Finding 387183 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The University lacks written procedures for key elements of its information security program, specifically elements 4, 5, 7, and 9, which are required for compliance with federal regulations.
  • Impacted Requirements: This non-compliance affects the institution's ability to manage risks, monitor safeguards, implement necessary policies, and report on the information security program effectively.
  • Recommended Follow-Up: Develop and implement formal written procedures for the missing elements to ensure compliance with 16 CFR 314 and 2 CFR 200, and conduct regular reviews to maintain adherence.

Finding Text

Criteria (A)Per 16 CFR 314.3 the institutions with 5,000 or more customers must stablish written information securityprogram to include nine elements. The elements that an institution must address in its written informationsecurity program are at 16 CFR 314.4. At a minimum, an institution’s written information security programshould include: 1.Designates a qualified individual responsible for overseeing and implementing the institutions or servicer’sinformation security program and enforcing the information security program (16 C.F.R. 314.4(a)). 2.Provides for the information security program to be based on a risk assessment that identifies reasonablyforeseeable internal and external risks to the security, confidentiality, and integrity of customer information(as the term customer information applies to the institution or servicer) that could result in the unauthorizeddisclosure, misuse, alteration, destruction, or other compromise of such information, and assesses thesufficiency of any safeguards in place to control these risks (16 C.F.R. 314.4(b)). 3.Provides for the design and implementation of safeguards to control the risks the institution or serviceridentifies through its risk assessment (16 C.F.R. 314.4(c)). At a minimum, the written information securityprogram must address the implementation of the minimum safeguards identified in 16 C.F.R. 314.4(c)(1)through (8). 4.Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it hasimplemented (16 CFR 314.4(d)). 5.Provides for the implementation of policies and procedures to ensure that personnel are able to enact theinformation security program (16 C.F.R. 314.4(e)). 6.Addresses how the institution will oversee its information system service providers (16 C.F.R. 314.4(f)). 7.Provides for the evaluation and adjustment of its information security program in light of the results of therequired testing and monitoring; any material changes to its operations or business arrangements; theresults of the required risk assessments; or any other circumstances that it knows or has reason to knowmay have a material impact the information security program (16 C.F.R. 314.4(g)). 8.For an institution or servicer maintaining student information on 5,000 or more consumers, addresses theestablishment of an incident response plan (16 C.F.R. 314.4(h)). 9.For an institution or servicer maintaining student information on 5,000 or more consumers, addresses therequirement for its Qualified Individual to report regularly and at least annually to those with control over theinstitution on the institution’s information security program (16 C.F.R. 314.4(i)). (B)Per 2 CFR 200.303, a non-federal entity mush establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award.Condition and ContextDuring our audit of the internal controls over compliance and compliance requirements, we noted that the University did not have written procedures or formal policies to ensure compliance with all the elements included in the criteria. We were no able to identify formal written procedures for the elements: 4,5,7 and 9.

Corrective Action Plan

Management has already written the basic Security of Information Plan as required by 16 C.F.R. 313.3 and 313.4. A framework for personnel training is being developed, as well as a reporting dateto the Board of Trustees has been set before the end of the current fiscal year. A risk assessment plan isbeing developed and the University is in the process of contracting an independent third party to conductmonitoring and risk assessment of the data security plan, reporting at least four times per year. Correctionsor modifications to the plan or the established safeguards will be implemented based in said monitoring processes. The person designated to be in charge is Dr. Edgardo Aviles Garay, director of the Information Tecnologies and Telecomunications Department, under the guidance of the Vicepresident of Administrative Affairs. The corrective plan should be completed by June 30, 2024.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 387184 2023-001
    Significant Deficiency
  • 387185 2023-001
    Significant Deficiency
  • 387186 2023-001
    Significant Deficiency
  • 387187 2023-001
    Significant Deficiency
  • 963625 2023-001
    Significant Deficiency
  • 963626 2023-001
    Significant Deficiency
  • 963627 2023-001
    Significant Deficiency
  • 963628 2023-001
    Significant Deficiency
  • 963629 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Students Loans $40.50M
84.063 Federal Pell Grant Program $25.42M
84.425F Covid 19 Education Stabilization Fund $15.59M
84.007 Federal Supplemental Educational Opportunity Grant (fseog) $1.22M
83.033 Federal Work-Study Program (fws) $742,414
84.047A Trio Upward Bound $393,520
84.047A Trio Upward Bound-Site $299,337
84.031S High Education – Institutional Aid $208,135
84.129 Rehabilitation Long-Term Training $197,361
16.575 Crime Victim Assistance Program- Voca Centro Servicios Psicologios Nueva Vida Arecibo $158,855
93.859 Inbre-Crosstalk and Other Project $95,498
47.076 Stem Education-Race for Success $80,686
20.614 Program Fiesta-National Highway Traffic Safety Adm (nhtsa) Discretionary Safety Grants and Cooperative Agreements $79,350
97.036 Ecmc-Basic Needs Assistances $15,000
15.657 Endangered Species Recovery Implementation $10,702
97.036 Ecmc-Project Success Emergency Aid $8,800
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,524
10.558 Child and Adult Care Food Program $4,956
93.859 Inbre Cyp 450, Mutation and Crosstalk $142
93.859 Nbre-Mithophagy $111