Your dealership is constantly changing. You upgrade software, hire new employees, and adjust your processes to stay competitive. Each of those changes affects how customer information is collected, stored, and protected.
That is why the FTC Safeguards Rule requires every dealership to keep its information security program current. Staying current means keeping your safeguards up to date with your technology, people, and operations.
What It Means
Keeping your program current means reviewing and updating your information security plan on a regular schedule.
You should review your program at least once a year, and any time you make a change that could affect how customer data is handled. This includes:
- Installing new software such as a CRM, DMS, or accounting platform
- Working with new vendors or service providers
- Adding or removing employees with system access
- Moving to a new facility or changing network equipment
- Updating policies or hardware
Each change can introduce new risks. Your Qualified Individual should document those changes, update your risk assessment, and adjust your safeguards or employee training as needed.
A current program reflects your dealership’s real environment. It ensures that what is written on paper matches how your business operates day to day.
Why It Matters
Cyber threats evolve as quickly as the tools used to stop them. A security measure that worked last year may no longer be effective today.
Keeping your program current protects your dealership from new vulnerabilities that appear when systems or staff change. It also helps you stay compliant with lender and manufacturer expectations, many of which now require proof of ongoing security updates.
Regulators want to see that your dealership treats cybersecurity as an active process. A program that has not been reviewed or updated in years is a clear sign that compliance has fallen behind.
Updating your program regularly also saves time and money in the long run. Small updates are easier and less expensive than large corrections after a problem occurs.
Example from a Dealership
A dealership recently switched to a new CRM system that offered better reporting and integration with their website. During the transition, the Qualified Individual reviewed how customer data moved through the new platform.
The dealership updated its written policies, adjusted employee access levels, and provided quick training sessions on handling customer data safely. These steps were documented in the compliance binder.
When an auditor later asked how the dealership ensured customer information stayed protected during technology changes, the report and training records provided clear proof.
How to Keep Your Program Up to Date
- Review Annually: Schedule a full review of your security program each year, even if no major changes occurred.
- Update After Changes: Revisit your program whenever you add new software, vendors, or staff.
- Document Everything: Keep written notes of what changed, why it changed, and how your safeguards were adjusted.
- Reassess Risks: If something new affects how customer data is handled, update your risk assessment.
- Train as Needed: Make sure employees understand new procedures or systems that involve customer information.
If you work with a Managed Security Service Provider (MSSP), they can help track these updates and provide reports to prove that your program remains compliant and effective.
The Bottom Line
Keeping your information security program current shows that your dealership takes compliance and customer protection seriously. It prevents outdated safeguards from creating new vulnerabilities and builds long-term trust with your customers, lenders, and partners.
Regular updates are not just about meeting FTC requirements. They are about maintaining a strong, secure, and responsible dealership operation that adapts to change.
If your dealership needs help reviewing or updating its program, Safer Dealer can connect you with experts who understand automotive systems and FTC compliance requirements.
Your dealership changes every day—your safeguards should too.