Finding 959222 (2023-004)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-21
Audit: 296385
Organization: San Diego Christian College (CA)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: San Diego Christian College is not fully compliant with the updated requirements of the Gramm-Leach-Bliley Act (GLBA).
  • Impacted Requirements: Key areas lacking include documentation of security programs, risk assessments, multi-factor authentication, continuous monitoring, incident response plans, and employee training.
  • Recommended Follow-Up: Allocate more resources to meet GLBA requirements and enhance security measures to protect student information.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program. Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: San Diego Christian 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 commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Categories

Subrecipient Monitoring Material Weakness

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.81M
84.063 Federal Pell Grant Program $734,811
84.038 Federal Perkins Loan Program $268,472
84.007 Federal Supplemental Educational Opportunity Grants $48,876
84.007 Covid-19 Federal Supplemental Educational Opportunity Grants $34,188
84.033 Federal Work-Study Program $736