Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance
Other Matter
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 College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: The College has not updated its written information security program to align with the revised regulations, sufficiently documented its security risk assessment and safeguards, including general threats, or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not implemented sufficient vendor management policies and reviews and documented the work performed, or provided a written, annual report to the board
Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The College 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 College 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.