FTC Safeguards Rule

The FTC Safeguards Rule requires covered financial institutions to develop, implement, and maintain a written information security program with layered safeguards designed to protect customer information.

The Rule is not just about having documents. It expects organizations to understand what customer information they hold, where it lives, who can access it, what risks exist, and what controls are in place to reduce those risks. The FTC’s own guidance makes clear that the program must be tailored to the business, kept in writing, and actively supervised. There are real ramifications for non-compliance, too. Although SkyMed was not levied a fine, there were required to implement a very stringent information security program for 20 years.

Where organizations get exposed

• Treating compliance like a policy binder instead of an active security program
• No clearly assigned Qualified Individual with authority and accountability
• Incomplete risk assessments or assessments that are never updated
• Weak access controls, inconsistent MFA, or shared admin access
• No documented oversight of vendors handling customer information
• Missing encryption, logging, monitoring, or incident response procedures
• Leadership not receiving periodic reporting on the state of the program

How we support your Safeguards compliance

For many organizations, the hardest part is not understanding the Rule. It is turning the Rule into a repeatable operating model that people actually follow.

What we actually do for you:

• Determine whether your organization falls under the Rule and get a baseline of exposure vs compliance
• Build or refine your written information security program
• Serve in a Qualified Individual support role, with practical oversight and accountability
• Perform or coordinate risk assessments tied to real systems, workflows, and vendors
• Leverage our partnerships for affordable Pen Testing
• Review access, MFA, encryption, endpoint protection, logging, and response readiness
• Help establish vendor oversight, onboarding and offboarding controls, and policy governance
• Create executive reporting that supports board or leadership review requirements
• Assist with breach response planning and FTC notification readiness where applicable

FTC safeguards work best when security, process, and accountability move together.

If your current program would not hold up under scrutiny, we can help you tighten the rulebook before The Rule tightens up on you.