Finding 369312 (2023-003)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-15
Audit: 290552
Organization: Cleary University (MI)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University failed to meet key requirements of the Gramm-Leach-Bliley Act (GLBA), risking student information security.
  • Impacted Requirements: Lack of documentation for security programs, risk assessments, multi-factor authentication, continuous monitoring, vendor management, and annual reporting.
  • Recommended Follow-Up: Allocate adequate resources to ensure full compliance with GLBA requirements.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the 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 recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Categories

Subrecipient Monitoring Material Weakness

Other Findings in this Audit

  • 369311 2023-003
    Material Weakness
  • 369313 2023-003
    Material Weakness
  • 369314 2023-003
    Material Weakness
  • 369315 2023-004
    Material Weakness Repeat
  • 369316 2023-004
    Material Weakness Repeat
  • 369317 2023-004
    Material Weakness Repeat
  • 369318 2023-005
    - Repeat
  • 369319 2023-005
    - Repeat
  • 945753 2023-003
    Material Weakness
  • 945754 2023-003
    Material Weakness
  • 945755 2023-003
    Material Weakness
  • 945756 2023-003
    Material Weakness
  • 945757 2023-004
    Material Weakness Repeat
  • 945758 2023-004
    Material Weakness Repeat
  • 945759 2023-004
    Material Weakness Repeat
  • 945760 2023-005
    - Repeat
  • 945761 2023-005
    - Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.85M
84.063 Federal Pell Grant Program $1.26M
84.007 Federal Supplemental Educational Opportunity Grants $68,262
84.033 Federal Work-Study Program $6,056