Finding 540475 (2024-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 350256
Organization: Hawaii Pacific University (HI)
Auditor: Kmh LLP

AI Summary

  • Core Issue: The University lacks a written information security program as required by the Gramm-Leach-Bliley Act (GLBA), despite having a designated security officer.
  • Impacted Requirements: Failure to comply with GLBA could lead to administrative actions from the Department of Education and affect Title IV program participation.
  • Recommended Follow-Up: The University should develop a comprehensive information security program, document compliance efforts, and conduct regular internal assessments or engage a third-party consultant for reviews.

Finding Text

Criteria: 16 CFR Part 314 requires the University to implement information safeguard standards prescribed by the Gramm-Leach-Bliley Act (GLBA). GLBA requires institutions and servicers to develop, implement, and maintain a written, comprehensive information security program which contains administrative, technical, and physical safeguards that are appropriate to the size and complexity of the institution or servicer, the nature and scope of their activities, and the sensitivity of any student information. An institution’s written information security program must include the following elements: • Element 1: Designates a Qualified Individual responsible for overseeing and implementing the institution’s or servicer’s information security program and enforcing the information security program (16 C.F.R. 314.4(a)). • Element 2: 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 or servicer) 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 C.F.R. 314.4(b)). • Element 3: Provides for the design and implementation of safeguards to control the risks the institution or servicer identifies through its risk assessment (16 C.F.R. 314.4(c)). At a minimum, the written information security program must address the implementation of the minimum safeguards identified in 16 C.F.R. 314.4(c)(1) through (8). • Element 4: Provides for the institution or servicer to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 C.F.R. 314.4(d)). • Element 5: Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program (16 C.F.R. 314.4(e)) • Element 6: Addresses how the institution or servicer will oversee its information system service providers (16 C.F.R. 314.4(f)). • Element 7: Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the information security program (16 C.F.R. 314.4(g)). • Element 8: For an institution or servicer maintaining student information on 5,000 or more consumers, addresses the establishment of an incident response plan (16 C.F.R. 314.4(h)). • Element 9: For an institution or servicer maintaining student information on 5,000 or more consumers, addresses the requirement for its Qualified Individual to report regularly and at least annually to those with control over the institution on the institution’s information security program (16 C.F.R. 314.4(i)). Context: We conducted inquiries with the University’s Information Security Officer to determine whether the University had a written information security program that addressed the elements required by GLBA. Although the University has a designated security officer (i.e. Qualified Individual), management confirmed that the University did not have a written comprehensive program in place as prescribed by the GLBA. Cause: Management indicated there was a lack of awareness regarding the requirement to establish an information security program that addressed the required elements. Effect: The University was not in compliance with the GLBA requirement which could result in administrative action by the Department of Education and may impact the University’s participation in Title IV programs. Questioned Costs: None Identification of repeat finding: N/A. Recommendations: We recommend the University develop and implement an Information Security Program that includes the required elements prescribed by GLBA. The University should develop and retain documentation supporting the completion and implementation of each of the required elements. Once completed, the University should conduct periodic internal assessments of the Information Security Programs’ compliance or consider engaging a third-party consultant to conduct such a review. Views of responsible officials: The Information Security Officer has developed a comprehensive project plan to implement the core 9 elements as listed under FTC Safeguards. The plan is backed by HPU’s 3rd party risk assessment conducted in November of 2024. The addition of a new hire and a part-time resource has facilitated significant progress. Budget for necessary tools, software, and services such as penetration testing are being actively quoted for review by the Budget Office and CFO for both current and future fiscal years. Checkpoints have been established every two weeks to review and confirm substantial progress towards meeting all requirements and address any barriers or setbacks that may occur. The Vice President of Operations and CIO will review the progress support efforts to meet the requirements and targeted delivery date. The HPU Cybersecurity Committee will be provided with the 2024 Risk Assessment and the Information Security Program documentation and policies for both initial and ongoing review of the programs with the objective to further strengthen the program beyond minimum requirement.

Categories

Subrecipient Monitoring Student Financial Aid

Other Findings in this Audit

  • 540445 2024-004
    Material Weakness Repeat
  • 540446 2024-005
    Material Weakness
  • 540447 2024-004
    Material Weakness Repeat
  • 540448 2024-005
    Material Weakness
  • 540449 2024-004
    Material Weakness Repeat
  • 540450 2024-005
    Material Weakness
  • 540451 2024-004
    Material Weakness Repeat
  • 540452 2024-005
    Material Weakness
  • 540453 2024-004
    Material Weakness Repeat
  • 540454 2024-005
    Material Weakness
  • 540455 2024-004
    Material Weakness Repeat
  • 540456 2024-005
    Material Weakness
  • 540457 2024-004
    Material Weakness Repeat
  • 540458 2024-005
    Material Weakness
  • 540459 2024-004
    Material Weakness Repeat
  • 540460 2024-005
    Material Weakness
  • 540461 2024-004
    Material Weakness Repeat
  • 540462 2024-005
    Material Weakness
  • 540463 2024-004
    Material Weakness Repeat
  • 540464 2024-005
    Material Weakness
  • 540465 2024-002
    Material Weakness
  • 540466 2024-003
    Material Weakness
  • 540467 2024-006
    Significant Deficiency
  • 540468 2024-004
    Material Weakness Repeat
  • 540469 2024-005
    Material Weakness
  • 540470 2024-004
    Material Weakness Repeat
  • 540471 2024-005
    Material Weakness
  • 540472 2024-002
    Material Weakness
  • 540473 2024-003
    Material Weakness
  • 540474 2024-006
    Significant Deficiency
  • 540476 2024-003
    Material Weakness
  • 540477 2024-006
    Significant Deficiency
  • 540478 2024-002
    Material Weakness
  • 540479 2024-003
    Material Weakness
  • 540480 2024-006
    Significant Deficiency
  • 540481 2024-002
    Material Weakness
  • 540482 2024-003
    Material Weakness
  • 540483 2024-006
    Significant Deficiency
  • 540484 2024-002
    Material Weakness
  • 540485 2024-003
    Material Weakness
  • 540486 2024-006
    Significant Deficiency
  • 540487 2024-002
    Material Weakness
  • 540488 2024-003
    Material Weakness
  • 540489 2024-006
    Significant Deficiency
  • 540490 2024-004
    Material Weakness Repeat
  • 540491 2024-005
    Material Weakness
  • 540492 2024-004
    Material Weakness Repeat
  • 540493 2024-005
    Material Weakness
  • 540494 2024-004
    Material Weakness Repeat
  • 540495 2024-005
    Material Weakness
  • 540496 2024-004
    Material Weakness Repeat
  • 540497 2024-005
    Material Weakness
  • 540498 2024-002
    Material Weakness
  • 540499 2024-003
    Material Weakness
  • 540500 2024-006
    Significant Deficiency
  • 540501 2024-004
    Material Weakness Repeat
  • 540502 2024-005
    Material Weakness
  • 540503 2024-004
    Material Weakness Repeat
  • 540504 2024-005
    Material Weakness
  • 540505 2024-004
    Material Weakness Repeat
  • 540506 2024-005
    Material Weakness
  • 540507 2024-004
    Material Weakness Repeat
  • 540508 2024-005
    Material Weakness
  • 1116887 2024-004
    Material Weakness Repeat
  • 1116888 2024-005
    Material Weakness
  • 1116889 2024-004
    Material Weakness Repeat
  • 1116890 2024-005
    Material Weakness
  • 1116891 2024-004
    Material Weakness Repeat
  • 1116892 2024-005
    Material Weakness
  • 1116893 2024-004
    Material Weakness Repeat
  • 1116894 2024-005
    Material Weakness
  • 1116895 2024-004
    Material Weakness Repeat
  • 1116896 2024-005
    Material Weakness
  • 1116897 2024-004
    Material Weakness Repeat
  • 1116898 2024-005
    Material Weakness
  • 1116899 2024-004
    Material Weakness Repeat
  • 1116900 2024-005
    Material Weakness
  • 1116901 2024-004
    Material Weakness Repeat
  • 1116902 2024-005
    Material Weakness
  • 1116903 2024-004
    Material Weakness Repeat
  • 1116904 2024-005
    Material Weakness
  • 1116905 2024-004
    Material Weakness Repeat
  • 1116906 2024-005
    Material Weakness
  • 1116907 2024-002
    Material Weakness
  • 1116908 2024-003
    Material Weakness
  • 1116909 2024-006
    Significant Deficiency
  • 1116910 2024-004
    Material Weakness Repeat
  • 1116911 2024-005
    Material Weakness
  • 1116912 2024-004
    Material Weakness Repeat
  • 1116913 2024-005
    Material Weakness
  • 1116914 2024-002
    Material Weakness
  • 1116915 2024-003
    Material Weakness
  • 1116916 2024-006
    Significant Deficiency
  • 1116917 2024-002
    Material Weakness
  • 1116918 2024-003
    Material Weakness
  • 1116919 2024-006
    Significant Deficiency
  • 1116920 2024-002
    Material Weakness
  • 1116921 2024-003
    Material Weakness
  • 1116922 2024-006
    Significant Deficiency
  • 1116923 2024-002
    Material Weakness
  • 1116924 2024-003
    Material Weakness
  • 1116925 2024-006
    Significant Deficiency
  • 1116926 2024-002
    Material Weakness
  • 1116927 2024-003
    Material Weakness
  • 1116928 2024-006
    Significant Deficiency
  • 1116929 2024-002
    Material Weakness
  • 1116930 2024-003
    Material Weakness
  • 1116931 2024-006
    Significant Deficiency
  • 1116932 2024-004
    Material Weakness Repeat
  • 1116933 2024-005
    Material Weakness
  • 1116934 2024-004
    Material Weakness Repeat
  • 1116935 2024-005
    Material Weakness
  • 1116936 2024-004
    Material Weakness Repeat
  • 1116937 2024-005
    Material Weakness
  • 1116938 2024-004
    Material Weakness Repeat
  • 1116939 2024-005
    Material Weakness
  • 1116940 2024-002
    Material Weakness
  • 1116941 2024-003
    Material Weakness
  • 1116942 2024-006
    Significant Deficiency
  • 1116943 2024-004
    Material Weakness Repeat
  • 1116944 2024-005
    Material Weakness
  • 1116945 2024-004
    Material Weakness Repeat
  • 1116946 2024-005
    Material Weakness
  • 1116947 2024-004
    Material Weakness Repeat
  • 1116948 2024-005
    Material Weakness
  • 1116949 2024-004
    Material Weakness Repeat
  • 1116950 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $38.81M
84.063 Federal Pell Grant Program $4.15M
84.031 Higher Education Institutional Aid $866,229
10.237 From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals $508,876
93.364 Nursing Student Loans $465,512
84.038 Federal Perkins Loan Program_federal Capital Contributions $448,254
84.033 Federal Work-Study Program $314,802
11.417 Sea Grant Support $285,652
84.007 Federal Supplemental Educational Opportunity Grants $228,999
11.609 Measurement and Engineering Research and Standards $220,979
20.205 Highway Planning and Construction $196,719
47.050 Geosciences $156,022
93.264 Nurse Faculty Loan Program (nflp) $126,593
11.427 Fisheries Development and Utilization Research and Development Grants and Cooperative Agreements Program $125,630
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $115,877
93.279 Drug Use and Addiction Research Programs $97,809
93.859 Biomedical Research and Research Training $78,312
93.310 Trans-Nih Research Support $61,801
12.431 Basic Scientific Research $60,679
47.083 Integrative Activities $59,173
11.999 Marine Debris Program $57,025
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $50,966
47.076 Stem Education (formerly Education and Human Resources) $41,967
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $34,534
93.110 Maternal and Child Health Federal Consolidated Programs $22,800
11.454 Unallied Management Projects $22,378
10.200 Grants for Agricultural Research, Special Research Grants $17,470
11.620 Science, Technology, Business And/or Education Outreach $14,310
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,544