Finding 384133 (2023-005)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-25
Audit: 297264
Organization: Concordia University, St. Paul (MN)

AI Summary

  • Core Issue: The Written Information Security Program (WISP) is missing key elements required by the Gramm-Leach-Bliley Act (GLBA).
  • Impacted Requirements: Compliance with GLBA mandates for safeguarding sensitive data and explaining information-sharing practices.
  • Recommended Follow-Up: Review and update the WISP to include all necessary elements as per the new GLBA requirements effective June 9, 2023.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to 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 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: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have taken all of the findings and placed it on our risk register. Each Wednesday, we have a vulnerability call with our VCISCO. Over the last year, we have reduced the number of vulnerabilities in our systems. Over the last month, we have begun to work on the items on our risk register. We have a working session set for April 8, 2024 to update all findings that relate to the policies that were not to standard. For the other items, we will work on our weekly calls to set up the necessary SOPs to address the deficiencies. Name of the contact person responsible for corrective action: Director of Computer Services of Network Jonathan Breitbarth Planned completion date for corrective action plan: June 30, 2024

Categories

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 384112 2023-001
    Material Weakness Repeat
  • 384113 2023-001
    Material Weakness Repeat
  • 384114 2023-001
    Material Weakness Repeat
  • 384115 2023-001
    Material Weakness Repeat
  • 384116 2023-001
    Material Weakness Repeat
  • 384117 2023-001
    Material Weakness Repeat
  • 384118 2023-002
    Significant Deficiency Repeat
  • 384119 2023-002
    Significant Deficiency Repeat
  • 384120 2023-002
    Significant Deficiency Repeat
  • 384121 2023-002
    Significant Deficiency Repeat
  • 384122 2023-002
    Significant Deficiency Repeat
  • 384123 2023-002
    Significant Deficiency Repeat
  • 384124 2023-003
    Significant Deficiency
  • 384125 2023-003
    Significant Deficiency
  • 384126 2023-003
    Significant Deficiency
  • 384127 2023-004
    Significant Deficiency
  • 384128 2023-004
    Significant Deficiency
  • 384129 2023-004
    Significant Deficiency
  • 384130 2023-004
    Significant Deficiency
  • 384131 2023-004
    Significant Deficiency
  • 384132 2023-004
    Significant Deficiency
  • 384134 2023-005
    Significant Deficiency
  • 384135 2023-005
    Significant Deficiency
  • 384136 2023-005
    Significant Deficiency
  • 384137 2023-005
    Significant Deficiency
  • 384138 2023-005
    Significant Deficiency
  • 384139 2023-006
    Significant Deficiency
  • 960554 2023-001
    Material Weakness Repeat
  • 960555 2023-001
    Material Weakness Repeat
  • 960556 2023-001
    Material Weakness Repeat
  • 960557 2023-001
    Material Weakness Repeat
  • 960558 2023-001
    Material Weakness Repeat
  • 960559 2023-001
    Material Weakness Repeat
  • 960560 2023-002
    Significant Deficiency Repeat
  • 960561 2023-002
    Significant Deficiency Repeat
  • 960562 2023-002
    Significant Deficiency Repeat
  • 960563 2023-002
    Significant Deficiency Repeat
  • 960564 2023-002
    Significant Deficiency Repeat
  • 960565 2023-002
    Significant Deficiency Repeat
  • 960566 2023-003
    Significant Deficiency
  • 960567 2023-003
    Significant Deficiency
  • 960568 2023-003
    Significant Deficiency
  • 960569 2023-004
    Significant Deficiency
  • 960570 2023-004
    Significant Deficiency
  • 960571 2023-004
    Significant Deficiency
  • 960572 2023-004
    Significant Deficiency
  • 960573 2023-004
    Significant Deficiency
  • 960574 2023-004
    Significant Deficiency
  • 960575 2023-005
    Significant Deficiency
  • 960576 2023-005
    Significant Deficiency
  • 960577 2023-005
    Significant Deficiency
  • 960578 2023-005
    Significant Deficiency
  • 960579 2023-005
    Significant Deficiency
  • 960580 2023-005
    Significant Deficiency
  • 960581 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $35.20M
84.063 Federal Pell Grant Program $5.30M
84.038 Federal Perkins Loans Outstanding, Beginning of Year $555,118
84.007 Federal Supplemental Educational Opportunity Grants $308,750
84.033 Federal Work-Study Program $133,000
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $100,919
84.425 Education Stabilization Fund $60,961