For tax preparers
You signed line 11. This is what stands behind it.
Form W-12 asks every PTIN applicant and renewer to acknowledge that paid preparers are required by law to create and maintain a written information security plan. The requirement does not scale with the size of your practice. A sole preparer with one client is inside it.
The three documents that decide what you owe
What applies to you
Where the gaps usually are
The five things that catch preparers out
Season staff
Preparers you bring on for four months still need access controls, signed acknowledgments and training, and their access still has to be removed in April. The offboarding step is the one everybody skips.
The portal is not the whole story
A secure portal covers documents in transit. It says nothing about the return files on a laptop, the scans in an email folder, or the backup drive in a desk.
Preparer software vendors are service providers
Your tax software, your e-file transmitter and your document manager all touch client information, which puts them under 314.4(f) and means your contracts need the safeguards clause.
Personal devices
The phone that receives client texts and the home laptop used in March are both in scope, and both need encryption and a written policy behind them.
The plan drifts every season
You change software, add a preparer, drop a vendor. By the following October the document describes a practice that no longer exists.
The renewal-week mistake
Assembling a program the week you renew produces a program that looks assembled the week you renewed. A year of dated entries costs no more and reads completely differently. The only requirement is starting before October. More on the renewal window
Know another firm that needs this? Each one that signs up with your code takes 20% off your own renewal. Five and you pay nothing.
How the discount works →Find out what you would actually have to show
The quiz asks the questions a reviewer would, in the order the regulations set them out.