06 / QUESTIONS
Straight answers.
Does my firm really need a written security plan?
If you are paid to prepare tax returns, very likely yes. The FTC Safeguards Rule names tax preparation firms as financial institutions, and requires them to keep a written information security program. The IRS says the same in its guidance for tax professionals, and the PTIN application (Form W-12, line 11) asks every preparer to confirm they know about the requirement.
Sources: 16 CFR 314.1(b) and 314.2; FTC Safeguards Rule guide; Form W-12, line 11.
The IRS has a free template. Why pay for this?
You can absolutely use it. IRS Publication 5708 is a good starting point, and we build from it. What most small firms don't have is the time to fill it in for how their own office actually works: who has access to what, which software and vendors hold client data, how backups are handled, and what happens if a laptop is stolen. That's the part we do for you.
Source: IRS Publication 5708.
Is a written plan enough to be compliant?
No. The plan is required, but so is following it. The rule also calls for safeguards such as multi-factor authentication, encryption of client data, staff training, vendor oversight, and regular review. Your plan describes how your firm does those things. If some of them aren't in place yet, we'll point that out plainly, and the optional Safeguards check can confirm what's actually turned on.
Source: 16 CFR 314.4.
We're a small office. Do all the requirements apply to us?
Firms that keep customer information on fewer than 5,000 consumers are exempt from a few parts of the rule: the written risk assessment, continuous monitoring or annual penetration testing, the written incident response plan, and the annual written report to leadership. You still need the written security program itself. We'll note which exemptions apply to your firm, and we still recommend a short written incident plan because the IRS asks preparers to report data theft promptly.
Sources: 16 CFR 314.6; IRS Publication 4557.
What happens if client data is stolen?
The IRS asks tax professionals to report client data theft to their local IRS Stakeholder Liaison right away. Separately, if a breach involves unencrypted information of 500 or more consumers, the FTC rule requires you to notify the FTC no later than 30 days after discovery. Your plan will include who to call and in what order.
Sources: IRS Publication 4557; 16 CFR 314.4(j).
What do you need from us?
About 15 minutes to answer a questionnaire about your office: staff, devices, software, vendors, backups, and how you handle client files. We never ask for client tax data or anyone's Social Security number.
Is this legal advice? Do you guarantee compliance?
No and no. Central CTO is a technology advisory firm, not a law firm. The plan is a working document your firm adopts and follows. We don't guarantee compliance with any law or regulation, or that a plan will prevent a breach. If you have legal questions about your obligations, talk to your attorney.
Do we have to replace our IT provider?
No. If you have an IT provider, we'll document what they handle and include them in the plan. Central CTO doesn't sell hardware, software, or managed services.
Not legal advice. Central CTO provides technology advisory services and is not a law firm. Information on this page is general and is provided for convenience, with links to official sources. It is not legal, tax, or compliance advice. A written security plan doesn't guarantee compliance with any law or regulation, and doesn't guarantee that a security incident won't happen. Your firm is responsible for adopting, following, and maintaining its plan. For questions about your legal obligations, consult an attorney.