Finding 1325 (2023-001)

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with a couple of components of the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has certain policies in the safeguards and vendor sections of GLBA have not been fully documented. Cause: The Seminary made significant progress to address and document compliance with the updated requirements of GLBA and has a few areas left to complete. Effect: The Seminary may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the Seminary for significant work completed on GLBA. We recommend the Seminary complete documentation of the known policies and procedures related to safeguards and vendors be included in the information security program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.