Written Information Security Plans

In the contemporary digital landscape, safeguarding sensitive data is imperative for CPA firms, as well as other financial firms, who are entrusted with confidential financial information. 

 

The Gramm-Leach-Bliley Act (GLBA), passed in 1999, requires financial institutions – companies that offer consumers financial products or services like loans, financial or investment advice, or insurance – to explain their information-sharing practices to their customers and to safeguard sensitive data.

 

While the GLBA was passed in 1999, the Internal Revenue Service (IRS) has recently taken this one step further and requires paid tax preparers to certify, as part of the PTIN renewal process, that they have a Written Information Security Plan (WISP).  This IRS requirement became mandatory starting in the second quarter of 2023.

 

This directive transcends mere procedural formality; rather, it constitutes a measure in building client trust and developing firms’ digital resiliency, thereby upholding firms’ reputations.

 

The Benefit of Practitioner Involvement in WISP Development

 

An understanding of IRS Guidelines: Given the intricate and perpetually evolving nature of IRS regulations, engaging a practitioner specializing in these guidelines becomes indispensable.  Such professionals ensure not only the compliance of your WISP but also its capacity to anticipate forthcoming alterations.  Practitioners’ ability to navigate the complexities of cybersecurity requirements transforms an otherwise daunting task into a manageable undertaking.

 

Tailored Security Strategies: Recognizing the unique attributes of your firm and its distinct security needs, practitioners are adept at tailoring your WISP to address your company’s specific vulnerabilities.  This bespoke approach results in a robust defense against potential breaches and acknowledges the ineffectiveness of a one-size-fits-all mentality in the nuanced realm of financial information security.

 

Advanced Risk Assessment and Management: Professionals in this field bring forth a repertoire of tools and methodologies to identify and mitigate risks.  Leveraging their experience, they possess the acumen to foresee potential risks that might elude conventional scrutiny, and to implement proactive measures to forestall data breaches.

 

Employee Training and Awareness: An integral facet of a WISP involves training personnel to discern and respond effectively to security threats.  Practitioners are proficient in developing and delivering training programs that resonate with your team, cultivating a culture of heightened security and risk awareness.

 

Efficient Resource Allocation: Internal development of a WISP can prove resource-intensive.  Collaboration with a practitioner allows your firm to concentrate on core business activities while ensuring the efficient and effective development of the WISP.

 

Ongoing Support and Updates: Given the dynamic nature of the digital landscape, the WISP must function as a living document.  Practitioners offer continuous support and updates, ensuring that your firm remains ahead of emerging threats and remains in compliance with evolving regulatory standards.

 

Augmented Client Confidence: By showcasing your commitment to data security through a professionally crafted WISP, your firm stands to significantly enhance client trust and loyalty.  This demonstration underscores the gravity with which you value and protect their sensitive information.

 

Conclusion

 

While the prospect of developing a WISP in accordance with IRS guidelines may initially appear formidable, the collaborative engagement of a subject-matter practitioner serves to transform this challenge into a strategic opportunity.  Such an investment signifies a commitment to fortifying your firm's security, compliance, and future resilience.  We strongly advocate for the consideration of the substantial benefits derived from practitioner guidance in this critical endeavor.

Thank You!


Paul Kriebel

Managing Director, Cybersecurity

paul.kriebel@cradvise.com




Maxwell Maszle

Manager, Advisory

max.maszle@cradvise.com

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