Finding 1100876 (2024-003)

Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster ALN Numbers: 84.268 – Federal Direct Loan Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP). Questioned Costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: Student personal information could be vulnerable. Repeat Finding: Yes – See 2023-002 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: There is no disagreement with the audit finding.