Compliance glossary
Definition

Customer Information (FTC Definition)

Any record about a consumer that is held by a financial institution, including tax returns, Social Security numbers, and financial account data.

What it means.

Under the FTC Safeguards Rule, customer information means any record containing nonpublic personal information about a consumer that is handled by or on behalf of a financial institution (16 CFR 314.2(d)). For CPA firms, this includes tax returns, W-2s, 1099s, Social Security numbers, bank account information, mortgage details, brokerage statements, and any other client financial record. Customer information includes records held electronically, in paper form, and in any other medium.

Why it matters for CPA firms.

The scope of customer information determines what your security program must protect. Many firms underestimate it, focusing only on tax returns while overlooking working papers, email attachments, voicemails with bank details, and old paper files. Every system that touches customer information falls under the Safeguards Rule. Your data inventory and WISP must cover all of it, not just the tax software.

Relevant regulations.

  • 16 CFR 314.2(d)
  • Gramm-Leach-Bliley Act (GLBA)

How Kompflow helps.

The Data Inventory & Classification module handles this for your firm, personalized to your software, team size, and state requirements.

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