Finding Text
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Financial Aid Year
Condition: Word of Life did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Word of Life has not fully implemented multi-factor authentication on systems containing personally identifiable information (PII) or sufficient vendor management policies and reviews. Additionally, Word of Life has not provided a written, annual report to the board.
Cause: Word of Life has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: Word of Life 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 Word of Life 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.