Finding 960726 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-25

AI Summary

  • Core Issue: The College is not fully compliant with the updated requirements of the Gramm-Leach-Bliley Act (GLBA), particularly in documenting security assessments and implementing necessary safeguards.
  • Impacted Requirements: Key areas of concern include lack of multi-factor authentication, insufficient vendor management, and absence of an incident response plan, which could expose student information to security risks.
  • Recommended Follow-Up: Allocate more resources to meet GLBA requirements and enhance compliance efforts, as management agrees with the findings and has a corrective action plan in place.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 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 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 sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 384283 2023-001
    Significant Deficiency
  • 384284 2023-001
    Significant Deficiency
  • 384285 2023-001
    Significant Deficiency
  • 384286 2023-001
    Significant Deficiency
  • 384287 2023-001
    Significant Deficiency
  • 384288 2023-001
    Significant Deficiency
  • 384289 2023-002
    -
  • 960725 2023-001
    Significant Deficiency
  • 960727 2023-001
    Significant Deficiency
  • 960728 2023-001
    Significant Deficiency
  • 960729 2023-001
    Significant Deficiency
  • 960730 2023-001
    Significant Deficiency
  • 960731 2023-002
    -

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $808,701
84.063 Federal Pell Grant Program $373,013
84.038 Federal Perkins Loan Program $161,569
84.033 Federal Work-Study Program $100,559
84.007 Federal Supplemental Educational Opportunity Grants $58,968
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $20,746