Purpose & Posture

The FTC Safeguards Rule requires financial institutions to maintain a written, risk‑based information security program.
We prepare organizations by establishing governance, risk assessment, safeguards documentation, evidence management, and sustainment—so your program operates defensibly over time. Our role is readiness and sustainment, not regulatory determination.

ROLE BOUNDARIES (IMPORTANT)

We are a compliance readiness and sustainment partner.

  • We are a compliance readiness and sustainment partner.
  • We are not a QSA and do not perform or influence PCI DSS assessments, ROCs, or SAQs.
  • Independent assessments are conducted by Qualified Security Assessors.
  • We do not guarantee outcomes.

How We Help

1) Scope & Applicability

  • Identify customer information and in‑scope services.
  • Define program boundaries and service provider relationships.

2) Risk Assessment

  • Facilitate defensible, documented risk assessments.
  • Align identified risks to appropriate safeguards.

3) Governance & Program Design

  • Define the Qualified Individual role and responsibilities.
  • Develop the written information security program (WISP) with clear ownership.

4) Safeguards & Evidence

  • Map administrative, technical, and physical safeguards to evidence.
  • Build an evidence register and review cadence for sustainment.

5) Service Provider Oversight

  • Document oversight expectations, contractual controls, and monitoring approach.

6) Ongoing Program Evaluation

Support monitoring, testing, and periodic assessments to validate program effectiveness.

Sustainment

We support long‑term program maintenance via:

  • Evidence refresh cycles and version control
  • Change management for business and vendor shifts
  • Executive reporting to track safeguard effectiveness and risk movement

Representative Deliverables

  • Written information security program (WISP)
  • Risk assessment documentation and treatment notes
  • Evidence register with ownership and cadence
  • Service provider oversight records (inventory, obligations, monitoring)
  • Sustainment & review calendar with management inputs
Request an FTC Safeguards readiness call
Download the Evidence Register Template (sanitized)

Note: We focus on readiness, documentation, evidence, and sustainment. Regulatory oversight is external and independent; we do not provide legal determinations.