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Financial-aid data is GLBA "customer information," and any AI tool that touches it is in scope for the Safeguards Rule — with two different clocks: 30 days to the FTC under the Safeguards Rule, and same-day reporting to Federal Student Aid on detection or even suspicion. This kit gives you the written program with an AI overlay, the vendor controls, the breach runbook, and the institutional policy. Built by a former government attorney who ran security and privacy programs at scale. Free AI policies exist. Free GLBA material exists. Nothing combines Safeguards, AI governance, vendor review, and IRB research data into one operating structure.
Who it's for: CISO/CIO, General Counsel/compliance, and the financial-aid and research offices at universities and community colleges.
What's Included:
GLBA Safeguards Program + Breach Runbook (FSA/FTC timelines)
Institutional AI & Data Governance Policy
Risk Tiering + Required Controls
AI/EdTech Vendor Vetting (service-provider safeguards)
FERPA & CA Public-Records Handling; Incident & Breach Response
IRB / Research-Data AI Governance (universities)
Educational templates, not legal advice. Confirm current FTC/FSA requirements with your counsel and security office.
Need help putting this into operation? JHarris Advisory runs fixed-scope, fixed-fee engagements on program design, rollout sequencing, and staff training. Consulting services, not legal services. Start a scoping conversation at jharrisadvisory.com/contact
Financial-aid data is GLBA "customer information," and any AI tool that touches it is in scope for the Safeguards Rule — with two different clocks: 30 days to the FTC under the Safeguards Rule, and same-day reporting to Federal Student Aid on detection or even suspicion. This kit gives you the written program with an AI overlay, the vendor controls, the breach runbook, and the institutional policy. Built by a former government attorney who ran security and privacy programs at scale. Free AI policies exist. Free GLBA material exists. Nothing combines Safeguards, AI governance, vendor review, and IRB research data into one operating structure.
Who it's for: CISO/CIO, General Counsel/compliance, and the financial-aid and research offices at universities and community colleges.
What's Included:
GLBA Safeguards Program + Breach Runbook (FSA/FTC timelines)
Institutional AI & Data Governance Policy
Risk Tiering + Required Controls
AI/EdTech Vendor Vetting (service-provider safeguards)
FERPA & CA Public-Records Handling; Incident & Breach Response
IRB / Research-Data AI Governance (universities)
Educational templates, not legal advice. Confirm current FTC/FSA requirements with your counsel and security office.
Need help putting this into operation? JHarris Advisory runs fixed-scope, fixed-fee engagements on program design, rollout sequencing, and staff training. Consulting services, not legal services. Start a scoping conversation at jharrisadvisory.com/contact