Kentucky Wesleyan College notice of data security incident – should the FTC investigate?

As posted on their web site on March 20, KWC reveals an incident that they became aware of in September 2020.

Kentucky Wesleyan College experienced a Network Security Incident, resulting in the temporary loss of availability to its files and systems. We have since resolved the Incident and implemented additional security measures. Although there was no direct evidence of any misuse of personal information, this Incident may have resulted in unauthorized access to the personal information of certain Kentucky Wesleyan faculty, students, staff records and potentially others. Accordingly, Kentucky Wesleyan will be providing direct formal notice to all individuals whose personal information may have been impacted by the Incident. We value our members of the Kentucky Wesleyan community and thank you for your understanding. For more information, please see our FAQs at the link below.

If you have any questions about this Incident or questions regarding the content of the formal notice, please telephone our dedicated call center at 1-866-752-0071 from 8:00 a.m. to 8:00 p.m. CT, Monday through Friday.

The FAQ does not explain the actual nature of the breach nor how it occurred. Nor does it explain why it took approximately six months to make notifications.  What it does reveal is the types of information involved:

What information may have been impacted?
The type of personal information that may have been accessed includes names, social security numbers, birth dates, addresses, driver’s license numbers, financial aid award information, and in some limited instances, other potential Personal Identifying Information (“PII”).

What types of personal information does “Other Potential PII” encompass?
Such information may encompass any of the following:

  • Taxpayer/ Employer Identification Number;
  • Email address with password or associated security questions;
  • Username with password or associated security questions;
  • Identity Protection Personal Identification Number Issued by the IRS; or
  • Biometric Data (g., fingerprints).

So six months to notify people that their SSN and other identity information and financial aid may have been accessed?

The security of student financial aid data should be covered by the Gramm–Leach–Bliley Act. The Federal Trade Commission has enforcement authority over GLBA. Both and had argued in a previous education sector breach incident that the FTC should take enforcement action over schools that fail to adequately secure student financial aid data. They didn’t investigate in that case.

The FTC generally has no authority over the education sector or not-for-profits, but they do have authority to enforce GLBA. When there’s a breach involving student financial aid and students aren’t even notified for almost six months — and then they are not even offered any mitigation services, maybe the FTC should take a look at the incident?

Updated 11:19 am: discovered that the college reported this incident as impacting 31,796 individuals. And although their web site notification and FAQ do not mention any mitigation services, their actual postal letter to individuals does offer 24 months of complimentary credit monitoring and identity theft restoration services with Cyberscout. The post was edited post-publication to remove a comment that they had not offered any services.

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