Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.
Finding 2024-001: Special Tests and Provisions – Gramm-Leach Bliley Act
Repeat of finding 2023-001
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
Assistance Listing Number - 84.033, 84.268, 84.063, 84.379, 84.007
Federal Award Number - Various
Federal Award Year - June 30, 2024
Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their
information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021,
the Federal Trade Commission issued final regulations that altered the current required elements of an
information security program and added several new elements. Under the regulations, institutions are
required to develop, implement, and maintain a comprehensive information security program that is written
in one or more readily accessible parts. The written information security program for institutions must
address all elements that apply. The elements for the information security programs set forth in this
section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and
do not prescribe how they will be addressed.
Condition: The University does not have a written information security program that addresses all elements that apply.
Cause: The University did not have procedures and processes in place specific to GLBA and therefore, did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the University at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should address each of the required minimum elements noted in the GLBA regulations (16 CFR 314.4).
Management's Response: The reported issue arises from the absence of written documentation outlining policies and procedures related to GLBA requirements. This matter is being addressed by the Director of Information Technology in collaboration with a campus-wide committee responsible for overseeing information security. A draft of the documented information security program has been created and will specifically address the cybersecurity requirements of GLBA.