Finding Text
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025