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Accounting & Tax Firms · FTC Safeguards Rule · IRS Pub 4557

IT and security for
CPA and tax firms

Accounting and tax practices hold some of the most sensitive data a small business can keep — Social Security numbers, bank account details, income records, and years of prior returns. Federal rules treat tax preparers as financial institutions, which makes protecting that data a legal obligation, not just good practice. West Computers builds and runs the security program your firm needs and keeps your systems up when filing deadlines hit.

// What Your Firm Needs
Written information security program (WISP)
Designated Qualified Individual
Written risk assessment
Multi-factor authentication everywhere client data lives
Encryption at rest & in transit
Monitoring or periodic security testing
Incident response plan
Vendor & service provider oversight
Staff security awareness training
Tested backups before tax season
Why It Applies to Your Firm

Tax and accounting firms are “financial institutions.”

The Gramm-Leach-Bliley Act gives the Federal Trade Commission authority to set data-protection rules for financial institutions under its jurisdiction. The IRS states plainly that this definition includes professional tax preparers, and its Security Summit guidance says tax and accounting professionals are covered regardless of size. The rule that applies is the FTC Safeguards Rule (16 CFR Part 314).

The rule requires a written information security program — what the IRS calls a WISP — appropriate to your firm’s size, complexity, and the sensitivity of the client data you hold. The amended rule’s specific technical requirements, including MFA and encryption, took effect in June 2023, and since May 2024 covered firms must notify the FTC within 30 days of discovering a security event that involves the unencrypted information of 500 or more consumers.

The IRS reinforces this every year: when paid preparers apply for or renew a PTIN, Form W-12 asks them to acknowledge that they are required by law to create and maintain a written information security plan.

// The Core Guidance
FTC Safeguards Rule (16 CFR 314)THE RULE
IRS Publication 4557SAFEGUARDS
IRS Publication 5708WISP GUIDE
Form W-12 (PTIN)ACKNOWLEDGED
FTC breach notification (500+)30 DAYS
What We Cover

The controls a CPA or tax practice actually needs.

Each of these maps to a requirement in the Safeguards Rule or to the practices the IRS recommends in Publication 4557. We implement them, document them, and keep them running.

📋

Written Information Security Program

We build your WISP using the structure in IRS Publication 5708 and the elements in the Safeguards Rule: a Qualified Individual, a written risk assessment, the safeguards you use, how they’re monitored and tested, vendor oversight, and how the program is updated as your firm changes.

🔐

Multi-Factor Authentication

The Safeguards Rule requires MFA for anyone accessing customer information on your systems. We enforce it across Microsoft 365, remote access, tax software portals, and client file-sharing — with phishing-resistant options where they fit.

🗝️

Encryption

Client information must be encrypted in transit and at rest. We encrypt laptops and workstations, servers, and backups, and set up secure ways to exchange returns and documents with clients instead of plain email attachments.

📆

Tax-Season Uptime

Your busiest weeks are the worst time for an outage. We schedule patching and hardware refreshes before the season, monitor around the clock, test backups and restores in advance, and keep a recovery plan ready so a failed machine doesn’t stop your filing work.

🛡️

Monitoring & Threat Response

The rule requires continuous monitoring or periodic penetration testing and vulnerability assessments. Our 24/7 SOC and MXDR service watches endpoints, email, and cloud accounts and responds to threats as they happen.

🎣

Phishing & Account Takeover Defense

The IRS warns that criminals target tax professionals to steal client data and file fraudulent returns. Email security, user coaching, and Zero Trust application control help stop the phishing and malware that lead to account takeover.

👤

Access Control & Offboarding

Least-privilege access to client files and tax software, periodic access reviews, and fast offboarding when seasonal staff leave — so former employees don’t keep access to client data.

🚨

Incident Response Plan

A written plan for detecting, containing, and recovering from a security event — including who to call, how to document it, and how to meet notification obligations to the FTC and your IRS stakeholder liaison.

🤝

Vendor Oversight & Training

Help reviewing the security of your tax software, cloud storage, and other providers, plus ongoing security awareness training for partners, staff, and seasonal hires.

How West Computers Helps

We build the program. You serve your clients.

01

Free Security Assessment

We review your current environment against the Safeguards Rule and IRS Publication 4557 — MFA coverage, encryption, backups, access, email security, and documentation — and tell you plainly where the gaps are.

02

Written Plan & Risk Assessment

We document your WISP and risk assessment so they reflect how your firm actually works, not a generic template that sits in a drawer.

03

Implement the Controls

MFA, encryption, monitoring, backups, email security, and access controls are deployed and configured, with evidence kept for each one.

04

Run It Year-Round

Ongoing monitoring, patching, access reviews, and an annual program review — with a pre-season readiness check before every filing season.

FAQ

Questions from CPA and tax firms.

Does the FTC Safeguards Rule apply to my tax or accounting firm?
If you prepare tax returns or otherwise provide financial services to consumers, very likely yes. The IRS states that the FTC’s definition of financial institution includes professional tax preparers, and IRS Publication 5708 says tax and accounting professionals are covered regardless of size. If you’re unsure how it applies to your practice, check with your legal counsel; we can help you meet the technical requirements.
What is a WISP?
A WISP is a written information security plan — the documented information security program the Safeguards Rule requires. It names a Qualified Individual, records your risk assessment, describes the safeguards you use, and explains how you monitor, test, and update them. IRS Publication 5708 walks through how to create one for a tax and accounting practice.
Is MFA required for a small firm?
Yes. The Safeguards Rule requires multi-factor authentication for anyone accessing customer information on your information systems, and IRS Publication 4557 notes this applies to all companies regardless of size. Firms that maintain information on fewer than 5,000 consumers are exempt from a few requirements, such as the written incident response plan and the annual report to leadership, but not from MFA, encryption, or the written program.
What does IRS Publication 4557 cover?
Publication 4557, Safeguarding Taxpayer Data, is the IRS guide to basic security steps for tax professionals, recognizing and reporting data theft, responding to and recovering from a data loss, and complying with the FTC Safeguards Rule.
How do you keep us running during tax season?
We front-load the risky work: patching, hardware replacements, and backup restore tests happen before the season starts. During the season, 24/7 monitoring and fast remote support keep small problems from turning into downtime, and a tested recovery plan covers a failed machine or a security incident.
Can West Computers serve as our Qualified Individual?
Yes. Through our Virtual CISO service, West Computers can serve as or support your Qualified Individual. Under the rule, your firm still designates a senior member of your own team to oversee that work.
Official Sources

Read the guidance yourself.

This page is a general overview, not legal advice. These are the primary sources we work from.

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