How we handle your clients’ data

What we take, where it goes, and who sees it.

For partners, practice managers and compliance

Lead reactivation works the people your firm has already met — former clients who did not come back, and prospects who asked for a quote, were followed up once or twice, and then were not. We rank them by likelihood to book a conversation and work the list from the top, so your staff spend their time on the people most likely to engage.

Many of those records carry rules of their own: section 7216 of the Internal Revenue Code for anything that came to you with a tax return, the FTC Safeguards Rule, your professional code and state board rules, and federal and state telemarketing law. This document sets out, control by control, how the engagement keeps your firm inside those rules — and which decisions stay with your firm. It is written to be read by the partner responsible for compliance and filed with your vendor due diligence.

Sections 02 to 06 are the plain-English part. They show the whole system in pictures, explain the four things the ranking looks at, and follow one example lead from your CRM to your staff. The sections after them are the detail your compliance review will check.

01

Commitments

Ten commitments, before the detail

• 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails, addresses and taxpayer IDs stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
• 02 · Tax return information is sorted first — Every record is placed in a section 7216 lane on your side, before anything is exported. Former tax clients without a signed consent stay with your firm.
• 03 · Nothing goes out without your approval — A partner, or the person you name, approves every template. Every message and the list it went to is kept for at least 36 months.
• 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
• 05 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction.
• 06 · Breach notice within 72 hours — As soon as possible and no later than 72 hours, so your firm can meet its own deadlines to clients, the FTC and the IRS.
• 07 · Return and destruction, certified — At the end of the engagement your data, including the identity key, is returned or destroyed, and we confirm it in writing.
• 08 · No tax advice, no promised results — Messages invite a conversation with your staff. No refund estimates, savings claims, guarantees or views on anyone’s taxes.
• 09 · A fee structure your firm chooses — A flat fee or a results-based fee, with how each is treated under your code and your state board set out in section 14.
• 10 · Evidence on request — Every control here has something you can inspect. We complete your due diligence questionnaire during onboarding.

02

The whole picture

The system on one page

The system works in three zones. Names and contact details stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your firm approves and sends.

G1 — the agreement and intake review — clears before any data moves. G7 covers retention and destruction.

Dashed gold-edged boxes, marked G1 to G7, are compliance gates. Nothing passes a gate until it clears. Section 03 lists what each one checks. Former tax clients without a section 7216 consent never enter the system: they stay with your firm (section 08).

03

Step by step

From our first conversation to the first message

Seventeen steps in five phases. The gate marks show where a compliance check has to clear before the work moves on.

Onboard (before any data)

• 01 First conversation — How your firm works with prospects today
• 02 Agreement — Roles, purpose, subprocessors, 72-hour notice G1
• 03 Intake review — Lead sources, consent wording, 7216 consents G1
• 04 Secure environment — In your environment, or our workstation

Prepare (on your side)

• 05 Map your stages — Your CRM statuses to eight shared stages
• 06 Check the list — Opt-outs, Do Not Call, clients, tax lane G2
• 07 Swap names for IDs — A random ID; the key stays with you
• 08 Notes into facts — Fixed-list answers; figures become tiers G3

Rank (Tez scoring)

• 09 Score — Intent, Opening, Reachability, Fit
• 10 Tier and reasons — A to D, with the top reasons
• 11 Short summary — Why call, and an opening line, checked G4
• 12 Next step — Channel by consent, and timing

Act (on your side)

• 13 Match back — The ranked list appears in your CRM
• 14 Your approval — A partner approves the wording G5
• 15 Send — Re-checked at sending; copies kept G6

Learn (ongoing)

• 16 Record outcomes — Booked, held, engaged; a held-back group
• 17 Improve and report — Your ranking only; results you can check G7

04

The ranking

How the list is put in order

Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.

How the ranking gets better

• 01It starts from your team’s experience — Your staff tell us how often each kind of paused prospect comes back. Those estimates set the first odds, and until your results come in we say so.
• 02It corrects itself from your results — As consultations are booked, held or declined, the odds for each reason move toward what actually happened at your firm.
• 03It becomes a model of your firm alone — After about 300 recorded outcomes, the ranking is fitted to your firm’s results. It is never trained on, or pooled with, another firm’s data.
• 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back for a set period. Comparing the two groups shows what the outreach changed, not what would have happened anyway.

05

A worked example

One lead, from your CRM to your staff

Dana Ruiz is fictional; her record is shaped like a real one. She asked for a bookkeeping quote and did not reply. Follow her through the four cards, left to right and top to bottom.

1 · Your CRM record (stays with you)

2 · What we receive (leaves your side)

Never leaves your side: her name, phone, email, CRM ID, the note itself, the revenue figure, exact dates.

3 · What comes back (back to you)

4 · In your CRM (stays with you)

No text consent, so email first. Her inquiry is over three months old, so a Do Not Call check precedes any call. The draft says why she is contacted. Your staff first see her name here.

• 01Her note became a few facts — “Second shop” left only as “an event expected by spring.” With event types your firm approves, the summary can say more.
• 02If she had come to you for a tax return — Her record would be tax return information. Without a signed 7216 consent it would stay with your firm, filtered out before export, and your own staff would follow her up (section 08).

06

The suggestion

How the “why call” note is written and checked

Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. A record under a 7216 consent gets a summary only if the consent names the AI provider. The AI writes; it does not decide. The order comes from arithmetic, and your firm approves anything sent.

The four checks at gate G4

• No personal data — The draft may not contain a name, number, email or address. Names appear only as a placeholder, filled in on your side at sending.
• No tax advice, no promised results — No refund estimates, savings figures, guarantees, contingent-fee offers or positions on anyone’s taxes. The draft invites a conversation with your staff, nothing more.
• Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.
• Says what it is; keeps to your list — Each draft reads as an offer of services and says why the person is being contacted. Phrases and topics your firm rules out are blocked.

07

Roles

Your firm stays responsible; so do we

Under the FTC Safeguards Rule a firm that prepares income tax returns is a financial institution and Tez I Solutions is its service provider: your firm chooses providers able to protect the data, binds them by contract and assesses them (16 CFR 314.4(f)). Your code adds a confidentiality agreement or the client’s consent (AICPA 1.700.040). Section 7216 adds a third condition: tax return information leaves your firm only under a signed consent naming us and the purpose, so former tax clients without one stay with you. This is how responsibility divides.

08

Data

What we take, and what we never take

Tax return information is any information given to your firm for, or in connection with, preparing a return — including a name, address and phone number, and including what a prospect gave you when they asked to have a return prepared (Treas. Reg. 301.7216-1). So every record is placed in one of three lanes before anything moves.

The list rule lets your firm contact its own former tax clients to offer tax return preparation (Treas. Reg. 301.7216-2(n); Rev. Rul. 2010-4). In California, Bus. & Prof. Code 17530.5 also requires a separate written consent before such information is disclosed.

What the lanes mean in practice

• 01Your former tax clients stay with you — You know them, and the law lets you contact them yourself to offer tax preparation. We do not receive, rank or message them; those relationships never leave your firm.
• 02Cross-selling from tax records needs a consent — Offering bookkeeping, payroll or advisory work on the strength of someone’s tax records needs a consent, and that consent cannot be requested after they received their completed return (Treas. Reg. 301.7216-3(b)(2)).
• 03A signed consent opens lane 2 — A consent naming us, the purpose and the information, signed before we receive anything (Treas. Reg. 301.7216-3; Rev. Proc. 2013-14), moves a record into lane 2 while it runs.
• 04Filtered at export, checked again at the end — The export allow-list leaves lane 1 out at the source; the final scan holds back anything that looks like tax return information.

09

The privacy layer

Where AI sits, and what it sees

Notes are the most sensitive part of a record and the most useful. So they are read where they already are, only short answers leave, and notes from tax engagements are not read at all.

10

Where it runs

Two ways to run the secure environment

The secure environment is where identifiable data lives during the engagement, and your firm chooses where it sits. In both options the key table never leaves it, the data stays in the United States, and the AI provider receives only a random ID and fixed-list facts.

Workstation standard, when Tez operates it

• Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each firm’s data.
• Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
• No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
• Wiped at the end — The firm’s volume is destroyed at termination and the destruction certified in writing.

11

Security and incidents

The controls, and what happens if one fails

If something goes wrong

• 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
• 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. Updates follow as we investigate.
• 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation and any IRS or state report.
• 04 · Support your notice, never pre-empt it — Notice to clients, and to the FTC within 30 days where 500 or more consumers are involved, is your firm’s call. We never contact your clients about it.

12

Professional rules

Your solicitation rules cover this outreach

Your code says members must not do through others what they may not do themselves (AICPA 1.600.010). Every message we send is your firm’s solicitation, held to the AICPA Code, Circular 230 and your state board.

• 01Not false, misleading or deceptive — AICPA 1.600 — No promised refunds or outcomes, no implied influence with the IRS, no fee quotes that leave out what drives the fee. Texas Rule 501.82 and New York’s Part 29 also bar unverifiable claims and guarantees.
• 02Says what it is, and where the contact came from — Circular 230 — Section 10.30 requires a solicitation to identify itself and the source of the information used to choose the recipient — for example, “you asked us about bookkeeping in February.”
• 03Stops when asked — Circular 230 section 10.30(c) and Texas Rule 501.82(c) bar persisting with a prospect who has said no. An opt-out, or a plain “not interested,” ends contact on every channel.
• 04Kept for 36 months — A copy of each electronic or mailed message and the list it went to, kept at least 36 months (Circular 230 section 10.30(c); Texas Rule 501.82(d)), in your systems or captured into them.
• 05No offer your rules forbid — No contingent-fee return preparation (AICPA 1.510; Circular 230 section 10.27), no commission-based products for attest clients (AICPA 1.520), and no use of tax records outside a signed consent (section 08).
• 06An approval trail, and rails it stops at — For every template: the draft, the approved wording, who approved it and when. Tax questions, identity checks and complaints go to your staff (gate G4, section 06).

13

Consent

No evidenced consent, no text message

Under the Telephone Consumer Protection Act the party that sends a message can be liable for it directly. So consent is enforced in software at the moment of sending, not left to policy. Business owners count: a text to a mobile number needs the same consent whether it reaches a household or a company.

• 01 · A consent history, not a checkbox — Each lead’s consent is an append-only record of source, wording, channel and date. Contactability is derived from it, never overwritten.
• 02 · Checked when the message sends — Consent, suppression, Do Not Call and quiet hours are rechecked at sending, not at list-building. Yesterday’s opt-out holds today.
• 03 · Aged leads without evidenced consent — Email, or your staff directly — not text. An inquiry over three months old, or a last paid engagement over 18 months ago, is no established business relationship for Do Not Call.
• 04 · Do Not Call and reassigned numbers — Checked against the National Do Not Call Registry and the FCC Reassigned Numbers Database. Results dated and stored.
• 05 · Quiet hours and state law — 8am to 9pm in the lead’s local time, narrower where required. Florida, Oklahoma, Maryland, Washington and Texas SB 140 rules applied by state.
• 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your staff is honoured on every channel and survives any re-import. Email unsubscribes within 10 business days.

14

How we are paid

Two fee models, and how each is treated

We offer two models. Fees are set in conversation and are not in this document. What belongs here is how each model is treated under your professional code and your state board, so your firm can choose with that in view.

Model A: Flat monthly fee

A fixed fee for operating the service. It does not depend on engagements won, fees earned or returns filed.

• AICPA Code. The fee is not paid to obtain any particular client, which supports treating it as a marketing cost rather than a referral fee under 1.520.
• State boards. A fixed fee does not depend on clients obtained, the test in California, or on your firm’s receipts, the test in New York.
• The simplest model to approve and document.

Model B: Results-based fee

A share of fees from engagements won back, measured from your CRM’s own records.

• AICPA Code. A payment to obtain a client must be disclosed to that client in writing (1.520.001 and 1.520.080).
• State boards. California bars paying a fee to obtain a client (Bus. & Prof. Code 5061). New York bars paying for client referrals and arrangements that depend on a firm’s receipts (8 NYCRR 29.1 and 29.10). Texas requires written disclosure of referral pay (Rule 501.71). Other boards differ.
• Tax records. Lane 2 results are reported only as the consent allows. Lane 1 never reaches us, so it is never part of the fee.
• Offered only where your counsel approves the structure in writing for each state you are licensed in.

15

Subprocessors and contract

Who else touches the data, and what we sign

The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor. Lane 1 records reach neither us nor any subprocessor.

What the agreement contains

• Roles and purpose — Your firm as financial institution and preparer, Tez as service provider; use limited to this engagement.
• No secondary use — No training, no sale, no reuse across clients, no enrichment, no further disclosure of tax return information.
• Security exhibit and 72-hour notice — The controls in sections 09 to 11, as binding terms.
• Consent warranty — How the leads were obtained, and which carry a section 7216 consent.
• Privacy requests — Access, correction and deletion within your deadlines, including state privacy laws for data outside the GLBA exemption.
• Audit, return and destruction — Reasonable audit and questionnaire rights; return or certified destruction at termination.

16

Regulatory map

Each rule, and where it is addressed

17

References

Every requirement, traced to its source

Each commitment in this document rests on a primary source: a statute, a regulation, a rule, a regulator’s own guidance, or a court decision. They are listed here so your firm can check our reading against the text. Links were current in October 2026.

18

Limits

What this document is not

• 01Not legal advice — Your partners and counsel decide how these rules apply to your firm. This document tells them what we do so they can. Several points — the reach of section 7216 to prospects, and results-based pay in your states — need their written view.
• 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We complete your due diligence questionnaire and provide the policies and evidence behind each control instead.
• 03Not a CPA firm or a tax adviser — Tez I Solutions does not prepare returns, give tax advice or make determinations about anyone’s tax liability. Former tax clients without a consent stay with your firm, so Tez never holds the records that would make it a tax return preparer under section 7216.
• 04Not permanent — Current as of October 2026. Rules in this area are moving — the FCC adopted new consent revocation rules on September 30, 2026, effective 30 days after publication. We review this document at least once a year and whenever a rule it relies on changes.
• 05Not a promise of results — A score says which prospects to contact first, not who will book. Until your firm’s own outcomes are recorded, the odds behind it are estimates drawn from your team’s experience.

A1

Commitments

Ten commitments, before the detail

• 01 · Your accounts, on business terms — We work only in accounts your business owns, on business plans. Never in a personal or consumer account — ours, yours or an employee's.
• 02 · A named user, never a shared password — You add us as a named user with our own sign-in and multi-factor authentication. We never ask for a shared password, and you should never send one to us by email.
• 03 · The least access that does the job — Each connection reaches only the data its workflow needs. Admin rights are used for set-up tasks, logged, and reduced afterwards.
• 04 · Nothing goes live without your approval — Every connection, workflow and set of instructions is approved by you, in writing, before it is switched on. So is every change to one that is already running.
• 05 · Automated where it is routine, a person in the loop where it is not — Routine, rule-based work can run on its own once you have approved it: sorting and tagging, summaries for your team, filing, and fixed-wording notices such as an appointment reminder from a template you signed off. Anything that needs a decision or a judgement — a reply written for a particular customer, a price, a term, a commitment, or anything your industry's page marks for review — has a person on your side in the loop before it goes anywhere. Each workflow's data sheet (A3) states which kind it is. Where your industry's page requires a person to review every customer message, that rule applies instead.
• 06 · Your data stays in your tools — We build and test inside your workspace. We do not copy your business data into Tez's own AI accounts. Where we need examples outside your tools, we use made-up records.
• 07 · Your data serves your business only — No reuse across clients, no sale, no training of anything by us. Prompts, instructions and workflows built from your material are yours and are not reused for anyone else.
• 08 · Vendor data settings confirmed in writing — During onboarding we read each tool's current data terms, set its controls with you, and give you a written record. We re-check it whenever a vendor changes its terms.
• 09 · Incident notice within 72 hours — As soon as possible and no later than 72 hours, or sooner where your industry's page says so.
• 10 · Access removed, everything handed over — At the end, our access is removed, every credential we created is revoked or rotated, and every workflow is documented and handed over. We confirm it in writing within 30 days.

Evidence on request: every control in this document has a record you can inspect, listed in section A5. If you send us a security questionnaire, we complete it during onboarding.

A2

Accounts and access

Whose accounts, and how we get in

The AI tools, the systems they connect to and the accounts that run them all belong to your business. We are given access to them; we never hold them. That is what makes the work portable: if we part ways, everything keeps running and nothing has to be moved out of our name.

Nothing in this section starts before you have decided to work with us. The first session is a conversation. We do not ask for logins, exports or files beforehand.

Who owns what

How access is set up

• 01 · You decide what we need — We list the systems and the role each one needs, and why. You agree or strike items out.
• 02 · You add us — Usually by adding us as a user, on a call where we walk through it together. A password is never sent.
• 03 · We confirm the safeguards — Multi-factor authentication on, role as agreed, sign-in recorded in the access record.
• 04 · Reviewed every quarter — We go through the access record with you and remove anything no longer needed.
• 05 · Removed at the end — Section A5 sets out how access ends.

Roles

Where a state privacy law reaches your business, we act as your service provider or processor for the access we hold, and the agreement says so.

A3

What the tools can see

Connections, scopes, and what stays out

An AI tool connected to one of your systems can see whatever that connection lets it see. An assistant that searches your files can surface anything the person using it is allowed to open — Microsoft says of its own Copilot that it "only surfaces organizational data to which individual users have at least view permissions." So the work starts with permissions, not prompts.

Before anything is connected

• Who can see what — Before an assistant is pointed at a shared drive, inbox or CRM, we review who can open what. Folders that are open to everyone but should not be are fixed first, with your approval.
• One data sheet per workflow — Every workflow gets a written sheet: what it reads, what it writes, who sees the result, and where a person reviews it. You approve the sheet before we build.
• Add-ons are vendors too — A plug-in, connector, custom GPT or agent from a third party is another company handling your data. None is installed without your approval and a record of its data terms.

What a data sheet looks like

Illustration — not real client data.

What stays out by default

Unless your written decision says otherwise, after we have shown you what the vendor's terms and your industry's rules say, these are kept out of every prompt, instruction file and connection:

• Social Security numbers, tax IDs, driver's licence and other government ID numbers
• Full bank account and card numbers
• Passwords, access codes, gate, door and alarm codes
• Health information
• Anything your industry's page (A7) marks as restricted

Where a connection would expose one of these — a folder of scanned IDs, a CRM field holding card numbers — the connection is narrowed to leave it out, or not built.

Before a workflow goes live

AI tools make mistakes. Every workflow is built on the assumption that a draft can be wrong, which is why the review step is part of the design rather than a suggestion.

A4

Model providers and training

What the vendors do with your data, and how we check

When your team or a workflow uses ChatGPT, Claude, Copilot or Gemini, the vendor processes that data under its contract with your business. Tez is not a reseller or partner of any AI vendor, and not a party to those contracts. Whether a vendor trains its models on your data, how long it keeps prompts, whether its staff can review them, and where it processes them are set by the vendor's terms and by the plan you are on. Those terms change. So we do not promise what a vendor will do. We promise what we will do.

What we do

• 01 · List every tool — Each AI tool and AI feature you pay for, the plan it is on, and who holds a seat.
• 02 · Read the current terms — For each one we record what the vendor says about training on your data, retention, human review, where data is processed, and which admin controls exist. Each entry carries the date and the address of the page we read.
• 03 · Set the controls with you — Where a tool offers a choice — training opt-outs, retention periods, chat history, which add-ons are allowed — we recommend the most protective setting that still does what you need, and you decide.
• 04 · Give you the record — The settings record is yours, in writing. Your compliance contact can file it with your vendor reviews.
• 05 · Re-check when terms change — When a vendor changes its data terms, we re-read them, update the record and tell you if anything moved. We also re-check the whole record at least every six months.

What the main vendors said when we checked

Read on each vendor's own page on 6 October 2026. This is the vendor's statement to its customers, not a commitment by Tez. If it changes, the vendor's current terms govern, and we update your record.

Consumer plans and personal accounts

Consumer plans run on different terms from business plans — Anthropic's Commercial Terms, for one, state that they do not cover its consumer offerings. We do not do business work in consumer or personal accounts, and we do not rely on a consumer plan's settings to protect business data.

Our own tools

We use AI tools of our own to write code and documentation. Your business data does not go into them. Anything we build for you is built and tested in your workspace, or against made-up records.

A5

Records, security and incidents

What we keep, how it is protected, and what happens if something fails

Records you can inspect

Records describe what we built and changed. They live in a location your business owns, and they do not contain your customers' data.

Changes to something already running

Every change to a live workflow is described, approved by you, tested, logged and reversible — the previous version is kept. If a vendor update breaks a workflow, or a workflow starts doing something it should not, we may pause it at once to stop harm, and tell you the same day. We do not change what a workflow does without your approval.

Security controls

If something goes wrong

An incident includes a workflow sending or showing data to the wrong person, a connection reaching more than its sheet allows, a suspected compromise of a Tez sign-in, and a vendor incident we learn of that affects your workspace.

• 01 · Contain — Pause the workflow, revoke the affected credential or connection, and stop the exposure.
• 02 · Notify you within 72 hours at the latest — Which systems and data, what window, what we have done. Sooner where your industry's page sets a shorter time. Updates follow as we investigate.
• 03 · Preserve evidence — Logs, the change log and the vendor's audit records are kept intact for your investigation.
• 04 · Support your notice, never pre-empt it — Whether customers or regulators are told is your decision. We never contact your customers about it. A vendor's own incident notice comes to you under your contract with that vendor.

When the engagement ends

Everything we build is yours — documented and portable. If we part ways, it keeps working and your team knows how it runs.

A6

Limits

What this document is not

• 01 · Not legal advice — Your counsel or compliance officer decides how your industry's rules apply to your business. This document tells them what we do so they can.
• 02 · Not a SOC 2 report — We do not hold a SOC 2 attestation. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
• 03 · Not the vendor — We do not run the AI vendors' systems or set their terms. Their security, retention, outages and incidents are governed by your contract with them. We are not a reseller, partner or certified provider of any AI vendor.
• 04 · Your obligations stay yours — Using AI tools does not move your duties to us: licensing, supervision, record keeping, privacy notices and your staff's use of AI remain your business's responsibility. We build to them, as your industry's page sets out.
• 05 · Not a promise about AI output — AI tools can be wrong, and confidently so. That is why anything that needs a judgement has a person in the loop, and why no workflow makes a decision your business would otherwise make.
• 06 · Not permanent — Current as of October 2026. Vendor terms and the rules on AI change often. We review this document at least once a year, and whenever a vendor term or rule it relies on changes.

A7

Accounting

What your industry's rules mean for your AI tools

An accounting firm's inbox, shared drive and practice software are full of tax return information, and federal law lets a preparer disclose or use it only for narrow reasons. An AI tool that reads those systems is handling it. So for a firm, the first question about any workflow is not what the tool can do but whether the data it would read is tax return information, and on what basis it may be shared. These are the rules that shape the answer, and what we do about each.

In practice

• A workflow may summarise new inquiries from your website form and draft a first reply for a person to send. It may not read prior-year returns to decide whom to market advisory services to.
• An assistant may answer staff questions from your firm's own procedures and templates. It is not pointed at the client tax folders on the shared drive until your counsel has confirmed the basis in writing.
• Meeting-note tools are set up so client tax figures stay in your practice software, not copied into a general AI workspace.
• During onboarding we check which AI tools staff already use with client files. If any are personal accounts, we tell you, and that use is moved or stopped before we build on it.

A8

Sources

Where these rules come from

1. U.S. Code, 26 U.S.C. 7216 and 6713 — https://www.law.cornell.edu/uscode/text/26/7216 2. Treas. Reg. 301.7216-1, definitions — https://www.ecfr.gov/current/title-26/section-301.7216-1 3. Treas. Reg. 301.7216-2, permitted uses and disclosures — https://www.ecfr.gov/current/title-26/section-301.7216-2 · Treas. Reg. 301.7216-3, consent — https://www.ecfr.gov/current/title-26/section-301.7216-3 · IRS, Section 7216 Frequently Asked Questions — https://www.irs.gov/tax-professionals/section-7216-frequently-asked-questions 4. FTC Safeguards Rule, 16 CFR Part 314 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314 5. FTC, Safeguards Rule: What Your Business Needs to Know — https://www.ftc.gov/business-guidance/resources/ftc-safeguards-rule-what-your-business-needs-know 6. IRS Publication 4557, Safeguarding Taxpayer Data — https://www.irs.gov/pub/irs-pdf/p4557.pdf 7. IRS Publication 5708, Creating a Written Information Security Plan — https://www.irs.gov/pub/irs-pdf/p5708.pdf 8. AICPA Code of Professional Conduct — https://pub.aicpa.org/codeofconduct/ethicsresources/et-cod.pdf 9. Circular 230, 31 CFR Part 10 — https://www.ecfr.gov/current/title-31/subtitle-A/part-10

• 01California Business and Professions Code 17530.5 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=17530.5.
• 02New York, 8 NYCRR Part 29 — https://op.nysed.gov/title8/rules-board-regents/part-29
• 03California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq.; California Privacy Protection Agency, threshold adjustment — https://cppa.ca.gov/regulations/cpi_adjustment.html