Finding 610433 (2022-005)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-16

AI Summary

  • Core Issue: The College lacks adequate safeguards to protect sensitive student information, putting it at risk.
  • Impacted Requirements: Compliance with 16 CFR 314.4 is not met, specifically regarding access controls and encryption of sensitive data.
  • Recommended Follow-Up: Develop and implement comprehensive information security policies to address identified risks as per the IT assessment.

Finding Text

Finding Number: 2022-005 Information on the Federal Program: Federal Agency: United States Department of Education (ED) Program Name: Student Financial Assistance Cluster Federal Award Identification Number: N/A Federal Award Year: Year Ended May 31, 2022 Specific Requirement: Required by 16 CFR 314.4, an institution must design and implement safeguards to control the risks identified through risk assessment including by (1) implementing and periodically review access controls, including technical and physical controls to (i) authenticate and permit access only to authorized users to protect against the unauthorized acquisition of student information and (ii) limit authorized users? access only to student information that they need to perform their duties and functions, (2) identifying and managing the data, personnel, devices, systems and facilities that enable them to achieve business purposes in accordance with their relative importance to business objectives and (3) protect by encryption all student information held or transmitted over external networks and at rest. Condition Found: During our audit, we noted the College does not have adequate safeguards and controls in place to mitigate identified information security risks. Context: Based on our testing, an information security risk assessment was completed by a third-party consultant. This risk assessment identified several instances where sensitive information is not encrypted and stands at risk. Based on our discussion with management, the risk assessment was completed in the Spring of 2022 and they did not have enough time to implement sufficient responses and safeguards to the identified information security risks. Questioned Costs: None. Cause and Effect: The College does not have adequate staff on site needed to efficiently implement information security changes. As a result, there are areas where sensitive student information is at risk. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: We recommend the College create information security policies and implement safeguards for each of the identified risks within the information technology assessment completed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan on page 42.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 33990 2022-004
    Significant Deficiency
  • 33991 2022-005
    Significant Deficiency
  • 33992 2022-005
    Significant Deficiency
  • 33993 2022-005
    Significant Deficiency
  • 610432 2022-004
    Significant Deficiency
  • 610434 2022-005
    Significant Deficiency
  • 610435 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $404,798
84.063 Federal Pell Grant Program $152,314
84.425 Education Stabilization Fund $151,003
84.007 Federal Supplemental Educational Opportunity Grants $8,813