Finding 947479 (2023-003)

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Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-28
Audit: 292694
Organization: William Jessup University (CA)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University is not fully compliant with the updated requirements of the Gramm-Leach-Bliley Act (GLBA).
  • Impacted Requirements: Lack of multi-factor authentication, insufficient vendor management policies, and no annual written report to the board.
  • Recommended Follow-Up: Formalize and document processes to ensure compliance with GLBA requirements.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not: - implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA. Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated 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 formalize and document processes to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Categories

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Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.39M
84.063 Federal Pell Grant Program $1.97M
84.033 Federal Work-Study Program $157,136
84.007 Federal Supplemental Educational Opportunity Grants $96,780
20.111 Aircraft Pilots Workforce Development Grant Program $75,133
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $37,588
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $20,109