Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033
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 implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews.
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 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.