Finding 7885 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-08
Audit: 10258
Organization: West Shore Community College (MI)

AI Summary

  • Core Issue: The College's security policy lacks necessary safeguards for compliance with the Gramm Leach Bliley Act, particularly regarding oversight of information service providers and security assessments.
  • Impacted Requirements: The policy fails to include annual penetration tests and biannual vulnerability assessments, increasing risks to sensitive data.
  • Recommended Follow-Up: Implement a review process to ensure compliance with all Gramm Leach Bliley policies, with confirmation from a second individual.

Finding Text

2023-002 - Gramm Leach Bliley Missing Compliance Requirements. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222103, P033A222103, P063P225088, and P268K225088. 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 written security policy fails to address how the College will oversee its information system service providers and the evaluation and adjustment of its information security program for any changes in the College's operations or the results of risk assessments. Additionally, the College's policy does not include performing annual penetration tests or biannual vulnerability assessments, as required by the Gramm Leach Bliley Act. Cause. The College does not have a review process in place to ensure all safeguard policies set forth in the Gramm Leach Bliley Act are met in the written security policy. 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. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley policies are met and confirmed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Categories

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 7878 2023-001
    Significant Deficiency
  • 7879 2023-001
    Significant Deficiency
  • 7880 2023-001
    Significant Deficiency
  • 7881 2023-001
    Significant Deficiency
  • 7882 2023-002
    Significant Deficiency
  • 7883 2023-002
    Significant Deficiency
  • 7884 2023-002
    Significant Deficiency
  • 584320 2023-001
    Significant Deficiency
  • 584321 2023-001
    Significant Deficiency
  • 584322 2023-001
    Significant Deficiency
  • 584323 2023-001
    Significant Deficiency
  • 584324 2023-002
    Significant Deficiency
  • 584325 2023-002
    Significant Deficiency
  • 584326 2023-002
    Significant Deficiency
  • 584327 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.29M
84.425 Education Stabilization Fund $822,050
84.268 Federal Direct Student Loans $278,537
84.048 Career and Technical Education -- Basic Grants to States $108,106
84.007 Federal Supplemental Educational Opportunity Grants $80,151
84.033 Federal Work-Study Program $21,478