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Small and medium-sized accounting firms often face unique challenges when building an Information Security (Info Sec) program. With increasing demands for security assurance, creating an effective Info Sec program is critical. However, limited resources and expertise can make the process feel overwhelming.
A structured, multi-step approach can simplify the process and reduce the time and resources needed to establish a robust security posture. Below, we outline the three key phases to help accounting firms get started.
Phase 1: Define Your Info Sec Plan
Defining your plan is the foundation of a successful InfoSec program. Skipping this step can lead to wasted time and resources, particularly during client security reviews. For accounting firms, this phase involves:
Determine Your Goal
What’s driving your InfoSec initiative? Is it purely for compliance with the FTC Safeguards Rule or IRS 4557? Are you aiming to obtain a certification like SOC 2, ISO 27001, or HIPAA to meet client demands? Or do you want to align with a framework like NIST CSF or GDPR to enhance overall security? Your goal will determine which policies and controls you need to prioritize.
Conducting a Risk Assessment
Identify the risks unique to your accounting practice. For example:
What happens if client financial data is compromised?
How likely are these risks, based on your technology and workflows
Answering these questions helps demonstrate accountability to clients and lays the groundwork for effective controls.
Documenting Your Policies and Controls
Your InfoSec program should include high-level policies (e.g. “We encrypt sensitive client data”) and actionable controls (e.g. “All client data is stored using 256-bit encryption”). For accountants, common controls might include access restrictions to accounting software, regular data backups, and secure client communication methods.
Time Estimate
Writing policies from scratch can take weeks or months. However, using tools and templates with pre-built, framework-aligned policies can save significant time.
Phase 2: Implement Security Controls
With your plan in place, it’s time to put it into action. This phase involves implementing the security controls you’ve identified. For accounting firms, these might include:
Encrypting client data stored in both on-premises and cloud-based accounting platforms.
Enforcing multi-factor authentication (MFA) for all employees accessing financial systems.
Securing client communication channels, such as email encryption or secure portals for document sharing.
Assign responsibilities to team members and track progress like you would for other operational tasks. Many firms find success using project management tools to ensure controls are implemented efficiently and consistently.
Time Estimate
Implementing controls for frameworks like NIST CSF, ISO 27001 or SOC 2 can takes 3–6 months, depending on the firm’s size and existing security measures. Firms with basic controls already in place (e.g. antivirus software and firewalls) may require less time.
Phase 3: Prove Compliance
Once your controls are in place, the final step is proving compliance. This phase is essential for building client trust, especially if you’re pursuing certifications like SOC 2 or ISO 27001.
What to Expect
Auditors or clients may request evidence to confirm your controls are working as intended. For example:
Policies outlining access controls for accounting software.
Screenshots showing MFA setup.
Logs of employee training sessions on phishing awareness.
Gathering and organizing this evidence can be time-intensive, but using compliance automation tools can streamline the process. These tools allow you to assign and track evidence collection tasks, ensuring faster responses to audit requests.
Time Estimate
With good preparation, this phase can be completed in less than two months, especially if compliance management software is used to track progress and manage auditor communications.
Final Thoughts for Accountants
Building an InfoSec program may feel daunting, but it’s an investment in protecting client trust and your firm’s reputation. By starting with a clear plan, methodically implementing controls, and proving compliance, even small and medium-sized accounting firms can achieve a strong security posture in under six months.
Leveraging compliance automation tools can simplify the process, helping your firm save time, reduce costs, and demonstrate professionalism to clients. As cyber threats and regulatory demands grow, having an effective InfoSec program is no longer optional—it’s essential for long-term success.
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