Finding 1180687 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-17

AI Summary

  • Core Issue: Data at rest encryption is not implemented for SAP and PeopleSoft Student Information Systems, despite a previous finding.
  • Impacted Requirements: This violates compliance requirement 16 CFR 314.4(c)(3), which mandates encryption for all student data held at rest.
  • Recommended Follow-Up: Ensure encryption implementation is prioritized before the deferred deadline of Q3 2026.

Finding Text

Special Tests and Provisions – Gramm-Leach-Bliley Act (GLBA) – Student Information Security: Implement Data at Rest Encryption for SAP and PS SIS (Repeat Finding) Drive-level encryption is implemented and observed for a sample workstation that processes customer information. However, encryption mechanisms are not currently implemented for SAP and PeopleSoft (PS) Student Information Systems (SIS) servers. Compliance requirement 16 CFR 314.4(c)(3) requires institutions to protect by encryption of all students’ data held at rest. As of review date, implementation has been deferred to the 3rd Quarter of 2026.

Corrective Action Plan

The District is in the process of upgrading PS SIS PeopleTools after which we will determine the most expedient path to implementing database encryption. The target completion for the PS SIS database encryption is Q3 of 2026. • The District is in the process of implementing encryption of the SAP database as part of the HANA upgrade project. The target completion for the SAP database encryption is Q3 of 2026. Personnel responsible for implementation: Carmen V. Lidz Position of responsible personnel: Vice Chancellor & Chief Information Office Expected Date of Implementation: Q3 of 2026

Categories

Special Tests & Provisions

Other Findings in this Audit

  • 1180676 2025-001
    Material Weakness Repeat
  • 1180677 2025-001
    Material Weakness Repeat
  • 1180678 2025-001
    Material Weakness Repeat
  • 1180679 2025-001
    Material Weakness Repeat
  • 1180680 2025-002
    Material Weakness Repeat
  • 1180681 2025-002
    Material Weakness Repeat
  • 1180682 2025-002
    Material Weakness Repeat
  • 1180683 2025-002
    Material Weakness Repeat
  • 1180684 2025-003
    Material Weakness Repeat
  • 1180685 2025-003
    Material Weakness Repeat
  • 1180686 2025-003
    Material Weakness Repeat
  • 1180688 2025-004
    Material Weakness Repeat
  • 1180689 2025-004
    Material Weakness Repeat
  • 1180690 2025-004
    Material Weakness Repeat
  • 1180691 2025-004
    Material Weakness Repeat
  • 1180692 2025-005
    Material Weakness Repeat
  • 1180693 2025-005
    Material Weakness Repeat
  • 1180694 2025-005
    Material Weakness Repeat
  • 1180695 2025-005
    Material Weakness Repeat
  • 1180696 2025-006
    Material Weakness Repeat
  • 1180697 2025-006
    Material Weakness Repeat
  • 1180698 2025-006
    Material Weakness Repeat
  • 1180699 2025-006
    Material Weakness Repeat
  • 1180700 2025-007
    Material Weakness Repeat
  • 1180701 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $214.97M
84.268 FEDERAL DIRECT STUDENT LOANS $22.37M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $5.78M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $5.45M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $4.59M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $4.47M
84.033 FEDERAL WORK-STUDY PROGRAM $3.77M
84.042 TRIO STUDENT SUPPORT SERVICES $2.81M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $2.17M
84.047 TRIO UPWARD BOUND $2.14M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $1.90M
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $1.46M
17.289 COMMUNITY PROJECT FUNDING/CONGRESSIONALLY DIRECTED SPENDING $1.04M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $1.02M
93.493 CONGRESSIONAL DIRECTIVES $774,771
84.044 TRIO TALENT SEARCH $641,362
10.558 CHILD AND ADULT CARE FOOD PROGRAM $632,943
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $408,936
17.261 WORKFORCE DATA QUALITY INITIATIVE (WDQI) $391,354
93.658 FOSTER CARE TITLE IV-E $354,101
94.006 AMERICORPS STATE AND NATIONAL 94.006 $317,119
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $311,111
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $269,624
10.223 HISPANIC SERVING INSTITUTIONS EDUCATION GRANTS $250,561
93.600 HEAD START $230,335
84.066 TRIO EDUCATIONAL OPPORTUNITY CENTERS $218,215
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $208,827
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $158,626
84.305 EDUCATION RESEARCH, DEVELOPMENT AND DISSEMINATION $139,739
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $81,975
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $81,916
45.031 AMERICAN LATINO MUSEUM INTERNSHIP AND FELLOWSHIP INITIATIVE $51,769
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $37,820
47.050 GEOSCIENCES $18,201