Finding 628663 (2022-002)

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Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-07-17
Audit: 50889
Organization: Holy Names University (CA)

AI Summary

  • Core Issue: The University has not conducted a formal risk assessment since January 2021, leaving student financial aid information vulnerable.
  • Impacted Requirements: The University’s IT policies do not fully meet the Gramm-Leach-Bliley Act's requirements for identifying and managing data security risks.
  • Recommended Follow-Up: Engage an outside resource to perform a formal risk assessment and provide remediation recommendations for any identified deficiencies.

Finding Text

2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.67M
84.047 Trio_upward Bound $1.04M
84.031 Higher Education_institutional Aid $565,081
84.425 Education Stabilization Fund $268,459
84.033 Federal Work-Study Program $148,819
84.038 Federal Perkins Loan Program - Outstanding As of July 1, 2021 $102,280
84.007 Federal Supplemental Educational Opportunity Grants $102,140
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $16,837
84.063 Federal Pell Grant Program $1,435
84.038 Federal Perkins Loan Program - Administrative Cost Allowance $0
84.038 Federal Perkins Loan Program - Loans Issued in the Year $0