Finding 574616 (2024-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-08-25

AI Summary

  • Core Issue: The University is not fully compliant with the updated requirements of the Gramm-Leach-Bliley Act (GLBA).
  • Impacted Requirements: Insufficient documentation and implementation of the information security program as per 16 CFR 314.3 and 314.4.
  • Recommended Follow-Up: Allocate necessary resources to meet GLBA requirements and enhance student information security.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not sufficiently documented the information security program as required by the updated GLBA rule, or implemented the components required. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University 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: 2023-003 Recommendation: We recommend the University 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.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Southwestern Christian University acknowledges the importance of the Gramm-Leach-Bliley Act (GBLA) and the responsibilities it places on higher education institutions to protect personal and financial information of students, families, and employees. We are committed to safeguarding sensitive data as part of our responsibility to operate with integrity and stewardship. To address these findings, SCU is working closely with our IT specialist in taking the following steps: a. Information Security Program: we are formalizing a written information security plan that meets the GLBA requirements, including risk assessment, safeguards, and monitoring. b. Designation of Coordinator: A qualified staff member has been designated to oversee GLBA compliance and ensure accountability in implementing safeguards. c. Employee training: Faculty and staff will be trained on data privacy, cybersecurity practices, and proper handling of sensitive information. d. Technical Safeguards: We will be enhancing systems for data encryption, access controls, and monitoring to reduce risks related to unauthorized access or disclosure. e. Ongoing review: Regular testing, audits, and updates will be conducted to ensure continuous improvement and adherence to GLBA standards. At Southwestern Christian University, we believe in protecting the personal information of our students and families is part of our mission of stewardship. Just as we are called to be faithful with financial resources, we are equally called to be trustworthy in safeguarding data. We are confident that the corrective actions being implemented will ensure that SCU not only meets compliance standards but also reflects our values of integrity, accountability and care. Person Responsible for Corrective Action Plan: Mark Arthur, Chief Financial Officer Anticipated Date of Completion: June 30, 2026

Categories

Material Weakness

Other Findings in this Audit

  • 574617 2024-003
    Material Weakness Repeat
  • 574618 2024-003
    Material Weakness Repeat
  • 574619 2024-003
    Material Weakness Repeat
  • 1151058 2024-003
    Material Weakness Repeat
  • 1151059 2024-003
    Material Weakness Repeat
  • 1151060 2024-003
    Material Weakness Repeat
  • 1151061 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.41M
84.063 Federal Pell Grant Program $866,917
84.007 Federal Supplemental Educational Opportunity Grants $39,337
84.033 Federal Work-Study Program $30,414