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Written Information Security Plan (WISP)

For Bluebonnet Tax Service (sample firm)

Katy, TX

This document is for general distribution and is available to all employees.

This document is available to clients by request and with the consent of the Firm's Data Security Coordinator.

Effective November 9, 2026. Last reviewed November 9, 2026. Next review due by November 9, 2027.

I. Objective

Our objective, in the development and implementation of this comprehensive Written Information Security Plan (WISP), is to create effective administrative, technical, and physical safeguards for the protection of the Personally Identifiable Information (PII) retained by Bluebonnet Tax Service (sample firm) (hereinafter known as the Firm). This WISP is to comply with obligations under the Gramm-Leach-Bliley Act and the Federal Trade Commission Financial Privacy and Safeguards Rules (16 CFR Part 314) to which the Firm is subject as a tax and accounting practice. The WISP sets forth our procedure for evaluating our electronic and physical methods of accessing, collecting, storing, using, transmitting, and protecting PII retained by the Firm.

For purposes of this WISP, PII means information containing the first name and last name or first initial and last name of a Taxpayer, Spouse, Dependent, or Legal Guardianship person in combination with any of the following data elements retained by the Firm that relate to Clients, Business Entities, or Firm Employees:

PII shall not include information that is obtained from publicly available sources such as a mailing address or phone directory listing, or from federal, state or local government records lawfully made available to the general public.

II. Purpose

III. Scope

The scope of the WISP related to the Firm shall be limited to the following protocols:

The Firm maintains customer information concerning fewer than 5,000 consumers. Under 16 CFR 314.6, the written risk assessment (314.4(b)(1)), penetration testing and vulnerability assessment schedule (314.4(d)(2)), written incident response plan (314.4(h)) and annual written report (314.4(i)) are not strictly required at this size. The Firm includes them anyway as good practice, and will treat them as required if it reaches that number.

IV. Identified Responsible Officials

Bluebonnet Tax Service (sample firm) has designated Maria Lopez (Owner, EA) to be the Data Security Coordinator (hereinafter the DSC). The DSC is the Firm's Qualified Individual under 16 CFR 314.4(a): the responsible official for the Firm's data security processes, who will implement, supervise, and maintain the WISP. The DSC will be responsible for:

Bluebonnet Tax Service (sample firm) has designated Maria Lopez to be the Public Information Officer (hereinafter the PIO). The PIO is the Firm's designated spokesperson. All outward-facing communications about a security matter are approved by the PIO, including client communications, statements to law enforcement agencies, releases to news media, and information released to business associates, neighboring businesses, and trade associations.

IRS Pub 5708 recommends that, in firms of two or more practitioners, the DSC and PIO be different individuals. Consider assigning the PIO role to a second person.

V. Risk Assessment

This section is the Firm's written risk assessment under 16 CFR 314.4(b). It is re-performed at each annual review and whenever operations change materially.

Information the Firm handles

Criteria used

Likelihood (how probable the threat is for an office like ours) and impact (harm to clients and the Firm if it happens) are each rated Low, Medium, or High. The overall rating is the higher of the two when either is High. Each risk is judged against confidentiality, integrity, and availability of client data. High risks are mitigated within 30 days; Medium risks within 90 days; Low risks may be accepted in writing by the DSC with a reason.

Identified risks and current controls

RiskRatingCurrent controlsDecision
Phishing email leading to stolen passwords or remote takeoverHighStaff training; MFA incomplete (see Attachment G)Mitigate
Remote access takeover of office computers (often nights and weekends)HighRemote tool; MFA and hours limits requiredMitigate
Theft or loss of a laptop, phone, or USB driveMediumEncryption incomplete (see Attachment G)Mitigate
Ransomware or malware destroying dataHighBackups (external); anti-malware; patchingMitigate
Unauthorized physical access to paper files or screensLowLocked storage; clear-desk ruleMitigate
Insider misuse or careless disclosure by staffMediumLeast-privilege access; signed acknowledgments; access removed at separationMitigate
Service provider breach (software, hosting, email, IT)MediumProvider safeguards confirmed in writing; MFA on provider accountsMitigate
Fire, flood, hurricane, or power lossMediumOff-site backup neededMitigate

Monitoring and testing for new risks

VI. Inside the Firm Risk Mitigation

To reduce internal risks to the security, confidentiality, and integrity of any retained electronic, paper, or other records containing PII, the Firm has implemented the following mandatory policies and procedures.

PII Collection and Retention Policy

Personnel Accountability Policy

PII Disclosure Policy

Reportable Event Policy

VII. Outside the Firm Risk Mitigation

Network Protection Policy

User Access Control Policy

Encryption Policy

Electronic Exchange of PII Policy

Wi-Fi Access Policy

Remote Access Policy

The DSC approve all remote access utilities. Remote access uses AnyDesk that encrypts both traffic and authentication, and requires MFA in addition to username and password. Remote access is not available unless the office is staffed and systems are monitored; nights and weekends are high-threat periods for remote takeover.

Connected Devices Policy

Service Provider Oversight Policy

The Firm selects service providers capable of maintaining appropriate safeguards, requires them by contract to maintain those safeguards, and periodically assesses them based on the risk they present (16 CFR 314.4(f)). Current providers with access to client data:

ProviderSafeguards confirmed in writing (date)Next assessment
Drake Tax (tax software)November 9, 2027
Google Workspace (email)November 9, 2027
AnyDesk (remote access)November 9, 2027

Information Security Training Policy

All employees are trained on keeping the Firm's PII private and confidential. The DSC conducts training on paper record handling, electronic record handling, phishing, and Firm security procedures at least annually and before each filing season, and before seasonal staff receive access (16 CFR 314.4(e)). Training is recorded with Attachment D.

Testing and Monitoring

The DSC regularly tests the effectiveness of key controls: confirming MFA is on for every account, checking that backups restore, reviewing user access lists, and reviewing security software alerts, at least every 90 days (16 CFR 314.4(d)(1)).

VIII. Incident Response and Breach Notification Plan

This is the Firm's written incident response plan under 16 CFR 314.4(h).

Area (16 CFR 314.4(h))The Firm's plan
1. GoalsStop the incident, protect clients from identity theft and fraudulent returns, restore operations, and meet every notification deadline.
2. Internal processAnyone who suspects an incident tells the DSC at once. The DSC disconnects affected devices from the network (without powering them off), changes passwords from a clean device, and contacts the tax software vendor and IT support.
3. Roles and decision authorityDSC (Maria Lopez) leads the response and decides on containment. PIO (Maria Lopez) approves all outside communication. Maria Lopez (Owner, EA) approves spending and client notification.
4. CommunicationsNo staff member speaks to clients, media, or other businesses about the incident except through the PIO. Notifications are made as listed below.
5. RemediationThe DSC documents the cause, fixes the weakness (patching, MFA, access removal, rebuilding devices), and confirms the fix before reconnecting systems.
6. DocumentationThe DSC keeps a written log: date and time found, what happened, systems and clients affected, actions taken, and notices sent.
7. ReviewAfter the incident, the DSC reviews this plan and records changes as an addendum.

Who the Firm notifies

Immediate checks after a suspected breach

IX. Annual Report to the Owner

At least once a year the DSC reports in writing to Maria Lopez (Owner, EA) on the overall status of the information security program and the Firm's compliance with the Safeguards Rule, and on material matters such as the risk assessment, risk decisions, service provider arrangements, test results, security events and responses, and recommended changes (16 CFR 314.4(i)).

Report itemNotes
Overall status of the program
Risk assessment changes
Service providers reviewed
Test and monitoring results
Security events and responses
Recommended changes
Signed: Maria LopezTitle: Data Security CoordinatorDate: ____________
Signed: Maria Lopez, Owner, EATitle: Received byDate: ____________

X. Implementation

Effective November 9, 2026, Bluebonnet Tax Service (sample firm) has created this Written Information Security Plan in compliance with the requirements for a written information security program in the Gramm-Leach-Bliley Act and the Federal Trade Commission Financial Privacy and Safeguards Rules, and with regard to the Texas Identity Theft Enforcement and Protection Act (Tex. Bus. & Com. Code chapter 521).

Signed: Maria LopezTitle: Owner, EADate: ____________
Signed: Maria LopezTitle: Data Security CoordinatorDate: ____________

Attachment A: Record Retention Policy

Attachment B: Rules of Behavior and Conduct Safeguarding Client PII

Attachment C: Security Breach Procedures and Notifications

Follow Section VIII. Keep this page with the contact details filled in so they are ready before an incident.

ContactName / phone / link
IRS Stakeholder Liaison (TX)irs.gov: search 'Stakeholder Liaison local contacts'
FTC Safeguards Rule event reportftc.gov (Safeguards Rule security event reporting form)
Texas Attorney General data breach formtexasattorneygeneral.gov (data security breach reports)
Tax software vendor supportDrake Tax
IT support
Insurance carrier
Local police non-emergency
Legal counsel

Attachment D: Employee/Contractor Acknowledgement of Understanding

I, ____________________, do hereby acknowledge that I have been informed of the Written Information Security Plan used by Bluebonnet Tax Service (sample firm). I have undergone training conducted by the Data Security Coordinator, and I have been able to have all questions regarding procedures answered to my satisfaction so that I fully understand the importance of maintaining strict compliance with the purpose and intent of this WISP. I understand that there will be periodic updates and training if these policies and procedures change. I understand that non-compliance with the WISP may result in disciplinary action up to and including termination. I understand the importance of protecting the Personally Identifiable Information of our clients, employees, and contacts, and will diligently monitor my actions, as well as the actions of others, so that Bluebonnet Tax Service (sample firm) is a safe repository for all personally sensitive data necessary for business needs.

Signed: Title: Employee/ContractorDate: ____________
Signed: Title: TitleDate: ____________

Attachment E: Firm Hardware Inventory Containing PII Data

Hardware itemLocationPrincipal userIn-service dateLast inventoried
Desktop computer 1OfficeNovember 9, 2026
Desktop computer 2OfficeNovember 9, 2026
Laptop 1Assigned userNovember 9, 2026
Business phone 1Assigned userNovember 9, 2026
Printer / scanner / copier 1OfficeNovember 9, 2026
Network router / firewallOfficeNovember 9, 2026
Paper file storageLocked cabinet/roomNovember 9, 2026
External backup drive (encrypted)Off-site or lockedDSCNovember 9, 2026

Attachment F: Firm Employees Authorized to Access PII

NameRoleAccess levelDate access grantedDate access terminated
Maria LopezOwnerEANovember 9, 2026
Seasonal PreparerPreparer1040 returns onlyNovember 9, 2026

Attachment G: Gap Checklist and Implementation Schedule

These items come from your answers. A plan only protects the Firm when its safeguards are actually in place, so complete each item and record the date.

PriorityRuleFindingActionDue byDone (date)
High16 CFR 314.4(c)(5)Multi-factor authentication is only on some systems.Turn on MFA for every person on Drake Tax, Google Workspace, remote access and any cloud storage. If a system cannot do MFA, the Qualified Individual must approve an equivalent control in writing.December 9, 2026
High16 CFR 314.4(c)(3)It is not known whether computer drives are encrypted.Turn on full-disk encryption (BitLocker on Windows, FileVault on Mac) on every desktop and laptop that stores or opens client data, and encrypt USB drives used for client files. Record the recovery keys in a secure place.December 9, 2026
HighIRS Pub 5708, Remote Access PolicyA remote access tool (AnyDesk) is in use.Require MFA on the remote access tool, remove unattended access where it is not needed, and allow remote sessions only during staffed office hours, as Pub 5708 recommends.November 23, 2026
MediumIRS Pub 5708, Wi-Fi Access PolicyClients or guests use the same Wi-Fi network as office computers.Create a separate guest network and keep office computers on a password-protected private network with strong (WPA2 or WPA3) encryption.December 9, 2026
LowIRS Pub 5708, Reportable Event PolicyNo cyber or data theft insurance is in place.Ask your insurance agent for a quote on a cyber liability policy or rider; many carriers also supply breach response help.January 8, 2027
Required16 CFR 314.4(e)(1)Security awareness training.Hold the first training session on this plan and collect a signed Attachment D from every person with access to client data.December 9, 2026
Required16 CFR 314.4(f)Service provider oversight.Confirm in writing that each service provider with access to client data (Drake Tax (tax software), Google Workspace (email), AnyDesk (remote access)) maintains appropriate safeguards, and keep that on file.December 24, 2026
RequiredIRS Pub 5708, Attachment CEFIN monitoring.Check the EFIN activity report in IRS e-Services weekly during filing season to spot returns you did not file.November 16, 2026
Required16 CFR 314.4(g)Annual review.Review and re-sign this plan.November 9, 2027

Attachment H: FTC Safeguards Rule Element Map

16 CFR 314.4 elementWhere this plan covers it
(a) Qualified IndividualSection IV
(b) Written risk assessmentSection V
(c)(1) Access controlsVII, User Access Control
(c)(2) Inventory of data and systemsV and Attachment E
(c)(3) EncryptionVII, Encryption
(c)(4) Secure development / app evaluationVII, Connected Devices and Service Providers
(c)(5) Multi-factor authenticationVII, User Access Control
(c)(6) Secure disposalVI and Attachment A
(c)(7) Change managementVII, Connected Devices
(c)(8) Monitoring and loggingVII, Network Protection
(d) Testing and monitoringVII, Testing and Monitoring
(e) Training and personnelVI and VII, Training
(f) Service provider oversightVII, Service Provider Oversight
(g) Keeping the program currentIV and Attachment G
(h) Incident response planSection VIII
(i) Annual reportSection IX
(j) FTC notification (500+ consumers)Section VIII

About this document

This plan was generated from the answers you gave, using the structure of IRS Publication 5708 and the elements of the FTC Safeguards Rule (16 CFR 314.4). It is a documentation template, not legal advice, and it does not by itself make your firm compliant: compliance comes from actually carrying out the safeguards it describes. Review it, correct anything that does not match your office, and have it reviewed by a qualified professional if you are unsure.