trends and needs
- Disability and accessibility services providers: Companies offering software and management tools for accessibility accommodations, such as Accessible Information Management (AIM), which handles sensitive data regarding students' health and accommodation needs
- Emergency response services: Providers of emergency medical services and crisis management systems that need access to critical student health information to ensure timely and effective responses in emergencies
TPRM Strategies to Protect Student Health Data in Higher Education
Higher education institutions should implement a robust TPRM program to secure the high volume of sensitive student data they collect and use. Below are some of the best strategies to enhance your institution's TPRM program to protect and secure sensitive student data.
Comprehensive due diligence
Higher education institutions must conduct comprehensive due diligence when they plan to engage third-party vendors to manage student health data. This process requires thoroughly vetting potential vendors to understand their data protection practices, security infrastructure, and past performance in handling sensitive information. Institutions should review the vendor's compliance with relevant laws such as HIPAA and FERPA and their history of data breaches or security incidents.
This due diligence also involves examining the subcontractors a vendor might use to ensure that all parties involved in handling student data meet the institution's strict security standards. Ultimately, this meticulous vetting process helps select vendors who align with the institution's needs and demonstrate a robust commitment to data privacy and security.
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Regular audits and compliance checks
Regular audits and compliance checks are important for maintaining the security and integrity of student health data. These audits should be conducted internally and by external auditors to ensure that third-party vendors always adhere to their contractual obligations and legal requirements. In-depth checks and ongoing monitoring help identify potential vulnerabilities or non-compliance issues that could compromise data security.
Regular compliance reviews also help vendors stay aligned with evolving data protection laws and the institution's data governance policies throughout their entire lifecycle. In particular, higher education institutions should check compliance with HIPAA, FERPA, and any state-specific data privacy laws that may apply to them. Higher education institutions are often exempt from US state privacy laws, but organizations should check compliance requirements for their specific state. By implementing ongoing auditing practices, institutions can proactively manage risks and hold vendors accountable.
How UpGuard helps
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Risk assessment and management processes
Effective risk assessment and management processes are crucial in safeguarding sensitive student health data. Higher education institutions should establish a formalized risk management framework to achieve this goal. This framework should help them identify, analyze, and mitigate potential security threats from third-party engagements. The process also involves risk ratings and regular risk assessments considering the likelihood and impact of potential risks and various security scenarios.
Based on these assessments, institutions should develop risk mitigation strategies, including enhanced security protocols, training programs for data handlers, and contingency planning. By continuously monitoring and updating these strategies, institutions can adapt to new threats and vulnerabilities, maintaining a strong defense against potential data breaches.
How UpGuard helps
UpGuard Vendor Risk is a comprehensive third-party risk management solution built to help your organization streamline vendor risk management.
Vendor Risk features a wide range of risk assessment processes and monitoring tools that enable users to quickly evaluate the security posture of their vendors and identify any potential vulnerabilities that present a risk. These features include:
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Incident response and breach notification protocols
Having a clear plan to manage data breaches involving sensitive student health information is critical. It is important to establish robust incident response and breach notification protocols, which should outline the steps to be taken immediately after the breach and assess its impact. The plan must also specify the process for notifying affected individuals and regulatory bodies, which should adhere to legal requirements.
It is essential to provide training to staff on how to respond to data breaches effectively, and it is recommended to conduct regular drills to test the response protocols. These measures ensure that the institution can act swiftly and efficiently in the event of a data breach, minimizing the damage caused and preserving trust with students and stakeholders.
How UpGuard helps
UpGuard Vendor Risk helps prevent security incidents from happening by using automated remediation workflows and industry-leading vulnerability detection tools.
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UpGuard Vendor Risk also lists vulnerabilities identified through information exposed in your vendor’s HTTP headers, website content, and open ports. Our free Risks and Vulnerabilities blog category focuses on specific risk findings and vulnerabilities, including how to resolve and mitigate common issues facing your organization.
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UpGuard features include:
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- Regulatory compliance tracking: Our compliance reporting feature enables customers to view their own or their vendor’s risk details (including web risks) mapped against recognized security standards or compliance frameworks like NIST CSF or ISO 27001.
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