your tools for a cybersecurity compliance check-up.
by donny shimamoto
cybersecurity for accountants
in august 2019, the irs published its list of “security six” steps to protect taxpayer information.[i] these described the six “basic protections” that it expects tax prepares to utilize.
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these include:
- anti-virus software – to scan computers for malicious software, the irs also recommended ensuring that you keep these up to date since threats evolve daily.
- firewalls – to protect both computers and networks from malicious or unnecessary web traffic.
- two-factor authentication (2fa) – also known as multi-factor authentication (mfa). this provides an extra layer of protection beyond a password, usually in the form of an additional security code that is sent to a user’s personal device or email.
- backup software or services – this doesn’t prevent a data breach so much as helps in the event of a ransomware attack so that you can still get to your files without paying the ransom.
- drive encryption – this protects the data on the device itself, especially in the event that the device is lost or stolen.
- virtual private network (vpn) – since many tax firms’ employees must occasionally connect to unknown networks or work from home, the irs recommends that firms enable them to connect to the office using a vpn to provide a secure, encrypted tunnel to transmit data between a remote user over the internet and the firm’s office network.
the key word above, though, is “basic.” these are all pretty basic protections, and most of the firms that i’ve talked with already have these in place. so, if you read the above and your response was, “yep, i’m doing all this,” don’t get a false sense of security.
the better guidance to look at to understand the irs’s expectation is irs publication 4557: safeguarding taxpayer data. you can find this at https://www.irs.gov/pub/irs-pdf/p4557.pdf. this publication provides a much more comprehensive picture of what the irs expects and it aligns much better with what i would expect to see in place as an it auditor. our team’s analysis of this publication identified approximately 80 individual compliance requirements.
want to see if you have addressed all the areas in publication 4557? take the cybersecurity compliance self-assessment for tax practitioners
the original ftc safeguards rule was put in place with the gramm-leach-bliley act (glba). one of the misleading aspects of this rule is that from a quick read it says it is applicable to “financial institutions”, which makes it sound like it is only applicable to banks and insurance companies. however, there are two activities that are included in the description of “financial institution” covered activities that end up pulling tax and accounting firms into this definition:
- businesses printing and selling checks on behalf of customers or wiring money
- income tax return preparers
the second one makes it very clear that tax preparers are included in this definition, and many firms that also do bookkeeping for their clients may be wiring money for them to process payments, so it may not just be your tax preparers that are subject to this but your outsourced accounting team too.
according to accounting firm cliftonlarsonallen[ii], organizations classified as “financial institutions” must implement the following security practices and then review, and periodically update formal policies and procedures, including:
- designating a qualified individual to oversee the information security program
- developing, implementing, and maintaining a written information security program
- completing a written information security risk assessment
- designing and implementing safeguards to control the risks you identify through risk assessment
- establishing continuous monitoring of information systems
- engaging third-party penetration testing and vulnerability assessments
- conducting security awareness training
- assessing third-party service providers periodically
- establishing a written information incident response program
- providing the board or respective group with a written report periodically and at least annually from the qualified individual
specific controls requirements regarding the implementation of safeguards include:
- implementing and reviewing access control
- inventorying the systems that handle customer information
- identifying and managing data based on risk
- encrypting data both in transit and at rest
- securing software development practices
- requiring the use of multifactor authentication for those accessing the information systems
- establishing secure procedures for disposing of data
- developing change management procedures
- implementing logging and monitoring procedures
these requirements were originally slated to go into effect on december 9, 2022, but the ftc has since delayed the effective date of the updated rule until june 9, 2023. however, this doesn’t mean that you should delay addressing these changes. note that a lot of the above controls and cybersecurity program elements are not simple things to just put in place. they require formalizing cybersecurity activities by writing policies and procedures and also documenting the execution of control activities.
these are also not things that you can just outsource to your it service provider—many of these require coordination and oversight of an it service provider, and the ftc specifically says this must be done by a “qualified individual”—someone that is familiar with the requirements and understands the safeguards that are put in place.
[i] irs tax tip 2019-117, https://www.irs.gov/newsroom/tax-pros-follow-the-security-six-steps-to-help-protect-taxpayer-data, august 27, 2019
[ii] https://www.claconnect.com/en/resources/articles/2022/ftc-glba-safeguards-rule-compliance, april 27, 2022