Finding 961866 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-27
Audit: 298271
Organization: Muskingum University (OH)
Auditor: Schneider Downs

AI Summary

  • Core Issue: The University lacks a formalized information security program, which is essential for compliance with GLBA requirements.
  • Impacted Requirements: Failure to implement regular testing and monitoring of safeguards as mandated by 16 CFR 314 f(d) and to establish necessary policies under 16 CFR 314.4(e)(1).
  • Recommended Follow-Up: Develop and document a comprehensive information security program and initiate regular vulnerability assessments and penetration testing to ensure compliance and safeguard sensitive data.

Finding Text

The Gramm-Leach-Bliley Act (Public Law 106-102) (“GLBA”) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (“16 CFR 314”). Under 16 CFR 314 f(d), the University should regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. Under 16 CFR 314.4 (e)(1), the University should implement policies and procedures to ensure that personnel are able to enact the information security program. The University does not have a formalized information security program to document the policies and procedures relevant with respect to requirements under 16 CFR 314.4(e)(1). The University does not regularly conduct vulnerability assessments, penetration testing, or other procedures to monitor its implemented safeguards as required under 16 CFR 314 f(d). Without a formalized policy in place surrounding its information security program, the University is not able to fully determine its compliance under the GLBA requirements, including the requirement to regularly test or otherwise monitor the effectiveness of its safeguards. Lack of regular testing or monitoring the effectiveness of the safeguards established could lead to the lack of timely identification of ineffectiveness or missing safeguards that could help detect or prevent breaches or other similar issues.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 385424 2023-001
    Significant Deficiency
  • 385425 2023-001
    Significant Deficiency
  • 385426 2023-001
    Significant Deficiency
  • 385427 2023-001
    Significant Deficiency
  • 385428 2023-001
    Significant Deficiency
  • 385429 2023-001
    Significant Deficiency
  • 961867 2023-001
    Significant Deficiency
  • 961868 2023-001
    Significant Deficiency
  • 961869 2023-001
    Significant Deficiency
  • 961870 2023-001
    Significant Deficiency
  • 961871 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $28.00M
84.268 Federal Direct Student Loans $14.65M
84.063 Federal Pell Grant Program $3.05M
84.038 Federal Perkins Loan Program $519,241
84.031 Higher Education_institutional Aid $331,894
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $185,301
84.425E Education Stabilization Fund $181,239
17.280 Workforce Investment Act (wia) Dislocated Worker National Reserve Demonstration Grants $157,424
84.033 Federal Work-Study Program $149,638
84.007 Federal Supplemental Educational Opportunity Grants $142,836
21.019 Coronavirus Relief Fund $38,210