Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented formalized employee training program, documented in data retention policies disposal of PII, or provided a written, annual report to the board covering all required elements.
Cause: The University has not codified and documented all informal practices occurring for compliance with 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: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to codify and document compliance with all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.