Finding 385118 (2023-007)

-
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-27
Audit: 298219
Auditor: Sikich LLP

AI Summary

  • Core Issue: The College failed to implement a required risk assessment for its information security program under GLBA standards.
  • Impacted Requirements: This noncompliance affects the College's ability to protect sensitive student information as mandated by federal regulations.
  • Recommended Follow-Up: Complete a formal risk assessment and seek guidance from the Department of Education to ensure compliance.

Finding Text

Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)). Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs. Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Categories

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.27M
84.063 Federal Pell Grant Program $1.06M
84.033 Federal Work-Study Program $957,859
84.038 Federal Perkins Loan Program $75,937
84.007 Federal Supplemental Educational Opportunity Grants $59,400
84.425 Education Stabilization Fund $31,926