Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants
84.033 – Federal Work Study Program
84.038 – Federal Perkins Loans
84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
84.379 – Teacher Education Assistance for College and Higher Education Grants
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 to June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: There were a few missing items from the Written Information Security Program.
Questioned Costs: N/A
Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP.
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.
Effect: The student personal information could be vulnerable.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.