FTC Safeguards Rule Compliance Audit Checklist
Purpose:
This checklist is designed to assist [Dealership Name] in conducting a thorough compliance audit for the FTC Safeguards Rule. It evaluates the dealership’s Information Security Program (ISP) and ensures that administrative, technical, and physical safeguards are effectively implemented to protect customer information.
1. Administrative Safeguards
1.1 Designation of Program Coordinator
Has a qualified employee been designated as the Program Coordinator?
Does the Program Coordinator oversee the Information Security Program and report to senior management?
1.2 Risk Assessment
Has a comprehensive risk assessment been conducted to identify potential risks to customer information?
Are specific risks documented, including internal and external threats?
Have strategies been implemented to mitigate identified risks?
1.3 Policies and Procedures
Are written policies and procedures in place for safeguarding customer information?
Do policies address employee training, vendor oversight, and data security?
1.4 Employee Training
Are employees trained on the Safeguards Rule and dealership-specific data protection policies?
Is training provided regularly and documented?
1.5 Incident Response Plan
Is there a documented plan for responding to security incidents or data breaches?
Are employees aware of their roles in the event of a breach?
2. Technical Safeguards
2.1 Access Controls
Are access controls in place to restrict access to sensitive customer information?
Are employee access privileges based on job responsibilities?
2.2 Multi-Factor Authentication
Is multi-factor authentication (MFA) implemented for access to systems containing customer information?
2.3 Encryption
Is customer information encrypted both in transit and at rest?
2.4 Monitoring and Detection
Are systems monitored for unauthorized access, malware, or other security threats?
Are intrusion detection/prevention systems in place?
2.5 Software Updates and Patches
Are all software, systems, and applications updated regularly to address vulnerabilities?
3. Physical Safeguards
3.1 Secure Storage
Are physical records containing customer information stored in locked, access-controlled areas?
Are documents left unattended in open areas (e.g., desks, counters)?
3.2 Device Security
Are dealership devices (e.g., computers, mobile devices) secured when not in use?
Are lost or stolen devices promptly reported and remotely wiped?
3.3 Secure Disposal
Are physical records securely shredded or destroyed when no longer needed?
Are electronic records securely deleted using certified data-wiping tools?
4. Vendor Oversight
4.1 Vendor Risk Assessments
Have vendors handling customer information been evaluated for their data security practices?
Are vendor contracts reviewed to ensure compliance with dealership security standards?
4.2 Monitoring Vendor Compliance
Are vendor performance and compliance monitored regularly?
Is there a process for terminating vendor relationships in case of non-compliance?
5. Monitoring and Testing
5.1 Ongoing Monitoring
Are systems and processes monitored continuously to identify vulnerabilities?
Are logs of system activity reviewed regularly?
5.2 Penetration Testing
Has penetration testing been conducted to evaluate the effectiveness of safeguards?
Are vulnerabilities identified during testing promptly addressed?
5.3 Audit Frequency
Is the Information Security Program audited at least annually?
Are audit results documented and shared with senior management?
6. Recordkeeping
6.1 Documentation of Safeguards
Are policies, risk assessments, and security measures documented?
Are records of employee training and incident response maintained?
6.2 Retention Period
Are records retained for at least five years or as required by applicable laws?
7. Incident Response and Breach Management
7.1 Breach Detection
Are systems capable of detecting unauthorized access or data breaches?
7.2 Breach Reporting
Are breaches reported to affected customers and regulatory authorities as required?
Are breach investigations documented?
8. Compliance with Regulatory Updates
Is the Information Security Program reviewed and updated annually or when regulations change?
Are all changes to the FTC Safeguards Rule incorporated into dealership policies and practices?
Audit Summary
- Date of Audit: [Insert Date]
- Auditor Name and Title: [Insert Name and Title]
- Findings: [Insert Summary of Findings]
- Corrective Actions: [List Required Actions and Deadlines]
Signature of Approval
Program Coordinator: ___________________________
Date: ___________________________
Senior Management: ___________________________
Date: ___________________________
This checklist ensures a thorough review of compliance with the FTC Safeguards Rule and identifies areas for improvement. Let me know if you need help tailoring it to your dealership’s specific needs!