Finding 585750 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-22
Audit: 12796
Organization: North Central Michigan College (MI)

AI Summary

  • Core Issue: The College's Gramm Leach Bliley Policy lacks essential safeguards like multi-factor authentication and data encryption.
  • Impacted Requirements: Noncompliance with FTC regulations increases risks to sensitive customer data.
  • Recommended Follow-up: Implement a review process to ensure all safeguard policies are met and verified by a second individual.

Finding Text

Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor authentication for anyone accessing customer information on the institution's system, conducting a periodic inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Categories

Special Tests & Provisions Significant Deficiency Equipment & Real Property Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 9302 2023-001
    Significant Deficiency
  • 9303 2023-001
    Significant Deficiency
  • 9304 2023-001
    Significant Deficiency
  • 9305 2023-001
    Significant Deficiency
  • 9306 2023-001
    Significant Deficiency
  • 9307 2023-001
    Significant Deficiency
  • 9308 2023-002
    Significant Deficiency
  • 9309 2023-002
    Significant Deficiency
  • 9310 2023-002
    Significant Deficiency
  • 9311 2023-002
    Significant Deficiency
  • 9312 2023-002
    Significant Deficiency
  • 9313 2023-002
    Significant Deficiency
  • 9314 2023-003
    Significant Deficiency
  • 9315 2023-003
    Significant Deficiency
  • 9316 2023-003
    Significant Deficiency
  • 9317 2023-003
    Significant Deficiency
  • 9318 2023-003
    Significant Deficiency
  • 9319 2023-003
    Significant Deficiency
  • 585744 2023-001
    Significant Deficiency
  • 585745 2023-001
    Significant Deficiency
  • 585746 2023-001
    Significant Deficiency
  • 585747 2023-001
    Significant Deficiency
  • 585748 2023-001
    Significant Deficiency
  • 585749 2023-001
    Significant Deficiency
  • 585751 2023-002
    Significant Deficiency
  • 585752 2023-002
    Significant Deficiency
  • 585753 2023-002
    Significant Deficiency
  • 585754 2023-002
    Significant Deficiency
  • 585755 2023-002
    Significant Deficiency
  • 585756 2023-003
    Significant Deficiency
  • 585757 2023-003
    Significant Deficiency
  • 585758 2023-003
    Significant Deficiency
  • 585759 2023-003
    Significant Deficiency
  • 585760 2023-003
    Significant Deficiency
  • 585761 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.82M
84.425 Higher Education Emergency Relief Fund - Institutions of Higher Education - Institutional $820,885
84.048 Career and Technical Education - Basic Grants to States - Local Annual $109,142
84.033 Federal Work-Study Program $55,000
45.164 Promotion of the Humanities_public Programs $53,490
84.268 Federal Direct Student Loans $49,187
84.007 Federal Supplemental Educational Opportunity Grants $35,000
84.048 Career and Technical Education - Basic Grants to States - Local Leadership $9,200