Finding 950832 (2023-005)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-07
Audit: 293985
Organization: Bethany College (KS)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: The College did not update its written Information Security Program to meet the FTC Safeguards Rule by the required deadlines.
  • Impacted Requirements: Key safeguards for data protection, including risk assessments and documentation of security measures, were not fully implemented.
  • Recommended Follow-Up: The College should formalize its Information Security Program immediately to ensure compliance and mitigate cybersecurity risks.

Finding Text

Finding 2023-005 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063, 84.033, 84.038 U.S. Department Of Education Student Financial Aid Cluster - Special Tests and Provisions Criteria: The Federal Trade Commission (FTC) issued the FTC Safeguards Rule on December 9, 2021 and gave notice to entities that are required to follow the Gramm-Leach-Bliley Act (GLBA) that each entity would be required to be in compliance with the revised requirements no later than June 9, 2023. The FTC Safeguards Rule expanded the requirements for the written information security program required to be established by the College. The requirements for the written information security program noted at 16 CFR 314.4 require that the College designate a Qualified Individual responsible for overseeing and implementing the College’s information security program, be based on a risk assessment that identifies reasonably foreseeable internal and external risks and establishes safeguards to address those risks, and requires that the following 8 safeguards be documented: • Implement and periodically review access controls • Conduct a periodic inventory of data, noting where it is collected, stored, or transmitted • Encrypt customer information on the institution’s system and when it’s in transit. • Assess apps developed by the institution • Implement multi-factor authentication for anyone accessing customer information on the institution’s system • Dispose of customer information securely • Anticipate and evaluate changes to the information system or network • Maintain a log of authorized users’ activity and keep an eye out for unauthorized access In addition, the College is responsible for regularly testing and monitoring the effectiveness of the safeguards it has implemented and establishing how it will complete the monitoring and testing in the written Information Security Program. The College is also responsible for documenting in the written Information Security Program how it will oversee its information system service providers and shall also provide for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; the results of the required risk assessments; any material changes to the College’s operations or business arrangements; or any other circumstances that it knows or has reason to know may have a material impact on the College’s information security program. Condition: The College took steps toward meeting the requirements of the FTC Safeguards Rule, including conducting an evaluation of its current compliance and implementing many of the new requirements, but the College failed to update its written Information Security Program to incorporate all of the changes required by the FTC Safeguards Rule by the due date of June 9, 2023 or June 30, 2023. Context: The College took steps to implement the requirements and established draft policies and procedures to meet the requirements of the FTC Safeguards Rule; however, the College did not formalize the policies and procedures or update its written Information Security Program. Effect: The failure to meet the requirements of the FTC Safeguards Rule including establishing formal documentation of the written Information Security Program could make the College vulnerable to cyber security and student data protection risks. Questioned Costs: None noted. Cause: Given the size of the College’s IT department, the College focused on implementing as many of the safeguards as possible first to meet the FTC Safeguards Rule and did not prioritize a formal update of its written Information Security Program to meet the requirements of the FTC Safeguards Rule. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The College should immediately formalize its written Information Security Program to meet the FTC Safeguards Rule. Views Of Responsible Officials (Unaudited): The College concurs with the finding and will formalize its written Information Security Program. Completion Date: Spring 2024 Contact Person: Joshua Bieber, Director of Information Technology

Categories

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 374382 2023-003
    Significant Deficiency Repeat
  • 374383 2023-003
    Significant Deficiency Repeat
  • 374384 2023-003
    Significant Deficiency Repeat
  • 374385 2023-003
    Significant Deficiency Repeat
  • 374386 2023-003
    Significant Deficiency Repeat
  • 374387 2023-003
    Significant Deficiency Repeat
  • 374388 2023-004
    Significant Deficiency
  • 374389 2023-005
    Significant Deficiency
  • 374390 2023-005
    Significant Deficiency
  • 374391 2023-005
    Significant Deficiency
  • 374392 2023-005
    Significant Deficiency
  • 374393 2023-005
    Significant Deficiency
  • 374394 2023-005
    Significant Deficiency
  • 950824 2023-003
    Significant Deficiency Repeat
  • 950825 2023-003
    Significant Deficiency Repeat
  • 950826 2023-003
    Significant Deficiency Repeat
  • 950827 2023-003
    Significant Deficiency Repeat
  • 950828 2023-003
    Significant Deficiency Repeat
  • 950829 2023-003
    Significant Deficiency Repeat
  • 950830 2023-004
    Significant Deficiency
  • 950831 2023-005
    Significant Deficiency
  • 950833 2023-005
    Significant Deficiency
  • 950834 2023-005
    Significant Deficiency
  • 950835 2023-005
    Significant Deficiency
  • 950836 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $19.99M
84.268 Federal Direct Student Loans $5.41M
84.063 Federal Pell Grant Program $1.65M
84.038 Federal Perkins Loan Program $795,039
21.027 Coronavirus State and Local Fiscal Recovery Funds $418,974
84.007 Federal Supplemental Educational Opportunity Grants $135,583
84.033 Federal Work-Study Program $80,120
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $18,860