Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with all the requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.