Finding 513255 (2024-001)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-06
Audit: 331201
Organization: Dallas Christian College (TX)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The College did not fully comply with GLBA requirements, specifically lacking multi-factor authentication (MFA) on all systems containing personally identifiable information (PII).
  • Impacted Requirements: Compliance with 16 CFR 314.4(c)(5) regarding the protection of PII.
  • Recommended Follow-Up: Implement MFA on the remaining system as soon as possible to mitigate security risks.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 - Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College had not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) during the fiscal year to comply with 16 CFR 314.4(c)(5). Subsequent to year-end, all but one system has MFA added. Cause: For the system that did not allow MFA natively in the prior year, a new system was identified, and the College moved to the new system shortly after fiscal year end. There is one additional system that the College is working to implement MFA as soon as possible. We commend the College for the substantial work done during the year. Effect: The College may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the College implement MFA on the one remaining system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: We migrated to a new student information system in September 2024 which does have both SSO and MFA capabilities. In addition, we only have one remaining VPN system to which we will add MFA. Person Responsible for Corrective Action Plan: Stephen Cobb, Director of Technology. Anticipated Date of Completion: December 31, 2024

Categories

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Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.57M
84.063 Federal Pell Grant Program $744,233
84.033 Federal Work-Study Program $29,223
84.007 Federal Supplemental Educational Opportunity Grants $19,714
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772