Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi-factor authentication for anyone accessing customer information on the institution's system, conducting a periodic inventory of data that notes where it is collected, ...
Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi-factor authentication for anyone accessing customer information on the institution's system, conducting a periodic inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the institution's system and when it's in transit, and the assessment of apps developed by the institution. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Auditor Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. Corrective Action. Currently, the College is reviewing the compliance requirements for Gramm Leach Bliley and will amend the current policy to ensure that each safeguard is being addressed within the policy. Responsible Person. Alex Freds, Director of IT Anticipated Completion Date. June 30, 2024