Who decides
In the first hours, someone has to choose what to shut down, who to call, and what to tell customers. If nobody owns those calls, they get made on the fly.
Managed Security & Compliance Programs
Your business may need a security program.
Who's managing yours?
Cybantage360 provides the qualified oversight, written program, employee and device protection, and ongoing documentation that small financial businesses need. Built for small teams. Priced for small businesses.
Assess · Protect · Manage · Document. Scope is set after an assessment. You don't need to share customer data to begin.
ONE COORDINATED PROGRAMFrom requirement to proof.
MANAGED
01Understand your exposureAssess
02Name your Qualified IndividualAssign
03Write the programDocument
04Put safeguards in placeOperate
05Keep the evidenceProve
A service framework. Each client's scope is set through assessment and written agreement.
Named oversight · Defined responsibilities · Evidence you can show
Why it matters
One complaint can raise questions
about your entire security program.
A customer reports identity theft. A complaint may lead to scrutiny of your safeguards, even if your business didn't cause the theft. Could you show what you've done to protect customer information?
You don't need a proven breach to face security compliance questions.
Regulators may examine whether the safeguards required for your business were in place. The cost of answering those questions can be serious for a one-, two-, or three-person firm.
The issue isn't only whether information was stolen. It's whether you can show that you met your obligations.
Could you produce the evidence?
- A current written information security program
- An assessment of customer-information risks
- Designated Qualified Individual oversight, where required
- Safeguards for employees, accounts, devices, and providers
- Records of reviews, training, corrective actions, and testing
Who files
Covered businesses must tell the FTC within 30 days of discovering unauthorized acquisition of unencrypted information on 500 or more consumers. The clock starts when your firm knows.
Who answers
Regulators, insurers, and customers will ask who was responsible. The Qualified Individual is that person, and they report to your leadership.
What you can show
Assessments, decisions, training records, and test results. Evidence is what lets you defend the choices you made.
The technical response is only part of it. The rest is whether your leadership can make, document, and defend the decisions that follow.
What we manage
The requirements are yours.
The work can be shared.
Small businesses still need people, process, and safeguards that work. Cybantage360 brings program oversight together with practical protection for employees, email, cloud accounts, and devices.
Know where you stand.
We identify which requirements apply, what customer information you hold, which systems and providers touch it, and where the gaps are. You get a ranked fix list.
A named person to lead.
We supply a Qualified Individual for your designation. They're responsible for overseeing, implementing, and enforcing your information security program.
A program that fits.
We write and maintain your program, with your responsibilities, procedures, controls, and exceptions. It isn't a template with your name on it.
Put the plan to work.
We implement or coordinate what's agreed: access controls, MFA, encryption, training, provider oversight, and testing.
Know who acts next.
We set response roles, escalation paths, and who talks to whom. Within the agreed scope, we coordinate technical responders, counsel, and insurers.
Make the work visible.
We track fixes, document decisions, keep the evidence, and report to management on program status and open issues.
Managed technology safeguards
Protect your people.
Protect the devices they use.
For a small firm, the biggest exposures often sit in an email inbox, a cloud account, or a laptop. We can deliver and oversee these safeguards as part of your managed program, with service levels matched to your systems and budget.
Security around every account.
Protect the people who handle client information and the cloud services they use every day.
- Advanced email protection: screen phishing, malicious links, impersonation attempts, and other email threats.
- Security awareness and phishing tests: give staff practical training and measure how they respond to suspicious messages.
- Exposed credential monitoring: identify employee credentials found in known compromised-data sources so they can be addressed.
- Cloud account threat monitoring: detect suspicious activity and support response to security events in supported cloud applications.
- Cloud data backup and recovery: back up and restore supported Microsoft 365 or Google Workspace data after accidental deletion, corruption, or an attack.
Security around every device.
Manage, monitor, and protect the computers employees rely on to serve customers.
- Remote monitoring and management: track device health, identify problems, and support remote maintenance.
- Operating system and software updates: manage patches, including supported third-party applications, to reduce known exposures.
- Antivirus protection: detect and block common malicious software.
- Endpoint threat and ransomware detection: investigate suspicious behavior and support containment and response.
- Encrypted device backup: protect selected endpoint data and support restoration when devices fail or files are lost.
- Optional 24/7 managed threat monitoring: add security operations review and response support where contracted.
Services are selected after assessment and listed in the agreement. Coverage depends on supported devices, cloud services, licenses, backup scope, and the level of monitoring purchased. Backup and monitoring do not eliminate the need for access controls, multifactor authentication, or client-specific procedures.
Who we serve
Four markets.
Including the providers behind them.
Each market handles sensitive information differently. We build the assessment, responsibilities, safeguards, and oversight around those differences, including third-party vendors that access, process, store, or support customer information. Your existing IT provider can stay part of the model.
01 / FINANCIAL ADVISORS & INVESTMENT SERVICES
Protect the information behind every client relationship.
Advisory and investment firms hold client identities, financial profiles, account documents, and sensitive messages. Protection follows that information through staff, custodians, portfolio platforms, and service providers.
What we help manage
- Which rules apply, based on your registration and activities.
- Access to client records, email, collaboration tools, and advisory platforms.
- Provider oversight, training, incident escalation, and evidence.
- Qualified oversight that fits your regulatory framework.
02 / TAX, ACCOUNTING & BOOKKEEPING SERVICES
Keep client protection working after tax season.
Tax returns, ID documents, payroll records, and financial statements move through staff, bookkeepers, seasonal workers, portals, and software providers. The written program has to match how your practice really runs.
What we help manage
- Risk assessment and a written information security program.
- A designated Qualified Individual for FTC-covered activities.
- Secure document handling, access reviews, MFA, and retention rules.
- Seasonal onboarding and offboarding, training, and provider oversight.
03 / MORTGAGE & LOAN SERVICING SERVICES
Protect borrower information from application through servicing.
Mortgage brokers, originators, lenders, and loan servicers handle income records, credit data, payment histories, bank information, and IDs. Safeguards must follow this information through origination, servicing, transfers, and outside providers.
What we help manage
- Assessment of borrower and loan servicing information, systems, and document flows.
- A written program and an outsourced Qualified Individual where it applies.
- Access controls for origination and servicing systems, email, remote work, and file sharing.
- Vendor reviews, corrective actions, response procedures, and reporting.
04 / FINANCIAL INTERMEDIARIES
Protect the information moving between financial parties.
Payment and transfer providers, collection services, credit counselors, and qualifying financial finders may handle or route sensitive customer information across several organizations. Each handoff needs clear responsibility and safeguards.
What we help manage
- Identify covered financial activities and customer-information flows.
- Assess permissions, data sharing, transaction systems, and outsourced services.
- Define a written program and Qualified Individual where the rule applies.
- Coordinate testing, incidents, vendor controls, reporting, and evidence.
Also serving third-party providers: IT and cloud services, bookkeeping and payroll processors, document platforms, call centers, outsourced operations, and other vendors supporting these four markets. A vendor's obligations may come from contracts, customer oversight, and other applicable laws; being a vendor does not automatically make it directly subject to the FTC Safeguards Rule. Financial and investment firms may instead fall under SEC or other regulators. We confirm applicability and service fit before engagement.
How it works
Establish it. Operate it.
Keep it current.
Define the scope
Confirm your business activities, regulatory scope, information, systems, and existing providers.
Build the baseline
Complete the assessment, designate oversight, adopt the written program, and agree on the fixes.
Manage the work
Put agreed controls in place, coordinate providers, train your people, and track open actions.
Review and adjust
Measure performance, report to management, and update the program as your risks and operations change.
Clear accountability
We manage the program.
You keep leadership oversight.
The FTC allows an outsourced Qualified Individual. Your business still owns compliance, and you must name a senior employee to direct and oversee that person.
Our agreement spells out what Cybantage360 does, what your team does, which providers are involved, and how open issues reach your leadership.
Read the FTC's Safeguards Rule guidance ↗Who's behind it
Led by Rod Andes.
Cybantage360 is a Cybantage service. Rod founded Cybantage after more than 30 years in IT, including over 15 in information security leadership. His background spans military intelligence, law enforcement, and governance, risk, and compliance.
He's the author of Surviving What Follows (Cybantage Press, 2026), on what leaders face after a security incident. cybantage.com ↗
Before you begin
Questions owners ask.
We're a small business, just one, two, or three people. Why do we need this?
Because the rule follows covered financial activities, not employee count. It can apply to a tax preparer, mortgage broker, or loan servicer with one employee. Other firms and vendors may have different regulatory or contractual duties.
FTC-covered businesses with information on fewer than 5,000 consumers are exempt from some provisions, not the full rule. Designated oversight and appropriate safeguards can still be required.
Small firms also have the least room to absorb an incident. We size the program to the work you do and the information you handle.
We provide services to financial firms. Can we use this program?
Yes. We work with technology, payroll, bookkeeping, document-processing, administrative, and other third-party service providers. We assess the information you handle, your customer contracts, and the rules that apply to your own activities. Serving an FTC-covered firm does not automatically make your company an FTC-covered financial institution, but your clients can require specific safeguards, oversight, and proof.
Can we outsource the Qualified Individual role?
Yes. Under 16 CFR § 314.4(a), the Qualified Individual can work for a service provider. We can supply a named person for your designation. You still own compliance, you still name a senior employee to oversee them, and the provider must maintain its own protective security program.
Do we have to report an incident to the FTC?
Possibly. FTC-covered businesses must notify the FTC as soon as possible, and no later than 30 days after discovery, when unencrypted customer information on 500 or more consumers is acquired without authorization. State laws and other duties may apply too. Part of the program is knowing in advance who decides and who files.
Can one written plan cover several businesses?
We use a shared framework and delivery process. But each business needs a program that fits its size, complexity, activities, and customer information. Client-specific assessments, scope, controls, and procedures are what make the framework fit yours.
Are businesses with fewer than 5,000 consumers exempt?
Partly. They may be exempt from certain provisions, not the whole Safeguards Rule. We assess what applies and document why the program is scoped the way it is.
Can you work with our existing IT provider?
Yes. We coordinate with them where it makes sense. The assessment and the contract set who implements each control, who checks it, and who owns each gap.
Does the service guarantee compliance or insurance coverage?
No. Results depend on the safeguards in place, your participation, the rules that apply to you, and ongoing performance. Insurance coverage depends on your policy terms and the facts of a claim. We provide defined work, oversight, and evidence. We can't promise immunity from incidents or enforcement.
Can you also protect our email, cloud accounts, and computers?
Yes. We can add email and phishing protection, employee training, exposed-password monitoring, cloud activity monitoring and backup, device management, patching, antivirus, threat detection, and endpoint backup. Optional 24/7 managed threat monitoring is available for an additional service level. We confirm supported systems and exactly what is included before deployment.
How is the service priced?
The proposed model includes an initial assessment and remediation, followed by ongoing program management. User and device protection can be scoped separately by the number of accounts and endpoints, the services selected, and the monitoring level required.
Your next step
Start with the business.
Then define the program.
Fill in a short brief about your business and what you need help with. Email it to us, or keep a copy for yourself.
Please don't include customer records, account details, or other sensitive information.
Prefer to talk? Call (629) 275-2770 or write randes@cybantage.com.
Assessment → Scope → Managed program