Does your Houston tax office need a written security plan?

Short answer: yes. Here is what the rules say, in plain English, with a checklist you can print.

I'm Robert Jacal. I set up and secure computers for Houston offices, and I do the work myself. Here is what the rules say about written security plans, straight from the sources.

The short answer

Yes. The IRS puts it plainly in Tax Tip 2024-93:

"Tax professionals are required by law to have a WISP in place to protect customer data."

WISP stands for written information security plan. The rule behind it is the FTC's Safeguards Rule, under the Gramm-Leach-Bliley Act, and it counts tax preparation firms as financial institutions.

You may have already said you know

When you renew your PTIN, Form W-12 line 11 asks you to check Yes or No to this:

"I am aware that paid tax return preparers are required by law to create and maintain a written information security plan that provides data and system security protections for all taxpayer information."

That box is an awareness statement. It doesn't ask you to prove you have a plan. But once you check it, nobody can say you weren't told.

What the rule asks for

The Safeguards Rule is 16 CFR Part 314. In plain words, among other things, it asks you to:

If your office is small

Section 314.6 gives some relief to offices that keep information on fewer than 5,000 people. They don't have to do the written risk assessment, the continuous monitoring (or the yearly penetration test and twice-yearly vulnerability scans), the written incident response plan, or the yearly written report to the owner or board.

Everything else still applies, including the person in charge, looking at your risks, encryption, multi-factor login, training, watching your vendors and the FTC breach notice. And the IRS doesn't skip small offices. It says a plan works best when "tailored to the size, scope, complexity and sensitivity of the customer data it handles." A two-person office gets a short plan. It still gets a plan.

Free help from the IRS

You don't have to buy anything to start. The IRS gives you a fill-in template in Publication 5708, and the security steps behind it in Publication 4557.

Checklist: is your office covered?

Print this page, or save it as a PDF from your browser, and check off what you have.

Next step

If you'd like a second pair of eyes, I do a free 30-minute checkup. I'll look at your setup and tell you exactly what's missing.

Email me for a free checkup

Not legal advice. This is a plain-English summary of the IRS and FTC sources linked above; for your specific situation, read the source or ask your attorney.