Finding Text
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster – Various
Assistance Listing Numbers: Various
Federal Award Identification Number and Year: Various
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: July 1, 2023, through June 30, 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 (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: During our testing, we noted the Academy did not implement multi-factor authentication (MFA) for anyone accessing customer information on the institution’s system during the year under audit.
Questioned costs: None
Context: Implement MFA is required based on the GLBA requirements that were applicable beginning on June 9, 2023 and was not implemented during the year under audit.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: Student personal information could be vulnerable.
Repeat finding: Yes
Recommendation: We recommend the Academy implement MFA for individuals that access sensitive information per GLBA requirements.
Views of responsible officials: There is no disagreement with the audit finding.