Finding 968915 (2023-001)

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: October 1, 2022 through September 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 (WISP) 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 three missing items from the Written Information Security Program. We did not identify procedures in place to securely dispose sensitive information. Standards should include a two-year retention period and a requirement that the institution periodically reviews its data retention period. We also did not identify in the WISP the institution's continuous monitoring capabilities and control testing. If continuous monitoring is not in place at the institution, then the institution should include within the written information security program, its processes to perform an annual penetration test and semi-annual vulnerability assessments. Lastly, we did not identify that the WISP includes the institution's continuous monitoring capabilities and control testing. If continuous monitoring is not in place at the institution, then the institution should include within the written information security program, its processes to perform an annual penetration test and semi-annual vulnerability assessments. Questioned costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were three elements 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: Student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.