The FTC Safeguards Rule: Information Security Program Elements

This article describes the elements of an information security program under the Federal Trade Commission Final Rule regarding Standards for Safeguarding Customer Information (the “FTC Rule”). While the effective date of the FTC Rule was January 10, 2022, certain information security program elements become effective as of December 9, 2022. This article also highlights differences between the FTC Rule information security program elements with counterparts under the New York State Depar