The Department of Education’s Office of Federal Student Aid (FSA) partners with various entities that are involved primarily in supporting the repayment and collection of student loans. FSA shares a variety of personally identifiable information (PII) on borrowers with its non-school partners. This includes names, addresses, phone numbers, email addresses, Social Security numbers, and financial information.
Key practices for overseeing the protection of PII shared with non-federal entities include requiring (1) risk-based security and privacy controls, (2) independent assessments to ensure controls are effectively implemented, (3) corrective actions to address identified weaknesses in controls, and (4) ongoing monitoring of control status. FSA established oversight policies and procedures for loan servicers and private collection agencies that generally address these key practices.
However, the Government Accountability Office found, FSA exercises minimal oversight of lenders’ protection of student data.
FSA officials maintain that the lenders are subject to other legal and regulatory requirements for protecting customer data. However, GAO reports, FSA does not have a process for ensuring lenders are complying with these requirements, and thus lacks assurance that appropriate risk-based safeguards are being effectively implemented, tested, and monitored.
GAO was asked to review how FSA ensures the protection of PII by its non-school partners. The agency collected and reviewed FSA documentation, reports, policies, and procedures and compared FSA policies and procedures to four key practices included in federal guidance for overseeing the protection of PII by non-federal entities. GAO also interviewed FSA officials with responsibility for the oversight of non-school partners.
GAO is making six recommendations to FSA to ensure that its oversight of non-school partners addresses the four key practices for ensuring the protection of PII. FSA concurred with three of the recommendations, partially concurred with two, and did not concur with one. It also described actions planned or under way to implement four of the recommendations.