Finding 501794 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-10-04
Audit: 323873
Organization: Augsburg University (MN)

AI Summary

  • Core Issue: The Written Information Security Program (WISP) is missing key elements required by the Gramm-Leach-Bliley Act (GLBA), exposing student personal information to potential risks.
  • Impacted Requirements: Five critical components, including risk assessment and multi-factor authentication, were either absent or in draft form, failing to meet GLBA standards effective June 9, 2023.
  • Recommended Follow-Up: The University should review GLBA requirements and ensure the WISP is complete and properly implemented to safeguard sensitive data.

Finding Text

Federal Agency: Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: N/A Award Period: June 1, 2023 to May 31, 2024 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 five items missing entirely from the Written Information Security Program: B.2 CLA was not able to verify that the WISP provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution) 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. B.3 The following minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) were in draft form in the WISP: o Implement multi-factor authentication for anyone accessing customer information on the institution’s system o Dispose of customer information securely o Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. B.4 In addition, CLA was not able to verify that the WISP provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. Questioned costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were four elements missing from the WISP at the end of the fiscal year. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance as well as there was a general lack of capacity in IT staffing to formally implement the WISP during the year. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements and is formally implemented. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 501787 2024-001
    Significant Deficiency
  • 501788 2024-001
    Significant Deficiency
  • 501789 2024-001
    Significant Deficiency
  • 501790 2024-001
    Significant Deficiency
  • 501791 2024-001
    Significant Deficiency
  • 501792 2024-001
    Significant Deficiency
  • 501793 2024-002
    Significant Deficiency
  • 501795 2024-002
    Significant Deficiency
  • 501796 2024-002
    Significant Deficiency
  • 501797 2024-002
    Significant Deficiency
  • 501798 2024-002
    Significant Deficiency
  • 1078229 2024-001
    Significant Deficiency
  • 1078230 2024-001
    Significant Deficiency
  • 1078231 2024-001
    Significant Deficiency
  • 1078232 2024-001
    Significant Deficiency
  • 1078233 2024-001
    Significant Deficiency
  • 1078234 2024-001
    Significant Deficiency
  • 1078235 2024-002
    Significant Deficiency
  • 1078236 2024-002
    Significant Deficiency
  • 1078237 2024-002
    Significant Deficiency
  • 1078238 2024-002
    Significant Deficiency
  • 1078239 2024-002
    Significant Deficiency
  • 1078240 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $23.74M
84.063 Federal Pell Grant Program $8.18M
84.038 Federal Perkins Loan Program $1.65M
84.007 Federal Supplemental Educational Opportunity Grants $685,822
84.033 Federal Work-Study Program $471,869
84.217 Trio_mcnair Post-Baccalaureate Achievement $264,834
84.042 Trio_student Support Services $243,428
47.050 Geosciences $241,355
47.076 Education and Human Resources $94,595
43.008 Education $46,984
94.021 Volunteer Generation Fund $40,956
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $33,917
47.074 Biological Sciences $22,138
93.242 Mental Health Research Grants $20,856