Finding 371067 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-28
Audit: 292738
Organization: Furman University (SC)

AI Summary

  • Core Issue: The University’s written information security program (WISP) lacks key components required by the Gramm-Leach-Bliley Act (GLBA) for protecting student financial aid information.
  • Impacted Requirements: Specific GLBA elements missing include user access controls, encryption, multi-factor authentication, and policies for penetration testing and vulnerability scans.
  • Recommended Follow-Up: The University should review and update the WISP to ensure it fully complies with GLBA requirements, which has been initiated post-June 30, 2023.

Finding Text

Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (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: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: These GLBA requirements were applicable beginning on June 9, 2023. During our testing, we noted certain components of the GLBA requirements that, although they have been implemented by the University, were not included in the University’s written information security program (WISP). The specific components were identified in requirement B.3, pertaining to the implementation of periodic review and implementation of user access controls, encryption controls, the use of multi-factor authentication, and change management policy. Furthermore, it was noted that the WISP did not describe the University’s policies for penetration testing or vulnerability scans. Cause: There was not a formal process in place to compare the WISP against all the new GLBA requirements to ensure compliance. Effect: The University’s WISP does not include all of the required elements. Repeat finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. We do note that after June 30, 2023 the University has updated the WISP to include all of the required elements. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 371066 2023-001
    Significant Deficiency
  • 371068 2023-001
    Significant Deficiency
  • 371069 2023-001
    Significant Deficiency
  • 371070 2023-002
    Significant Deficiency
  • 371071 2023-002
    Significant Deficiency
  • 371072 2023-002
    Significant Deficiency
  • 371073 2023-002
    Significant Deficiency
  • 371074 2023-002
    Significant Deficiency
  • 371075 2023-002
    Significant Deficiency
  • 371076 2023-002
    Significant Deficiency
  • 371077 2023-002
    Significant Deficiency
  • 371078 2023-002
    Significant Deficiency
  • 371079 2023-002
    Significant Deficiency
  • 371080 2023-002
    Significant Deficiency
  • 371081 2023-002
    Significant Deficiency
  • 371082 2023-002
    Significant Deficiency
  • 371083 2023-002
    Significant Deficiency
  • 371084 2023-002
    Significant Deficiency
  • 371085 2023-002
    Significant Deficiency
  • 371086 2023-002
    Significant Deficiency
  • 371087 2023-002
    Significant Deficiency
  • 371088 2023-002
    Significant Deficiency
  • 371089 2023-002
    Significant Deficiency
  • 371090 2023-002
    Significant Deficiency
  • 371091 2023-002
    Significant Deficiency
  • 371092 2023-002
    Significant Deficiency
  • 371093 2023-002
    Significant Deficiency
  • 371094 2023-002
    Significant Deficiency
  • 371095 2023-002
    Significant Deficiency
  • 371096 2023-002
    Significant Deficiency
  • 371097 2023-002
    Significant Deficiency
  • 371098 2023-002
    Significant Deficiency
  • 371099 2023-002
    Significant Deficiency
  • 947508 2023-001
    Significant Deficiency
  • 947509 2023-001
    Significant Deficiency
  • 947510 2023-001
    Significant Deficiency
  • 947511 2023-001
    Significant Deficiency
  • 947512 2023-002
    Significant Deficiency
  • 947513 2023-002
    Significant Deficiency
  • 947514 2023-002
    Significant Deficiency
  • 947515 2023-002
    Significant Deficiency
  • 947516 2023-002
    Significant Deficiency
  • 947517 2023-002
    Significant Deficiency
  • 947518 2023-002
    Significant Deficiency
  • 947519 2023-002
    Significant Deficiency
  • 947520 2023-002
    Significant Deficiency
  • 947521 2023-002
    Significant Deficiency
  • 947522 2023-002
    Significant Deficiency
  • 947523 2023-002
    Significant Deficiency
  • 947524 2023-002
    Significant Deficiency
  • 947525 2023-002
    Significant Deficiency
  • 947526 2023-002
    Significant Deficiency
  • 947527 2023-002
    Significant Deficiency
  • 947528 2023-002
    Significant Deficiency
  • 947529 2023-002
    Significant Deficiency
  • 947530 2023-002
    Significant Deficiency
  • 947531 2023-002
    Significant Deficiency
  • 947532 2023-002
    Significant Deficiency
  • 947533 2023-002
    Significant Deficiency
  • 947534 2023-002
    Significant Deficiency
  • 947535 2023-002
    Significant Deficiency
  • 947536 2023-002
    Significant Deficiency
  • 947537 2023-002
    Significant Deficiency
  • 947538 2023-002
    Significant Deficiency
  • 947539 2023-002
    Significant Deficiency
  • 947540 2023-002
    Significant Deficiency
  • 947541 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.55M
84.063 Federal Pell Grant Program $1.34M
84.425 Education Stabilization Fund $1.33M
84.007 Federal Supplemental Educational Opportunity Grants $264,242
47.083 Integrative Activities $149,375
93.395 Cancer Treatment Research $130,805
47.074 Biological Sciences $128,857
47.075 Social, Behavioral, and Economic Sciences $118,188
43.001 Science $117,158
84.033 Federal Work-Study Program $105,617
47.049 Mathematical and Physical Sciences $95,543
10.215 Sustainable Agriculture Research and Education $79,561
93.859 Biomedical Research and Research Training $52,299
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $50,266
84.324 Research in Special Education $25,267
93.137 Community Programs to Improve Minority Health Grant Program $21,726
45.163 Promotion of the Humanities_professional Development $20,992
12.006 National Defense Education Program $17,125
93.575 Child Care and Development Block Grant $14,659
15.657 Endangered Species Conservation Ð Recovery Implementation Funds $14,406
84.027 Special Education_grants to States $13,556
93.945 Assistance Programs for Chronic Disease Prevention and Control $10,620
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $8,472
47.076 Education and Human Resources $8,335
43.008 Education $5,000
93.110 Maternal and Child Health Federal Consolidated Programs $4,500
94.006 Americorps $362