Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
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 updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University 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 University 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.