Finding 945491 (2023-005)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-14
Audit: 290458
Organization: Connors State College (OK)

AI Summary

  • Core Issue: The college is not fully compliant with the updated Gramm-Leach-Bliley Act requirements, missing key elements in their Written Information Security Program (WISP).
  • Impacted Requirements: The college lacks essential safeguards for protecting sensitive data and has not adequately addressed all elements outlined in 16 CFR 314.
  • Recommended Follow-Up: The college should review and update their WISP to include all necessary components and ensure compliance with the latest GLBA regulations.

Finding Text

Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: The college was missing all of the requirements from the Gramm-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The institution has been in compliance with previous iterations of GLBA regulations. The Written Information Security Program (WISP) which was required as of June 9, 2023 had missing elements but a Qualified Individual was designated for overseeing and implementing the WISP. Some controls were in place whereas others were not. They did, however, have a WISP as of the deadline but it was missing some required information. Questioned costs: N/A Cause: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Effect: Student personal information could be vulnerable Repeat finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements.Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties

Other Findings in this Audit

  • 369035 2023-002
    Significant Deficiency
  • 369036 2023-002
    Significant Deficiency
  • 369037 2023-002
    Significant Deficiency
  • 369038 2023-002
    Significant Deficiency
  • 369039 2023-003
    Significant Deficiency
  • 369040 2023-003
    Significant Deficiency
  • 369041 2023-003
    Significant Deficiency
  • 369042 2023-003
    Significant Deficiency
  • 369043 2023-004
    Significant Deficiency
  • 369044 2023-004
    Significant Deficiency
  • 369045 2023-004
    Significant Deficiency
  • 369046 2023-004
    Significant Deficiency
  • 369047 2023-005
    Significant Deficiency
  • 369048 2023-005
    Significant Deficiency
  • 369049 2023-005
    Significant Deficiency
  • 369050 2023-005
    Significant Deficiency
  • 945477 2023-002
    Significant Deficiency
  • 945478 2023-002
    Significant Deficiency
  • 945479 2023-002
    Significant Deficiency
  • 945480 2023-002
    Significant Deficiency
  • 945481 2023-003
    Significant Deficiency
  • 945482 2023-003
    Significant Deficiency
  • 945483 2023-003
    Significant Deficiency
  • 945484 2023-003
    Significant Deficiency
  • 945485 2023-004
    Significant Deficiency
  • 945486 2023-004
    Significant Deficiency
  • 945487 2023-004
    Significant Deficiency
  • 945488 2023-004
    Significant Deficiency
  • 945489 2023-005
    Significant Deficiency
  • 945490 2023-005
    Significant Deficiency
  • 945492 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $4.37M
84.268 Federal Direct Student Loans $3.47M
84.042 Trio_student Support Services $318,567
84.031 Higher Education_institutional Aid $277,857
84.007 Federal Supplemental Educational Opportunity Grants $161,181
93.558 Temporary Assistance for Needy Families $97,341
84.033 Federal Work-Study Program $87,252
93.575 Child Care and Development Block Grant $71,505
84.048 Career and Technical Education -- Basic Grants to States $5,244