What Is the FTC Safeguards Rule?
The FTC Safeguards Rule is about how to protect customers’ non-public personal informat…
Federal Trade Commission Safeguards Rule
LOCATION
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United States
industry
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Financial Services
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Automotive
Requirements
9
Achieve Compliance Confidence
Understanding the Safeguards Rule: Protecting Non-Public Customer Information
What the Rule Actually Requires:
If you handle consumer financial data, whether you’re a CPA firm, mortgage broker, auto dealer, F&I office, or investment adviser—you’re required to implement a written security program with nine specific elements: a designated security lead, documented risk assessments, access controls, encryption, employee training, monitoring and testing, MFA, an incident response plan, and annual board reporting.
What That Looks Like in Practice:
ForgePath turns these requirements into operational controls. We run your risk assessment workshops. We write the policies your auditors actually want to see. We deploy the monitoring and testing tools that generate audit-ready evidence—so compliance isn’t a fire drill, it’s a baseline.
The Nine Requirements
FTC Safeguards Compliance At a Glance
If you’re a non-bank financial institution, CPA firm, mortgage broker, auto dealer, tax preparer, or investment adviser—you must implement all nine elements below. Here’s exactly what you’re required to have in place and what regulators will look for.
Requirements
Qualified Individual
Designate a Qualified Individual responsible for overseeing and enforcing the information-security program. This can be an internal hire or an outsourced vCISO, as long as that someone is formally serving as your Qualified Individual.
Written Risk Assessment
Document reasonably foreseeable internal and external risks to customer data and align safeguards to mitigate them.
Access Controls
Limit information access to authorized users and implement least-privilege, role-based permissions.
Encryption of Data in Transit & at Rest
Encrypt customer information both while stored and during transmission over external networks.
Security & Phishing Awareness Training
Provide ongoing training and phishing simulations to ensure employees understand their security responsibilities.
Monitoring & Testing
Implement continuous monitoring of your security program, or at minimum, conduct annual penetration testing and vulnerability assessments at least every six months.
Multi-Factor Authentication (MFA)
Require MFA for any individual accessing customer information in information systems.
Incident Response Plan
Develop a written IRP outlining procedures for detecting, responding to, and recovering from security events.
Board Reporting
Provide the board of directors (or equivalent) with a written report, at least annually, on program status, incidents, and recommendations.
How ForgePath Can Help
vCISO & Board Reporting Support
Need a qualified individual but not a full-time hire? Our vCISO service gives you executive-level security leadership, including the annual board reports the rule requires.
Vulnerability Management
Continuous scanning. Tracked remediation. Audit-ready reports. We run the program so you can prove to regulators it's actually working.
Penetration Testing Services
Your annual testing requirement, Covered. We simulate real attacker techniques against your network and applications, then document exactly what we found and how to fix it.
Security Awareness Training
Equip your staff to recognize social engineering, phishing, and other threats. The rule requires ongoing training. We deliver programs that meet the requirement and actually change behavior.
Phishing Simulation
Run continuous phishing campaigns to test employee readiness and document training effectiveness for regulators.
IR Plan Development & Review
The Safeguards Rule requires a written incident response plan. We build IRPs tailored to your environment, or review and strengthen what you already have.
Tabletop Exercises
Test your incident response plan before a real breach does. We run realistic scenarios so your team knows exactly what to do when something goes wrong.
Access Management Review
Evaluate your current access policies against least-privilege principles and identify over-permissioned accounts before auditors do.
Privileged Access Management (PAM)
Protect the accounts that matter most. We implement controls around admin and service accounts that access customer data.
Data Security Governance
Build the policies and controls that govern how customer data is stored, transmitted, and encrypted which is core to meeting the rule's technical safeguards.
Working With ForgePathForgepath has become a trusted security partner for YHB.
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Working With ForgePathForgepath delivered outstanding service on our network and app security tests.
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Working With ForgePathForgepath separates themselves from the rest as they’re a true security partner.
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Ready to Get Started?
Strengthen Client Trust with FTC Safeguards
Stop treating compliance as a checkbox. The firms that get Safeguards right don’t just satisfy regulators, they build security programs that actually reduce risk. ForgePath takes you from gap assessment to continuous monitoring, with documentation that holds up under FTC scrutiny.
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