US government regulations with azure

Question

I am looking for detailed documentation on ( Family Educational Rights and Privacy Act) FERPA

and I am looking for useful information. Still, I could not get a detailed implementation of FERPA with various Azure services such as ADLS, Azure Databricks, etc., and How the framework looks like.

https://learn.microsoft.com/en-us/compliance/regulatory/offering-ferpa

Please help me with this.

Answer 1

I found these links :

https://www.linkedin.com/pulse/ferpa-implementation-guide-microsoft-azure-now-live-simorjay-cissp/

https://www.media3.net/industry/FERPA%20Implementation%20Guide%20for%20Azure.pdf

1. Understanding FERPA Compliance Requirements

• FERPA Overview: FERPA protects the privacy of student education records. Educational institutions and entities that process these records must ensure confidentiality, access controls, and the ability to audit data access.
• Key FERPA Requirements:
  • Access Controls: Only authorized individuals should have access to educational records.
  • Data Encryption: Data must be encrypted both at rest and in transit.
  • Auditability: There should be logs and monitoring to track access to educational records.
  • Data Minimization: Collect and retain only the data necessary for the intended educational purpose.

2. Azure Data Lake Storage (ADLS)

• Access Controls:
  • Use Azure Role-Based Access Control (RBAC) to define who can access data in ADLS. Ensure that only authorized personnel have access to folders containing FERPA-protected data.
  • Azure Active Directory (AAD) integration with ADLS allows you to manage permissions based on user roles.
• Data Encryption:
  • Enable encryption at rest using Azure Storage Service Encryption (SSE). This ensures that all data stored in ADLS is encrypted.
  • Use Azure Key Vault to manage encryption keys, providing an additional layer of security.
• Auditability:
  • Implement Azure Monitor and Azure Storage Analytics to track access to ADLS. Log access requests, successful and failed attempts, and modifications to data.
• Data Minimization:
  • Implement data lifecycle management to automatically delete data that is no longer needed, according to FERPA guidelines.

3. Azure Data Factory

• Secure Data Movement:
  • Use Managed Identity to authenticate Azure Data Factory (ADF) and access ADLS or other data stores securely.
  • Ensure that data in transit between ADF and other services is encrypted using HTTPS/TLS.
• Access Controls:
  • Use AAD-based RBAC to control access to ADF resources. Assign roles such as Data Factory Contributor or Data Factory Operator to manage who can modify or execute pipelines.
• Logging and Monitoring:
  • Enable Azure Monitor for ADF to capture detailed logs of pipeline activities. This includes who initiated the pipeline, data movements, and any errors.
• Data Minimization:
  • Implement ADF’s Data Flow transformations to process only the necessary data, reducing the exposure of FERPA-protected information.

4. Azure Databricks

• Data Security and Privacy:
  • Configure Databricks clusters to use AAD tokens for authentication, ensuring secure access to data.
  • Use Databricks Table ACLs (Access Control Lists) to control access to data within Databricks. This ensures that only authorized users can access and query FERPA-protected data.
• Data Encryption:
  • Encrypt all data stored in Databricks File System (DBFS) using encryption at rest. Also, ensure that data in transit between Databricks and other Azure services is encrypted.
• Auditability:
  • Use Databricks audit logs to track user activities, including data access and queries run on FERPA-protected data. These logs should be securely stored and regularly reviewed.
• Data Minimization:
  • Implement data cleansing and anonymization techniques in your data processing pipelines within Databricks to reduce the amount of FERPA-protected data that is stored and processed.

5. General Best Practices

• Regular Compliance Audits: Schedule regular audits to ensure ongoing FERPA compliance across all Azure services.
  • Data Masking and Pseudonymization: Where possible, use Azure’s data masking features to obscure sensitive student information.
  • Incident Response Plan: Develop and test an incident response plan specifically for handling FERPA-related data breaches.

Example Framework for FERPA Compliance

AzureAD:

  - Enforce MFA for all users

  - Use Conditional Access to restrict access based on location and device

AzureDataLakeStorage:

  - Enable encryption at rest

  - Implement RBAC for fine-grained access control

  - Enable logging and monitoring with Azure Monitor

  - Setup lifecycle management for data retention

AzureDataFactory:

  - Use Managed Identity for secure data movement

  - Encrypt data in transit

  - Implement logging for all data movement activities

AzureDatabricks:

  - Secure clusters with AAD tokens

  - Encrypt DBFS at rest and in transit

  - Use audit logs to track data access

  - Implement data minimization in pipelines

AzureKeyVault:

  - Store and manage encryption keys securely

  - Rotate keys regularly

Monitoring and Auditing:

  - Use Azure Security Center for ongoing monitoring

  - Regularly review access logs and audit trails

This framework should provide you with a comprehensive approach to implementing FERPA compliance across Azure services. Be sure to consult with your organization's compliance team and legal advisors to tailor these recommendations to your specific needs.

Answer 2

this is a user supported forum. as your question has legal ramifications you should ask this question to an actual Microsoft account rep or open a support ticket.