The rule requires a written information security program and, unless exempt, specific written risk-assessment, testing, incident-response, and reporting records. Citation: 16 CFR 314.4 and 314.6.
Primary source: FTC Safeguards Rule business guidance
What documents does the Safeguards Rule actually require for a collection agency?
Details
Policywright splits the operating record into a WISP, incident response plan, acceptable use policy, and access control policy. For a collection agency, those documents should map to Consumer information arrives in placement files, skip-tracing tools, dialer and CRM systems, payment portals, call recordings, dispute documents, and creditor reporting. The WISP should track transfers back to clients and any vendors that receive account inventories.
Primary source: FTC Safeguards Rule business guidance.
FAQ
What documents does the Safeguards Rule actually require for a collection agency?
The rule requires a written information security program and, unless exempt, specific written risk-assessment, testing, incident-response, and reporting records. Citation: 16 CFR 314.4 and 314.6.
What is the data-flow issue for a collection agency?
Consumer information arrives in placement files, skip-tracing tools, dialer and CRM systems, payment portals, call recordings, dispute documents, and creditor reporting. The WISP should track transfers back to clients and any vendors that receive account inventories.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.