SafeguardOps delivers a done-for-you managed compliance program — the written information security program (WISP), the annual risk assessment, the Qualified Individual, the annual board report, and 30-day breach-notification readiness — all checked against the letter of 16 CFR Part 314 before a named security lead signs off.
Since June 9, 2023, every non-bank financial institution under GLBA must run a full information-security program under the FTC's amended Safeguards Rule. That means a written program, a designated Qualified Individual, a written risk assessment, encryption and MFA, continuous monitoring or twice-yearly vulnerability scans plus annual penetration testing, vendor oversight, an incident-response plan, and an annual written report to the board or owner. Since May 2024, institutions must also notify the FTC within 30 days of a breach affecting 500 or more consumers.
Most small financial institutions — auto dealers, mortgage brokers, tax preparers, collection agencies — have no CISO, no compliance staff, and no idea how to produce a defensible WISP or run a penetration test. They face two bad options: buy compliance software they must operate themselves, or hire a virtual CISO at $2,600–$11,600 per month. Both leave the actual work on the dealer's desk.
SafeguardOps productizes the entire obligation as a managed service. An internal AI engine drafts, maps controls, gathers evidence, and monitors continuously; a named human security lead makes the risk calls and signs the report. We sell the outcome — 'you are Safeguards-compliant, with a signed file behind every requirement.'
We do not summarize the law and hope. Every engagement is scored against a versioned rule pack tied to the exact text of 16 CFR Part 314. These are the provisions each program is held to.
A comprehensive WISP that identifies reasonably foreseeable internal and external risks, assesses safeguards, and includes administrative, technical, and physical controls — drafted from your systems inventory and vendor list.
A named human security lead who oversees the program, conducts the annual risk assessment, and signs the annual board report. The FTC deliberately made this role license-free — no certification required, only real-world know-how.
An annual written risk assessment that evaluates the confidentiality, integrity, and availability of customer information, identifies threats and vulnerabilities, and documents the safeguards implemented.
Controls to authenticate and authorize access to customer information, including encryption of data at rest and in transit, and multi-factor authentication for any individual accessing customer information.
Continuous monitoring or twice-yearly vulnerability scans plus annual penetration testing. Evidence of each scan and test is collected and retained in the compliance file.
A vendor oversight program that assesses and monitors service providers' safeguards, plus an incident response plan that includes the 30-day FTC breach notification duty for breaches affecting 500 or more consumers.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A named human security lead signs every report. That order is never reversed.
Upload your systems inventory and vendor list. We return a free completeness read: which of the eight Safeguards artifacts you already have, and which are missing.
As your authorized clerical agent, we collect your systems inventory, vendor contracts, existing policies, and any prior risk assessments. We also order any required vulnerability scans or penetration tests.
The AI engine drafts the WISP, risk assessment, and incident response plan against the 16 CFR Part 314 rule pack into field-locked templates — no legal opinions, no invented facts.
Each of the eight artifacts is checked against a rule-mapped control library. Amounts reconcile, dates are verified, evidence is mapped. Any failure blocks release.
A named security lead (your outsourced Qualified Individual) reviews the exception queue, makes risk judgments, and signs the annual board report. High-value or complex engagements route to attorney review first.
You receive a signed, audit-ready compliance file for each of the eight Safeguards elements, refreshed annually. If a breach or FTC inquiry hits, we defend the file.
The deliverable is a signed, audit-ready compliance file — not software you have to run. We do the work; you get the outcome.
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
We prepare documentation and run evidence collection as your clerical agent. We never provide legal advice or represent you in any legal matter. Attorney review is available and recommended for complex engagements.
Simple, predictable, and aligned with a compliance outcome — not a cut of any recovery.
Start with a free Compliance Gap Scan. Send your systems inventory and vendor list and we'll return a completeness read against every element of 16 CFR Part 314.
Documentation-completeness service · not legal advice · you remain the financial institution.