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Run: FTC Safeguards Rule Annual Risk Assessment Worksheet

Annual FTC Safeguards Rule risk assessment worksheet for auto dealers and financial institutions to document customer data risks, review safeguards, and assi...

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Assessment Scope and Recordkeeping

Record the assessment period covered by this annual review.
Select all business areas and systems that store, process, or transmit customer information.
Identify the categories of customer information maintained by the organization.
Confirm the assessment is documented and retained with supporting evidence, approvals, and remediation records.

Data Inventory and Information Flow

Customer information collection points are identified for sales, service, finance, online forms, and third-party channels.
All storage locations for customer information are documented, including cloud services, local devices, shared drives, and paper files.
Inbound and outbound transmission paths for customer information are reviewed, including email, portals, APIs, fax, and file transfers.
Retention periods and secure disposal methods are defined for records containing customer information.
Rate how effectively the organization limits collection and retention of customer information to what is needed.

Administrative and Governance Safeguards

A qualified individual is designated to oversee the information security program.
The written information security program has been reviewed and updated based on current risks and business changes.
Employees with access to customer information completed security awareness training within the required period.
Rate the effectiveness of joiner, mover, and leaver access controls.
Service providers with access to customer information are identified, reviewed, and monitored with appropriate contractual and security oversight.

Technical Safeguards

MFA is implemented for access to systems containing customer information where required by policy and risk.
Sensitive customer information is encrypted in transit and at rest, or compensating controls are documented where encryption is infeasible.
Logging, alerting, and monitoring are enabled for systems that store or process customer information.
Rate the effectiveness of patching and vulnerability remediation for in-scope systems.
Antimalware/EDR controls are deployed and managed on endpoints that access customer information.
Administrative and elevated access is limited, reviewed, and removed when no longer needed.

Physical Safeguards and Facility Controls

Offices, file rooms, server closets, and other restricted areas are secured against unauthorized entry.
Paper records containing customer information are stored in locked cabinets or otherwise protected when not in use.
Screens, printers, and desks are positioned or configured to reduce unauthorized viewing of customer information.
Shredding, destruction, or secure media disposal methods are available and used for sensitive records and devices.

Risk Findings, Remediation, and Approval

Summarize all identified deficiencies, non-conformances, and critical items that require remediation.
Document owners, target dates, and remediation steps for each finding.
Management has reviewed the results and accepted any remaining residual risk.
Inspector attestation that the annual risk assessment was completed accurately.

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