How to Protect Student Data During a Cloud Migration

Educational institutions and the third-party entities that help manage their data often possess and obtain sensitive student data as part of their operations. The need to keep that data in legal compliance and to maintain student privacy with its use means extra care and maintenance must be done to prepare the data for a cloud migration. This blog post reviews the sensitive student data for which organizations must identify, classify, and adhere to legal compliance, as well as the steps to take for a successful migration of such data to the cloud.

What Is Classified as Sensitive Student Data?

In the United States, federal law known as the Family Educational Rights and Privacy Act (FERPA) addresses specific requirements for the safeguarding of education records for public schools and school districts. In short, FERPA grants the following rights to parents and legal guardians for their child’s student data, which are then transferred to the students when they turn eighteen years old:

• Access to Education Records – Access must be granted to education records within a reasonable period.
• Amendment of Education Records – An amendment or correction can be sought for education records if believed to be misleading, inaccurate, or a violation of privacy rights. If denied, this request can be taken to a hearing.
• Disclosure of Education Records – Personally Identifiable Information (PII) may not be disclosed to a third party without prior written consent. Exceptions exist to this to permit disclosure but not require it, such as to school officials with a legitimate educational interest or for enrollment purposes.

Personal information such as social security numbers, names, addresses, and so on are the most important examples of sensitive student data to account for in a cloud migration, especially to stay within compliance with FERPA. Even if FERPA does not specifically apply to your organization, the possession of personal information for students often overlaps with other state and federal regulations for data privacy. This can be especially true when using personal data such as contact, location, and even social media information from mobile devices to conduct COVID-19 tracking. The possession and retention of such data can be a point of contention for students and their privacy concerns as well as potential liability for legal action. If steps are taken to stay within compliance, arrange safeguards, and maintain transparency on said data with students, parents, and legal guardians, then a planned cloud migration of student data has a greater chance of success.

Steps to Take During Your Cloud Migration

What needs to be done to prepare student data for a cloud migration? Consider the following steps when implementing your cloud migration strategy:

Understand the Data You Have

Unstructured data can leave your organization in the dark on what student data has been obtained. Such data should be identified and assessed for potential risk to prepare for a cloud migration beforehand.

Understand Your Compliance Requirements

Requirements for access, data retention, and privacy can be regulated by an array of both federal and state regulations, not just FERPA. Since regulations under federal law apply regardless of state, it is best to assess required compliance at the federal level and then determine if laws at the relevant state level enforce higher compliance standards.

Control Who Has Access

Because sensitive student data in a cloud migration must be protected from a potential security breach, the legacy school systems in possession of student data must exercise strict access control for data governance. A zero-trust model for access to student data can put up essential safeguards when preparing and assessing the data for a cloud migration.

Assess the Impact on Your IT Assets

The cloud migration strategy must consider the short-term and long-term impact on the organization’s IT assets. Legacy school systems may require a hybrid-cloud strategy to mitigate the short-term impact on access and upkeep, so that requested access and amendments to educational records are not tripped up by technical complications.

For more information on cloud migration strategies, see Cloud Migration Strategies For a Seamless Transition.

Run a Comprehensive Data Sanitization

Data sanitization prior to a cloud migration can address multiple points of concern at once. First, it will reduce costs for the cloud migration itself to remove stale or outdated student data that is not required to be retained or migrated. Second, it can help address sensitive student data that should not be retained or migrated at all, depending on both privacy policy and legal compliance. Finally, it reduces the post-migration maintenance that may be required in the event such data in the previous points are overlooked, so that will further reduce costs to keep a cloud migration’s performance and upkeep goals on-track.

Encrypt Data for the Migration

Whether shipping physical storage or conducting a digital migration online, sensitive student data must be encrypted as a safeguard for the transfer. Cloud service providers can offer means to apply this encryption, and costs can be reduced for this process by isolating the sensitive student data beforehand.

Reassess Your Security & Vulnerabilities Post-Migration

The steps needed to protect student data prior to the cloud migration must also apply after the migration has been carried out. Security awareness for your organization, maintenance and upkeep by cybersecurity staff, and regulatory compliance must factor in the implemented cloud migration strategy, as well as the capabilities of the utilized cloud services. Ensure that access to the student data in the cloud is properly secured and authenticated, apply a zero-trust model for access, and set up training for best practices to discourage improper handling of student data.

For further discussion on data security, see Data Security in 2022: The Top Challenges and How to Solve Them.

Protect Your Student Data

Classify360 can be a powerful asset to protect your student data. Its manage-in-place design, light server footprint, and secure, cloud-based data governance can help your organization identify, classify, and take action on your data to enforce privacy policies and maintain legal compliance. Risk analysis models and automation tools can help pinpoint sensitive information in your data sources and maintain your data governance on an ongoing basis.