Finding 580718 (2023-006)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-12-13
Audit: 6574
Organization: City Colleges of Chicago (IL)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: City Colleges lacks a documented policy for a required safeguard under the Gramm-Leach Bliley Act, specifically failing to conduct a periodic inventory of data.
  • Impacted Requirements: This finding violates 16 CFR 314.4(c), which mandates institutions to implement minimum safeguards for information security, including data inventory and access controls.
  • Recommended Follow-Up: City Colleges should finalize and implement a formal policy to ensure compliance with GLBA requirements by Spring 2024.

Finding Text

Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans: 84.268 Federal Pell Grant Program: 84.063 Federal Work-Study Program: 84.033 Federal Supplemental Educational Opportunity Grants: 84.007 Federal Award Year 2022-2023 Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic inventory of data, nothing where it’s collected, stored or transmitted. Criteria In accordance with 16 CFR 314.4(c), an institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). This includes the following: (1) implement and periodically review access controls, (2) conduct a periodic inventory of data, noting where it’s collected, stored or transmitted, (3) encrypt customer information on the institution’s system and when it’s in transit, (4) assess apps developed by the institution, (5) implement multi-factor authentication for anyone accessing customer information on the institution’s system, (6) dispose of customer information securely, (7) anticipate and evaluate changes to the information system or network, and (8) maintain a log of authorized users’ activity and keep an eye out for unauthorized users. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are being completed over information security policies and that they are in compliance with GLBA requirements. Questioned Costs There were no questioned costs with respect to this finding. Cause City Colleges does not have a periodic data inventory in place. The policy is under development with an expected completion date of Spring 2024. Effect Failure to meet the minimum requirements of the GLBA act is noncompliance and increases the risk of unauthorized disclosure, misuse, alteration, destruction, or other comprise of student information. Recommendation We recommend City Colleges implement controls to ensure that GLBA requirements are reviewed and addressed in a formally documented policy. Views of responsible officials We agree with this finding. See corrective action plan.

Categories

Student Financial Aid Equipment & Real Property Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 4265 2023-001
    Significant Deficiency Repeat
  • 4266 2023-001
    Significant Deficiency Repeat
  • 4267 2023-002
    Significant Deficiency Repeat
  • 4268 2023-003
    Significant Deficiency
  • 4269 2023-003
    Significant Deficiency
  • 4270 2023-004
    Significant Deficiency
  • 4271 2023-004
    Significant Deficiency
  • 4272 2023-005
    Significant Deficiency
  • 4273 2023-005
    Significant Deficiency
  • 4274 2023-005
    Significant Deficiency
  • 4275 2023-005
    Significant Deficiency
  • 4276 2023-006
    Significant Deficiency
  • 4277 2023-006
    Significant Deficiency
  • 4278 2023-006
    Significant Deficiency
  • 4279 2023-006
    Significant Deficiency
  • 4280 2023-007
    Significant Deficiency Repeat
  • 4281 2023-008
    Significant Deficiency
  • 4282 2023-008
    Significant Deficiency
  • 4283 2023-008
    Significant Deficiency
  • 4284 2023-008
    Significant Deficiency
  • 580707 2023-001
    Significant Deficiency Repeat
  • 580708 2023-001
    Significant Deficiency Repeat
  • 580709 2023-002
    Significant Deficiency Repeat
  • 580710 2023-003
    Significant Deficiency
  • 580711 2023-003
    Significant Deficiency
  • 580712 2023-004
    Significant Deficiency
  • 580713 2023-004
    Significant Deficiency
  • 580714 2023-005
    Significant Deficiency
  • 580715 2023-005
    Significant Deficiency
  • 580716 2023-005
    Significant Deficiency
  • 580717 2023-005
    Significant Deficiency
  • 580719 2023-006
    Significant Deficiency
  • 580720 2023-006
    Significant Deficiency
  • 580721 2023-006
    Significant Deficiency
  • 580722 2023-007
    Significant Deficiency Repeat
  • 580723 2023-008
    Significant Deficiency
  • 580724 2023-008
    Significant Deficiency
  • 580725 2023-008
    Significant Deficiency
  • 580726 2023-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $48.88M
84.268 Federal Direct Student Loans $3.70M
84.007 Federal Supplemental Educational Opportunity Grants $2.59M
84.002 Adult Education - Basic Grants to States $1.78M
93.600 Head Start $1.68M
93.575 Child Care and Development Block Grant $1.22M
12.006 National Defense Education Program $1.00M
84.425 Education Stabilization Fund $1.00M
84.048 Career and Technical Education -- Basic Grants to States $893,559
84.042 Trio_student Support Services $801,918
16.575 Crime Victim Assistance $664,261
84.033 Federal Work-Study Program $653,800
47.076 Education and Human Resources $563,204
84.382 Strengthening Minority-Serving Institutions $450,437
84.044 Trio_talent Search $345,063
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $333,367
20.205 Highway Planning and Construction $253,409
84.066 Trio_educational Opportunity Centers $242,457
17.268 H-1b Job Training Grants $225,991
10.558 Child and Adult Care Food Program $144,596
84.031 Higher Education_institutional Aid $130,988
21.027 Coronavirus State and Local Fiscal Recovery Funds $105,397
81.117 Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/assistance $41,771
84.116 Fund for the Improvement of Postsecondary Education $36,849
93.732 Mental and Behavioral Health Education and Training Grants $20,885
93.859 Biomedical Research and Research Training $12,375
17.285 Apprenticeship USA Grants $2,640
81.049 Office of Science Financial Assistance Program $2,471