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In my work with higher education institutions and state/local agencies, one debate comes up more often than any other when it comes to building a security program that actually works:
It’s rarely a black-and-white decision. But I’ve found that how an organization answers this question says a lot about how they manage risk, how they think about compliance, and whether they’re planning for today’s threats or yesterday’s structure.
I’ve sat across the table from IT leaders who inherited decades of decentralized decision-making. One university we worked with had six separate identity providers across their campus’—none of which had consistent multi-factor authentication (MFA). Each group had autonomy, which seemed great until they needed to enforce a unified access policy. It's also common for there to be issues when there is a need to respond to an incident or prepare for an audit.
It’s a pattern I see often. Universities and state & local agencies weren’t built like Fortune 500 companies—they’re federated by design, operating more like coalitions than corporations. That gives them flexibility but also makes enterprise-wide visibility and control a major challenge.
When an environment is fragmented, governance often becomes reactive. Teams don’t know what assets exist outside their walls, have inconsistent logging across systems, and asset ownership is unknown. These inconsistencies can have a significant impact during a breach or cyber incident.
In environments that choose to centralize their security operations, we usually see a few benefits show up quickly:
But I don’t want to pretend centralization solves everything. You can’t force control top-down and expect buy-in. If the culture isn’t ready or if it’s purely an IT-driven initiative, centralization can just shift friction elsewhere.
I’ve also seen decentralized models succeed when there’s strong communication and shared accountability. Some research departments move faster and innovate more because they aren’t constrained by centralized procurement or tooling. Local government agencies, too, often need flexibility to serve their unique communities.
But when things go wrong, that flexibility becomes fragmentation:
Most importantly, these environments tend to underestimate third-party risk. When we run assessments, we often find vendors with privileged access who were onboarded without consistent background checks, contract language, or monitoring in place.
A lot of organizations start this conversation because they’re seeking alignment and compliance. GLBA. CJIS. NIST 800-171. HIPAA. But the compliance mandate is often just the symptom of a deeper problem: lack of internal control.
For example, the new GLBA Safeguards Rule update requires continuous monitoring, documented incident response plans, and an appointed security lead. That’s not something you can fake with a policy PDF or a once-a-year tabletop. It takes structure.
And that’s where your operating model—centralized, decentralized, or hybrid—starts to either support or sabotage your compliance efforts.
At NuHarbor, we’re seeing more institutions move toward governed hybrid models—and I think this is where the future is heading.
That means:
One state university we work with adopted a federated GRC model: the security team provides a policy and control framework, and individual colleges map their systems to it with advisory support. It’s not perfect, but it’s far more sustainable than either extreme.
If you’re unsure what model fits your organization, here’s where I suggest starting—not with a technical decision, but a leadership one:
There’s no ideal model. But there is a right model for your maturity, risk tolerance, and culture.
What I’ve learned is this: Structure isn’t something you set and forget—it’s something you evolve as your organization grows. And it’s okay to be pragmatic. If you’re decentralized today, centralize where it counts. If you’re centralized but losing agility, push decision-making closer to the edge—just don’t lose visibility.
If you want to have this conversation in more detail, we’re always happy to dig in with you and your team. Let’s talk.
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Jorge Llano is an Executive Cybersecurity Strategic Advisor at NuHarbor Security. In his role, Jorge helps clients that want to enhance their cybersecurity program by offering objective cybersecurity knowledge, approaches, and tools. Jorge has worked as a cybersecurity executive for two decades, holding positions in both the public and private sectors. His primary responsibilities are creating and executing the organization's security strategy and presenting it to the board of directors, employees, and other executive management colleagues. Jorge holds a doctorate in information assurance from the University of Fairfax and a master's degree in cybersecurity from Penn State University.
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