Finding 963075 (2023-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-27

AI Summary

  • Core Issue: The College is not complying with the Gramm-Leach-Bliley Act (GLBA) due to missing policies and procedures.
  • Impacted Requirements: Key safeguards like data inventory, multi-factor authentication, and risk management documentation are lacking.
  • Recommended Follow-Up: Update IT policies and procedures to align with GLBA guidelines and ensure regular monitoring of safeguards.

Finding Text

Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Act requires: • The information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution) that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)). • The institution design and implement safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). 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). The minimum safeguards that the written information security program must address are summarized as follows: o Conduct a periodic inventory of data, noting where it's collected, stored, or transmitted. o Assess apps developed by the institution. o Implement multi-factor authentication (MFA) for anyone accessing customer information on the institution's system. • The institution must regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During testing we noted the following exceptions: • Safeguards were not clearly linked in their policy. o The College did not document that it conducts a periodic inventory of data, noting where it’s collected, stored, or transmitted. o There was no evidence indicating a discussion to standardize the use of MFA for end users. • The College does not have a written risk management section of their information technology policies. • There was no written policy regarding program development and software practices in relation to sensitive information. • The College does not have a written policy that identifies continuous monitoring or control testing that takes place periodically. Context: We tested the requirements of GLBA by reviewing College policy and procedures. Questioned costs: None. Cause: The College did not have policies or procedures indicating their compliance with certain aspects of GLBA. Effect: The College did not comply with GLBA requirements. Repeat Finding: No Recommendation: We recommend the College update their IT policies and procedures to follow the guidelines outlined by the GLBA. Views of responsible officials and management’s response: The College agrees with the finding.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 386628 2023-001
    Significant Deficiency
  • 386629 2023-002
    Significant Deficiency Repeat
  • 386630 2023-002
    Significant Deficiency Repeat
  • 386631 2023-003
    Significant Deficiency
  • 386632 2023-003
    Significant Deficiency
  • 386633 2023-003
    Significant Deficiency
  • 386634 2023-003
    Significant Deficiency
  • 386635 2023-003
    Significant Deficiency
  • 386636 2023-004
    Significant Deficiency
  • 963070 2023-001
    Significant Deficiency
  • 963071 2023-002
    Significant Deficiency Repeat
  • 963072 2023-002
    Significant Deficiency Repeat
  • 963073 2023-003
    Significant Deficiency
  • 963074 2023-003
    Significant Deficiency
  • 963076 2023-003
    Significant Deficiency
  • 963077 2023-003
    Significant Deficiency
  • 963078 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Loans $4.87M
84.063 Federal Pell Grant Program $1.69M
84.038 Federal Perkins Loans $1.21M
84.033 Federal Work-Study Program $230,509
84.007 Federal Supplemental Educational Opportunity Grants $223,867
47.049 Nsf: Leaps Malmskog $122,091
47.049 Nsf: Leaps Light $104,092
47.070 Nsf: Burge Cise $61,731
47.050 Nsf: Grtaz Mercury Oxid Pat $57,892
47.078 Nsf: Ici-Hot in West Antarctica $49,118
47.050 Nsf: Firp - Gratz Course $46,463
47.050 Nsf: Testing Models-Sibumas $37,177
43.001 Nasa: Stsci: Radiation Field of Li(n)ers: the Milky Way As An Extragalactic System $23,194
47.074 Nsf: Barnes Career $21,418
93.575 Child Care Operations Stabilizations Grant $19,660
47.078 Nsf: Testing the Linchpin Wais $18,837
47.076 Nsf: Progress; Barnes Iuse Mentoring $15,524
43.001 Nasa: Stsci: the Lmc's Galactic Wind Through the Eyes of Ullyses $15,450
47.050 Nsf: Gevedon Rodingites $13,648
47.050 Nsf: Schanz Bedrock Rivers $11,943
47.049 Nsf: Sub: Moran Geometric Top $6,815
43.001 Nasa: Stsci: Testing the Limits of Mass Transfer Stability with A Post-Mass_transfer Binary in M67 $4,961
93.575 Child Care Workforce Sustainability Grant $3,566
47.050 Nsf: Collab Res Recruit Woman Geoscience $717
47.074 Nsf: Barnes Soil & Wildfire $363
43.001 Nasa: Blue Lurkers: Low-Mass Blue Stragglers & Stability of Mass Transfer $269
47.049 Nsf: Leaps2; Part Suppo Malmskog $-784