Finding 2180 (2023-001)

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The Seminary has not implemented multi-factor authentication on all systems containing personally identifiable information (PII) or had the qualified individual approve in writing the exception. Additionally, the written, annual report to the board does not include all the required areas based on the updated regulations. Cause: The Seminary has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The Seminary has a couple of gaps to adequately address the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We commend the Seminary for the work completed on GLBA. We recommend the Seminary allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.