Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379
Federal Award Identification #: 2022-2023 Financial Aid 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 has not:
• Implemented multi-factor authentication on systems containing personally identifiable information (PII)
• Implemented continuous monitoring, such as penetration testing and vulnerability scanning
• Implemented sufficient vendor management policies and reviews
• Provided a written, annual report to the board
Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.