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Free template · FTC Safeguards Rule · IRS Pub. 4557

The WISP every paid tax preparer is required to have

A Written Information Security Plan is the security document the FTC Safeguards Rule and IRS Publication 4557 expect every preparer to keep. Most small firms don't have one — not because it's hard, but because nobody has ever shown them what goes in it. Here are all eight sections, in full.

Read time ~7 min · Free PDF template at the end

Why a small firm needs one

Under the FTC Safeguards Rule, a paid tax return preparer counts as a financial institution. That brings an obligation to maintain a written information security program covering how client data is protected — regardless of whether the firm is twelve people or one. IRS Publication 4557, Safeguarding Taxpayer Data, sets out the same expectation in plainer language, and the IRS asks preparers to confirm they have a plan at PTIN renewal.

The rule is deliberately scaled: the program has to be appropriate to your firm's size and complexity, the nature of what you do, and the sensitivity of what you hold. A solo practice does not need the same document as a regional firm. What it does need is a document that addresses every element honestly and describes what the firm actually does — an aspirational plan nobody follows is worse than a modest one that's true.

This page is a starting point, not legal advice. It describes the structure of a WISP and what each section is for. Requirements change and your circumstances may differ — check the current FTC Safeguards Rule and IRS Pub. 4557, and take professional advice where you need it.

0 · Firm details

Open with the identifying facts, so the plan is unambiguously yours and unambiguously current.

SECTION 0
Firm legal name
Principal office address
Plan effective date
Qualified Individual (security coordinator)

1 · Designate a Qualified Individual

The Safeguards Rule (16 CFR 314.4(a)) requires one named person accountable for your information security program. In a solo practice that is you; the point is that the accountability is written down rather than assumed. Name them and define their authority.

SECTION 1
Qualified Individual — name & title
Reports to / oversight

2 · Risk assessment

Identify reasonably foreseeable internal and external risks to the confidentiality, integrity and availability of client data — and, crucially, where that data actually lives. Most firms are surprised by how many places the answer includes.

SECTION 2
Highest-priority risks identified

3 · Safeguards in place

The controls you have implemented. Work down the list honestly — every unchecked box is an action item, and a plan that records the gaps alongside a date to close them is more defensible than one that quietly claims everything is fine.

4 · Service providers

Vendors that touch client data — tax software, cloud storage, email, e-file providers — must be capable of protecting it, and you are expected to have satisfied yourself of that. List them and confirm safeguards.

SECTION 4
Key service providers & what data they hold

5 · Incident response plan

Under IRS rules you must be able to report a data breach quickly, which means deciding who does what before the morning it happens.

SECTION 5
Incident lead & backup contact

6 · Employee training & the annual review

A plan written once and filed away is the most common failure mode. Record training and schedule the review.

SECTION 6
Next scheduled review date

7 · Attestation

The Qualified Individual attests that the plan has been implemented and will be maintained. This is what turns a document into a commitment.

SECTION 7
Signature
Printed name & title
Date

Take the template

PDF · Template

WISP Starter Kit

All eight sections above as a fill-in-the-blanks PDF, with the safeguards checklist and the attestation block laid out to sign.

✓ Ready — download the PDF ↓

Stop filling it in by hand

BlackTally builds and maintains the plan for you.

It generates your WISP from these exact controls, publishes it with an attestation and version history, tracks the annual review, and keeps your preparer roster and PTIN renewals current — alongside chasing your clients for missing documents.

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