Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The College had noted the updated requirements of GLBA and engaged a third party to assist with addressing and documenting compliance with the updated requirements of GLBA. This process took place after fiscal year-end.
Effect: The College may have unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the College 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.