16 CFR Part 314FTC Safeguards Rule
Tax preparation businesses are "financial institutions" under the rule. You need a written information security program with a designated Qualified Individual, MFA for anyone accessing systems with client data, encryption, staff training and oversight of your service providers.
A breach involving 500 or more consumers must be reported to the FTC within 30 days.
Form W-12 · line 11Your PTIN renewal
When you renew your PTIN, the form asks you to confirm you are aware that paid preparers are required by law to create and maintain a WISP.
That is an acknowledgment of awareness, not proof of a plan. If there is ever a breach, the first question is where the plan is.
Fla. Stat. 501.171Florida breach notice
Florida requires reasonable measures to protect personal information. A breach affecting 500 or more Floridians must be reported to the Florida Department of Legal Affairs within 30 days. Your plan should cover both the FTC and the Florida notice.
16 CFR 314.6Small office? Most of it still applies.
Firms holding information on fewer than 5,000 consumers are exempt from a few parts: the written risk assessment, the testing schedule, the written incident response plan and the annual report. They are not exempt from the Qualified Individual, MFA, encryption, training or vendor oversight. We will tell you which parts apply.
General information, not legal advice.