Finding Text
Federal Program - Student Financial Assistance Cluster
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
CFDA 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 College does not have a written information security program that addresses all elements that apply.
Cause: The College’s procedures and processes in place specific to GLBA did not have written documentation of all required elements.
Effect: Failure to comply with the requirements of GLBA standards puts the College at risk of compromising consumer, nonpublic personal information.
Questioned Costs: Not applicable.
Context: Not applicable.
Recommendation: The College should perform and document an annual risk assessment to determine the College’s specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the College should address each of the required minimum elements noted in the GLBA regulations
(16 CFR 314.4).
Management's Response: The College does have a written information security program but does not currently have it in the format recommended by the auditors. The College will update the documentation of all required elements, specific to GLBA, following the auditors' template.