Auto Dealerships — FTC Safeguards Rule

FTC Safeguards Rule Compliance for Auto Dealerships in Illinois

Dealers that offer financing or leasing hold some of the most sensitive customer data there is: Social Security numbers, credit applications, and bank details. We deliver the risk assessment, written program, and security testing the Safeguards Rule requires, with a clear report for your compliance file.

What the rule requires

What the Safeguards Rule requires from dealers

Dealerships that arrange financing or leasing for customers are financial institutions under the FTC Safeguards Rule.

A written program and a Qualified Individual

Your dealership needs a Written Information Security Program based on a written risk assessment, overseen by a Qualified Individual who reports in writing to ownership at least once a year.

16 CFR § 314.4(a), (b), (i)

Testing on a set schedule

Unless you monitor your systems continuously, the rule requires an annual penetration test and vulnerability assessments at least every six months, plus after any material change to your operations.

16 CFR § 314.4(d)(2)

MFA, encryption, and breach notice

Multi-factor authentication for anyone accessing your systems, encryption of customer information, and notice to the FTC within 30 days of discovering a breach affecting 500 or more customers.

16 CFR § 314.4(c)(3), (c)(5), (j)

Dealers holding information on fewer than 5,000 consumers are exempt from the written risk assessment, the penetration testing schedule, the written incident response plan, and the annual report. Most franchise dealers exceed that threshold. We confirm which case applies to you on the first call.

What we review

Your dealership, from the F&I office to the service lane

  • Where customer data lives: DMS, CRM, F&I tools, credit bureau portals, scanned deal jackets
  • Internet-facing systems: firewall, VPN, remote access, website and lead forms
  • Internal network: segmentation between sales, service, guest Wi-Fi, and cameras
  • Multi-factor authentication on DMS, email, and remote access
  • Encryption of customer information on laptops, backups, and in transit
  • Service providers: DMS vendor, IT provider, and third-party marketing tools
  • Staff awareness: phishing and social engineering aimed at F&I and office staff
What you receive

Documentation for your compliance file

  • Written risk assessment of your customer information
  • Written Information Security Program for your rooftop
  • Penetration test report, external and internal, with prioritized fixes
  • Vulnerability assessment reports every six months (bundle)
  • Qualified Individual guidance and annual report template
  • Compliance summary for your file, lenders, and auditors
How it works

From first call to final report

1

Free 20-minute call

We confirm which parts of the rule apply to your dealership and map your systems and vendors.

2

Risk assessment

We review how customer data flows through sales, F&I, and service, and document the risks.

3

Penetration test

Controlled testing of your internet-facing and internal systems, scheduled around business hours.

4

Report and program

You receive the test report, the WISP, and a prioritized plan, and we review it with your team.

Packages

Fixed prices, quoted before any work starts

Starting prices for a typical small office. Your written quote sets the final price after the free call.

Dealer Safeguards Assessment

$4,500one-time
  • Written risk assessment
  • WISP for one rooftop
  • Qualified Individual guidance
Request a Quote

Dealer Compliance Bundle

$9,500per year, or $850/month
  • Risk assessment and WISP
  • Annual external and internal penetration test
  • Two semi-annual vulnerability assessments
  • Compliance report for your file
Request a Quote

External Penetration Test

$3,500starting at
  • Up to 16 public IP addresses
  • Firewall, VPN, and internet-facing services
  • Report with prioritized fixes
Request a Quote

See all CYBERISK prices →

Protecting customer data under the FTC Safeguards Rule (10 s)
FAQ

The Safeguards Rule: questions from dealers

Does the FTC Safeguards Rule apply to my dealership?

If your dealership arranges financing or leasing for customers, it is treated as a financial institution under the rule and must comply. We confirm your situation on the free call.

How often do we need a penetration test?

At least once a year, plus vulnerability assessments at least every six months and after any material change, unless you continuously monitor your systems. Dealers with fewer than 5,000 consumers are exempt from this testing schedule.

Our DMS vendor handles security. Is that enough?

No. The rule makes the dealership responsible for its own program and for overseeing its service providers. Your DMS is one system among many: email, remote access, Wi-Fi, and staff devices also hold customer data.

Who can be our Qualified Individual?

An owner, a manager, an employee, or an outside provider. The dealership remains responsible, and the Qualified Individual must report in writing to ownership at least once a year.

What if customer data is stolen?

If unencrypted information about 500 or more customers is involved, you must notify the FTC as soon as possible and no later than 30 days after discovery. A tested incident response plan makes that deadline manageable.

Will testing disrupt sales or service?

No. Testing is scheduled with you in advance, can run outside business hours, and uses controlled techniques designed not to interrupt your systems.

Official sources

This page is general information about regulatory requirements, not legal advice.