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Cybersecurity risk: Hidden vulnerabilities in student data collection

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Yaron Galant
Yaron Galant
Yaron Galant is chief product officer at Kiteworks, where he leads product strategy and innovation in data security and compliance.

Universities invest heavily in network security, identity management systems, and cybersecurity training. Yet many institutions collect their most sensitive student information—Social Security numbers, mental health disclosures, financial aid applications, disability accommodation requests—through generic web forms that cannot prove compliance, enforce proper access controls or maintain adequate audit trails.

This disconnect creates a critical vulnerability at the exact point where protected information enters institutional systems. IT departments secure the network perimeter but admissions offices, registrars, student health services and research departments often use form solutions selected for convenience rather than security capabilities.

Cybersecurity consequences are significant

FERPA violations trigger federal investigations and potential loss of funding. The Department of Education has increased enforcement actions against institutions that cannot demonstrate adequate protection of student education records.

State data breach laws add notification requirements, regulatory fines and legal exposure from class-action lawsuits.

Title IX and ADA compliance create additional risks. Forms collecting mental health information, disability accommodations or sexual misconduct reports require heightened protection.

Exposure can lead to privacy violations, potential discrimination claims, and regulatory consequences under multiple federal frameworks.

Research operations face their own complications. IRB-approved studies require specific data protections.

When institutions collect research participant information through platforms that lack proper security controls, they compromise research integrity and create compliance exposure with federal research regulations.

International dimensions multiply the complexity. Study abroad programs and international student enrollment subject institutions to GDPR requirements for EU citizens and various other jurisdictional frameworks.

Generic form platforms typically cannot guarantee where data resides geographically, making compliance with data sovereignty requirements nearly impossible to demonstrate.

Why admissions and registration forms present maximum risk

Student intake processes have become the highest-risk FERPA vulnerability. These forms collect the complete range of protected student information in a single interaction—academic records, test scores, Social Security numbers, family financial data and demographic information.

Intake forms often remain accessible longer than other university systems, increasing exposure time. They frequently grant access to multiple user groups—admissions counselors, financial aid officers, academic advisors, athletics recruiters—creating complex access management challenges.

Generic form platforms typically lack the granular role-based controls necessary to limit viewing to individuals with legitimate educational interest, a core FERPA requirement.

Most critically, universities often cannot demonstrate who accessed what student information and when. Department of Education audits require detailed access logs showing legitimate educational interest for every view of student records. Most form solutions provide insufficient audit trails to satisfy this requirement.

Generic platform compliance gap

FERPA mandates that institutions maintain “reasonable” security measures protecting student education records. The Department of Education has made clear through enforcement actions that this standard requires specific capabilities: documented access controls, comprehensive audit logging, encryption of data in transit and at rest and policies governing data retention and destruction.

Generic form platforms were designed for general business use, not regulated education environments. They lack critical capabilities, including:

  • Granular access controls that enforce legitimate educational interest standards
  • Comprehensive audit trails tracking who viewed what data after collection
  • Verified application and data-level security protections with independent validation
  • Guaranteed data residency to comply with international privacy laws
  • Automated retention controls with verified deletion

Protecting against targeted attacks

Cybercriminals specifically target universities for student identity information. Recent attack patterns show threat actors focusing on data collection endpoints rather than core network infrastructure. They recognize that universities often secure central systems while leaving intake forms inadequately protected.

Recent findings from the Kiteworks Sensitive Content Communications Risk Report show that a growing share of higher education security incidents originate at data collection endpoints such as intake forms, where institutions often lack the visibility and audit logging needed to demonstrate regulatory compliance.

Traditional perimeter-based approaches fail when attackers steal credentials through phishing or social engineering. Effective protection implements continuous verification regardless of authentication history. Every form submission requires validation.

Staff receive minimum necessary access rather than broad permissions. System architecture segments different data types, containing potential breaches rather than allowing network-wide compromise.

International student data requirements

International enrollment has made data sovereignty critical for university compliance programs. Institutions enrolling EU students must address GDPR requirements that restrict personal data transfers outside the European Economic Area unless specific safeguards are in place.

Most form platforms cannot guarantee where data resides, potentially violating regulations and risking substantial fines, operational restrictions that could prevent recruiting in affected countries, and reputational damage.

Study abroad programs and research collaborations with international partners create additional obligations requiring platforms with regional deployment options and documentation proving compliance.

What institutions should do now

Universities should begin with a comprehensive inventory of current form usage. Where are forms collecting student data? What platforms host these forms? Who has access to submitted data?

This inventory typically reveals shadow IT deployments where departments selected their own solutions and forms collecting sensitive information through inadequately secured platforms.

Treat form selection as a governance decision requiring input from compliance officers, legal counsel and data protection officers. Evaluation criteria should include demonstrable security capabilities, audit trail quality, access control granularity and data residency guarantees.

Establish clear policies defining what information can be collected through which platforms. Highly sensitive data requires forms with stronger controls than general inquiry forms.

Not all forms need identical protection, but they all need a robust security baseline. Institutions should consciously determine appropriate security levels.

The question isn’t whether digital intake security matters. The question is whether institutions will address this vulnerability before it becomes their next federal investigation, class-action lawsuit, or headline breach.

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