Higher Education’s Push Toward a Virtual CISO Approach

In recent years, higher education institutions have faced an increasingly complex cybersecurity landscape. From ransomware attacks that disrupt learning environments to rising compliance obligations under federal mandates, colleges and universities—especially small and mid-sized ones—are under mounting pressure to strengthen their cybersecurity posture. But as the need for cyber leadership grows, many of these same institutions are simultaneously grappling with reduced budgets, shrinking full-time IT staff, and difficulty justifying the cost of a full-time Chief Information Security Officer (CISO).

Enter the Virtual CISO (vCISO) model—a flexible, scalable, and increasingly popular way for higher education institutions to access cybersecurity leadership without the full-time cost. In this blog, we explore the factors driving the adoption of virtual CISOs across higher ed, what this model looks like in practice, and how it’s helping institutions meet growing expectations from regulators, insurers, and stakeholders.

The Budget Problem: Shrinking Resources, Growing Threats

The financial pressures on higher education are no secret. According to the National Center for Education Statistics (NCES), undergraduate enrollment was 15% lower in fall 2021 than in fall 2010. Much of this decrease occurred during the pandemic, with some increases to enrollment in the recent years (though not returning to 2010 levels). Many experts also fear a looming enrollment cliff due to the decreased birth rates ever since the 2007 recession and those rates only now beginning to impact college enrollment as children born that year turn 18 in 2025. Smaller private institutions and community colleges are often hit hardest. Less tuition revenue often means budget tightening across departments—including IT.

At the same time, cyber threats continue to rise. The education sector has become one of the top targets for ransomware attacks, according to the 2024 IBM X-Force Threat Intelligence Index. Attackers know that institutions often lack the resources or maturity to defend against persistent threats, and many see smaller schools as easy entry points to more lucrative targets or valuable data sets.

This creates a conundrum: cyber risk is growing, but the ability to pay for dedicated cybersecurity leadership is declining.

CISOs Are Hard to Find—And Harder to Keep

Even when funding is available, finding and retaining a qualified CISO can be a tall order. Experienced security professionals are in high demand across all industries. The 2024 (ISC)² Cybersecurity Workforce Study estimated a global shortage of over 4 million cybersecurity professionals, with demand for leadership roles outpacing supply.

In higher education, this challenge is compounded by salary competition. According to HigherEdJobs, institutions often struggle to offer compensation packages that compete with the private sector. As a result, IT and security leaders often wear multiple hats—or leave for more lucrative opportunities.

For smaller institutions that have never had a CISO, the prospect of hiring one full-time may feel daunting or even unnecessary—until regulations say otherwise.

The Regulatory Wake-Up Call: FTC Safeguards and the “Qualified Individual”

One of the most significant drivers pushing institutions toward cybersecurity leadership is the revised Federal Trade Commission (FTC) Safeguards Rule, which went into effect in June 2023. The rule applies to institutions that qualify as “financial institutions” under the Gramm-Leach-Bliley Act (GLBA)—including colleges and universities that participate in federal student aid programs.

The updated rule mandates that covered institutions must designate a “qualified individual” to oversee their information security program. This person must have the expertise to implement and manage the program, ensure risk assessments are conducted, monitor service providers, and report to the board or highest governing body on the program’s status.

For many institutions—particularly those without a formal CISO or established security program—this requirement posed a serious compliance gap.

In fact, the Department of Education’s Office of Federal Student Aid (FSA) clarified in 2023 that institutions found out of compliance with GLBA requirements could face administrative consequences, including the potential loss of Title IV eligibility.

It’s no longer optional to have someone “kind of” in charge of cybersecurity. Institutions must be able to point to a qualified individual overseeing their program—and document that person’s role, qualifications, and activities.

Why the Virtual CISO Model Makes Sense

For colleges and universities navigating this tightrope of risk, regulation, and resourcing, the virtual CISO model offers a strategic middle ground. Here’s why it’s gaining traction:

1. Cost-Effective Access to Expertise

A full-time CISO salary—especially for someone experienced in higher ed and regulatory frameworks—can easily exceed $150,000 to $200,000 annually, not including benefits. A virtual CISO model offers fractional access to the same level of expertise at a fraction of the cost, with pricing scaled based on need.

2. Meets Regulatory Requirements

A qualified virtual CISO can satisfy the FTC’s “qualified individual” requirement and help implement an actionable security program tailored to the institution’s environment. This includes risk assessments, documentation, third-party monitoring, and executive reporting—core pieces of any GLBA-compliant program.

3. Built-in Flexibility

Every institution has different needs. Some already have robust IT teams and just need guidance; others need help standing up an entire information security program. The vCISO model can scale to support either scenario, offering more hours during key initiatives or audits and scaling down during quiet periods.

4. Faster Ramp-Up

Hiring and onboarding a new CISO can take months. A virtual CISO can often begin work in weeks, with immediate access to templates, risk libraries, and proven playbooks. For institutions under regulatory pressure or facing insurance deadlines, speed matters.

5. Cross-Sector Insights

Virtual CISOs often serve multiple clients, giving them exposure to evolving best practices, real-world threats, and the latest tools in cybersecurity. This broader perspective helps them bring fresh ideas and benchmark strategies that might not emerge from internal-only teams.

6. Board and Leadership Communication

One of the most critical roles of a CISO is translating technical risk into business terms that resonate with institutional leadership. Experienced virtual CISOs are adept at creating board-level reports, aligning cybersecurity with institutional strategy, and communicating priorities clearly to stakeholders who may not have a technical background.

Realities on the Ground: A Common Scenario

Consider a small liberal arts college with fewer than 2,000 students. Their IT team consists of a director and two support specialists. They’ve historically relied on a managed service provider (MSP) for infrastructure support and a part-time consultant to handle firewall updates. They’ve never had a formal risk assessment, written cybersecurity policies, or security awareness training.

When they receive a compliance notice from the Department of Education regarding GLBA enforcement—and a request from their cyber insurer for documentation of security controls—they realize they need help, fast.

Hiring a full-time CISO isn’t feasible. But engaging a vCISO for 10–15 hours per month allows them to:

• Perform a gap assessment against GLBA and NIST CSF
• Draft and implement a written information security program (WISP)
• Set up a vendor management process
• Train staff on phishing and social engineering
• Create quarterly reports for their board
• Guide technical teams on MFA, encryption, and logging priorities

Within 6 months, the institution is significantly more prepared, with a defensible security posture—without having hired a single new FTE.

What to Look for in a Higher Ed-Focused vCISO

Not all virtual CISO services are the same. For higher education institutions, it's important to find a provider who understands:

• FERPA, GLBA, and other relevant regulations
• EDUCAUSE frameworks like HECVAT and IT Governance
• Institutional dynamics (e.g., shared governance, decentralization, unionized staff)
• Academic priorities, such as open access and data protection trade-offs

The best vCISO partners don’t just bring technical skills—they understand how to work within the culture and constraints of higher education, align cyber priorities with academic missions, and build trust across stakeholders.

CISO vs. vCISO: It Doesn’t Have to Be Either-Or

One common misconception about the virtual CISO model is that it must replace an in-house Chief Information Security Officer—or that bringing in external cybersecurity leadership signals a failure of internal teams. In reality, that couldn’t be further from the truth.

Virtual CISO services are not designed to displace internal personnel or render full-time roles obsolete. In fact, the most effective vCISO engagements complement existing staff by bringing added bandwidth, external perspective, and specialized knowledge. For institutions with a dedicated CISO or IT director already in place, a vCISO can act as a strategic advisor, a second set of eyes, or a project-based leader to drive specific initiatives forward—whether it’s compliance alignment, third-party risk management, or board reporting.

For schools without a CISO, a vCISO can step in as an interim or part-time leader, gradually helping to build out the policies, procedures, and governance structures that may one day support a full-time hire. The relationship is inherently flexible, and many institutions move fluidly between models depending on their growth, staffing, and regulatory needs.

Ultimately, it’s not about choosing between a CISO and a vCISO—it’s about choosing the right level of support for your institution’s current stage and goals. Whether reinforcing existing efforts or filling a critical leadership gap, a virtual CISO can be a strategic partner without stepping on anyone’s toes.

The Bottom Line

Higher education is at a crossroads when it comes to cybersecurity leadership. Budget constraints, regulatory demands, and staffing shortages are all colliding at a time when cyber threats are more pervasive and damaging than ever. For many institutions—especially those that have never had a formal CISO role—the virtual CISO model offers a practical, effective path forward.

By tapping into the expertise of a seasoned security leader on a part-time basis, institutions can meet compliance mandates, reduce risk exposure, and build more resilient programs—without overextending their budgets or burning out internal staff.

How Compass IT Compliance Can Help

Compass IT Compliance offers tailored Virtual CISO (vCISO) services designed specifically for higher education institutions. Our team includes security leaders with deep experience supporting colleges and universities, including experts who sit on the EDUCAUSE HECVAT advisory board, chair the Chief Privacy Officer’s Community Group, and serve on the Cybersecurity and Privacy Program Advisory Committee. We are considered trusted industry leaders and are regularly invited to speak at URMIA and other higher education security events.

Whether you need help meeting the FTC Safeguards Rule, building a long-term information security program, or simply communicating cyber risk to leadership, our vCISO team is here to help. We provide flexible engagement models, proven frameworks, and a deep understanding of academic environments—helping you build a smarter, more sustainable approach to cybersecurity.

Ready to learn more? Contact us today to explore how a vCISO can strengthen your institution’s cybersecurity posture.