CPA & ADVISORY FIRMS
Cyber governance for CPA and advisory firms
Reviewers can’t grade effort—only documented proof. Borealis builds and runs a cyber governance program for CPA and advisory firms (11–50 employees) and keeps evidence current in Aurora Command (the compliance portal). You can defend FTC Safeguards expectations and client diligence requirements without building a second program.
Respond faster with a maintained evidence set you can export.
Confidential • Built around FTC Safeguards + client diligence expectations • 30 minutes • No obligation
Built for Firm Reality, Not Single‑Framework Compliance
- Built around the real “compliance gap”: FTC Safeguards baseline and client diligence pressure
- Works alongside your MSP. No replacement, no helpdesk takeover
- Evidence-first: every requirement mapped to proof, owned, and printable/exportable on demand
- Built for the moments that matter: E&O renewals, regulator scrutiny, client due diligence, and M&A diligence
- Multi‑state friendly: one program, with clear deltas by state
Remote-friendly kickoff. Low disruption for staff.
Good fit if:
- You provide advisory services and handle sensitive client financial data
- You operate in multiple states and want one defensible program
- You want to protect valuation as partners exit or PE diligence intensifies
- You have an MSP but need governance ownership, cadence, and evidence
Not a fit if:
- You want an MSP replacement or daily IT operations provider
- You want “templates only” without operating a living program
- You only prepare a small number of seasonal returns and do not need a full governance program
What reviewers ask for
Client diligence and FTC Safeguards reviews tend to ask for the same core proof.
- A current written program with ownership and annual review
- Risk assessment + risk register (findings, owners, decisions)
- Vendor oversight (MSP and key platforms) with review notes
- Incident readiness with breach notification checklist
- Training records and policy approvals (where applicable)
- An export-ready evidence packet you can send when asked
Your MSP runs IT. Governance and evidence are a different job.
Tools reduce risk. Governance makes it defensible. Firms get squeezed because expectations come from multiple directions, and “we have security tools” isn’t proof.
The Shift
Firms are no longer just tax compliance shops. Advisory work, client expectations, and buyer diligence raise the bar for how you document security decisions and prove ongoing oversight.
The Compliance Gap
FTC Safeguards gives you a baseline. Clients and buyers add their own diligence requirements. Regulators and diligence teams expect you to know where you stand, and prove it.
What you get (deliverables)
- Written security program tailored to your operations (FTC Safeguards aligned)
- Risk register with owners, dates, and documented decisions
- Vendor oversight list + review cadence notes (including MSP and key platforms)
- Incident readiness plan + notification checklist (roles and timeline capture)
- Evidence map (what proof exists, who owns it, where it lives)
- Export-ready reviewer packet structure (including print-ready workbook exports)
Why the pressure is increasing
Regulators set the baseline. Clients bake it into questionnaires. Procurement and diligence teams repeat the questions. The pressure converges on one place: your firm.
Here’s where it hits first:
Client and Buyer Diligence
Questionnaires and diligence requests require fast, consistent answers backed by current evidence.
Fast notification windows
You don’t want to learn the window under pressure. You want checklists and roles already defined.
Valuation & timeline
Unclear applicability and weak documentation become leverage. Clean governance reduces uncertainty.
The questions you’ll get asked
The Governance Program
One operating system for governance. Clear overlays where state privacy and breach expectations apply. Evidence kept current.
Program Spine
- FTC Safeguards-aligned written program, tailored to how you operate
- Overlay alignment for applicable state privacy and breach expectations
- Governance structure: roles, approvals, documented responsibility
- Policies that match reality (not shelfware)
Risk System
- Risk assessment (annual and updated on material changes)
- Risk register with owners, dates, and treatment decisions
- Remediation roadmap that your MSP can execute without churn
Incident & Notification Readiness
- Incident Response Plan with playbooks
- Notification readiness for fast windows (with role clarity and checklists)
- Tabletop exercises with evidence that stands up to scrutiny
- “Determination worksheet” and timeline capture template
People & Vendors
- Access governance (MFA, joiner/mover/leaver, access reviews)
- Vendor inventory, minimum requirements, and review cadence
- Security awareness evidence
Can you produce evidence on demand?
Every control mapped to proof. Every proof owned. Evidence maintained continuously.
Keep evidence current in Aurora Command
Aurora Command keeps tasks, decisions, and evidence in one place so reviews don’t become a scramble. Track what’s due, assign owners, and export a reviewer packet when asked.
- See what’s due before it becomes urgent
- Assign owners so governance doesn’t live in your head
- Export clean packets for regulators, buyers, and diligence teams
COMPLIANCE PORTAL
No more spreadsheet chaos.
Borealis is the managed governance service. Aurora Command is the compliance portal that keeps your policies and evidence current. If you prefer to run the program in-house, Aurora Command can also be used self‑serve.
Nationwide Baseline and State Overlays
Aurora Command is built around the FTC Safeguards Rule baseline. State privacy and breach overlays are added as new requirements take effect, so you build once, operate once, and export to match the request.
Hover or click a state to see the summary. Overlays are highlighted so you can focus on what changes.
Licensed in multiple states?
We map once and show you what changes by state where an overlay exists, without multiplying programs.
Choose how governance responsibility is handled
Qualified Individual (QI) = the named person responsible for the security program. vCISO (virtual CISO) = ongoing security leadership without a full-time hire.
You retain the Qualified Individual (QI) internally
Best for firms with an internal Qualified Individual (QI)—the named person responsible for the security program—who can execute tasks but needs structure, cadence, and defensible evidence. Your program owner stays internal; we provide the system, evidence map, and accountability.
- We help you select the right framework
- We provide the governance model
- We help you design your policies
- Aurora Command helps you stay on track
- You remain the program owner (we provide structure + evidence mapping)
For teams who want to run the program in‑house
We serve as your QI and operate the program
For firms that want governance operated, not just assigned. We serve as your Qualified Individual, run the cadence, document decisions, and keep a clean evidence trail for renewals, questionnaires, and diligence.
- We help you establish or refresh your governance program
- We manage your daily governance model
- We serve as your Qualified Individual and provide CISO-level advisory services
- We take the stress off your hands
For teams who want full support
Advisory Track gives you the system. Managed Track gives you the system and the operator.
What happens after you book
30‑minute Program Review
We discuss firm size, services, tech stack, and current governance posture.
Scope & Proposal
You receive a tailored proposal with clear deliverables and timeline.
Build Phase Kickoff
Remote-friendly onboarding. We build the program foundation while keeping staff disruption minimal.
The Build
One-time setup. We build the governance engine.
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Program Scope Services, data types, vendor stack, MSP boundaries, advisory scope.
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FTC Safeguards-aligned Written Program Draft to final, with baseline and state overlay alignment.
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Risk Assessment Initial risk assessment and risk register.
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Evidence Map Evidence map and print-ready export structure.
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Aurora Command Setup Tasks, library, owners.
The Run
Monthly cadence. We keep you ready.
- Monthly accountability check-ins
- Evidence collection reminders
- Updates for material changes
- Guided questionnaire support
- QI/vCISO-led governance actions & oversight
- Higher-touch buyer and diligence support
- Leadership-ready reporting & decision tracking
- Diligence packaging (clean evidence trail)
Aurora turns governance work into proof.
The program is operated by Borealis, but the work lives in Aurora. That’s where questionnaires, evidence, owners, and exports stay organized so you can answer “show me” without panic.
Compliance Governance
Turn requirements into an operating system: owners, cadence, decisions, and a single source of truth.
- Track requirements (including custom)
- Assign owners and due dates
- Turn gaps into remediation
Evidence Collection
Map controls to what proves them, keep evidence organized, and export clean proof packets on demand.
- Evidence library and indexing
- Requests, reminders, and follow-up
- Print-ready packets and diligence exports
Questionnaire Prep (service-first)
We help you respond faster without sending “trust me” answers.
- Reusable response library
- Evidence-backed answers
- Clean exports for reviews and renewals
Built for real questionnaires
Upload what you have today, see what’s covered, then turn the rest into tracked requirements and remediation.
Ingest reliably
Bring questionnaires, evidence, and policies into one workspace.
See coverage
See how many questions can be drafted from your approved policies and evidence.
Review and edit
Walk through the assessment, attach evidence, and preserve human edits.
Export cleanly
Export answers and evidence as structured files and audit-ready bundles.
SEE IT WORK
Get a guided Aurora Command walkthrough
We’ll show you how questionnaires flow into requirements, how evidence stays organized, and what a print-ready workbook looks like.
FAQ
Do you replace our MSP?
No. Your MSP runs IT operations and tooling. Borealis runs the governance layer: ownership, cadence, documentation, and evidence.
Can’t I just download templates?
Templates that aren’t operated become liabilities. We build policies that match operations and create the evidence trail that proves year-round operation.
We only do tax preparation. Does this still apply?
We scope your footprint and create a defensible position based on how products are offered, licensed, and marketed.
We’re licensed in multiple states. Do we need multiple programs?
No. One operating system, with state overlays tracked and exportable.
We can’t disrupt tax season. Can we do this without chaos?
Yes. We plan around the calendar. Build in implementation season; maintain quietly during peak season; keep proof ready before January.
Do you provide legal, tax, or accounting advice?
No. We are a cybersecurity and compliance implementation firm. We help you implement defensible programs and evidence.
Can we do this without disrupting staff?
Yes. We keep staff asks small and scheduled. Most work is leadership alignment, documentation, and evidence organization, done remotely with minimal interruptions.
Do you work nationwide even though you’re Alaska-based?
Yes. The program is designed for remote execution and multi-state realities.
Ready to turn dual‑framework governance into proof?
Start with a 30‑minute conversation about your firm, your tech stack, and what “defensible” looks like for you.
Free • confidential • no obligation