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-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The College has not:
• documented a written information security program addressing all requirements of GLBA
• sufficiently documented its security risk assessment and safeguards for all systems containing personally identifiable information (PII)
• implemented multi-factor authentication on systems containing personally identifiable information (PII)
• 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 updated requirements of GLBA.
Effect: The College has not adequately addressed the updated 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 updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.