What Is a Written Information Security Program (WISP)?
A Written Information Security Program (WISP) is a formal, organization-wide document detailing how a business safeguards sensitive information, such as customer data, financial records, and personally identifiable information (PII). Unlike system-specific documentation like a System Security Plan (SSP), a WISP provides a holistic, policy-driven approach—governing how the entire organization manages and enforces security practices across all systems and personnel.
WISPs are mandated under several federal and state regulations, including:
- Gramm-Leach-Bliley Act (GLBA) and the FTC Safeguards Rule
- HIPAA for entities handling protected health information (ePHI)
- State privacy laws such as Massachusetts 201 CMR 17.00,New York DFS 500, and California’s CPRA
An effective WISP demonstrates organizational commitment to information security and compliance, making it essential during audits, regulatory reviews, cyber insurance assessments, and breach investigations.
Who Should Implement a Written Information Security Program (WISP)?
Organizations that handle sensitive, financial, health, or personal data—whether by law or contract—are often required to maintain a WISP. Below are the most common triggers and sectors where a WISP is essential.
WISP Requirements Under GLBA
Financial institutions—including lenders, CPA firms, credit unions, and fintech companies—must implement a WISP to comply with the FTC Safeguards Rule, part of the Gramm-Leach-Bliley Act (GLBA).
HIPAA-Covered Entities
Healthcare providers and business associates handling electronic protected health information (ePHI) are legally required to maintain a formal information security program under HIPAA.
State-Specific Mandates
States like Massachusetts, New York, and California explicitly require WISPs under laws such as 201 CMR 17.00, NY DFS 500, and the California Privacy Rights Act (CPRA).
Cyber Insurance Policyholders
Many cyber liability insurance providers now mandate documented security policies—including a formal WISP—as a prerequisite for coverage and claims approval.
Vendors in Regulated Supply Chains
Third-party service providers with access to client data often face contractual obligations to implement a WISP as part of vendor due diligence and regulatory compliance.
Other Data-Handling Businesses
Any organization that collects, processes, or stores personally identifiable information (PII) or nonpublic personal information (NPPI)—even if not directly regulated—should consider implementing a WISP to reduce risk, meet best practices, and align with vendor or client expectations.
WISP Compliance Checklist: What Should It Include?
A compliant Written Information Security Program (WISP) should include the following foundational components. These align with GLBA, HIPAA, and state-level mandates—and serve as a practical template for regulated businesses, SMBs, and service providers.
- Purpose and Scope: Define the objectives of the WISP and identify where and how it applies across systems, users, and data types.
- Data Classification: Identify, label, and categorize sensitive data such as Personally Identifiable Information (PII), electronic protected health information (ePHI), and Nonpublic Personal Information (NPPI).
- Risk Assessment: Describe how risks to data and systems are identified, evaluated, and documented—including threats, vulnerabilities, and likelihood.
- Access Controls: Outline role-based access, user authentication protocols, and least privilege enforcement. Include Multi-Factor Authentication (MFA) standards.
- Physical and Technical Safeguards: Document security technologies such as firewalls, encryption, endpoint protection, intrusion prevention systems (IPS), and facility access controls.
- Security Awareness Training: Define how employees are trained on phishing, social engineering, secure data handling, and acceptable use policies.
- Vendor Risk Management: Explain how third-party vendors are evaluated, onboarded, and monitored—including contract requirements and breach notification processes.
- Incident Response Plan (IRP): Include procedures for detecting, containing, escalating, and reporting cyber incidents or data breaches.
- Data Retention and Disposal: Set rules for how long sensitive data is retained and define secure disposal procedures for physical and digital records.
- Monitoring and Testing: Outline how the WISP will be validated—via regular audits, vulnerability scans, penetration tests, and other assessments.
- Enforcement and Sanctions: Specify consequences for noncompliance with WISP policies, including disciplinary measures.
- WISP Maintenance and Review: Assign ownership for the WISP and define how frequently it will be reviewed, updated, and re-approved.
💡 Tip: Consider using this checklist as a working table of contents for your actual WISP document.
Benefits of a Well-Developed WISP
Beyond meeting regulatory requirements, a well-developed WISP brings long-term operational, legal, and reputational benefits across the organization.
- Regulatory and Legal Compliance: Aligns with GLBA, HIPAA, FTC Safeguards Rule, and state-specific mandates to avoid fines and legal exposure.
- Risk Mitigation: Reduces the likelihood and severity of data breaches, security incidents, and audit penalties.
- Governance Clarity: Defines roles, responsibilities, and procedures—promoting consistent security practices across departments.
- Cyber Insurance Alignment: Demonstrates proactive risk management to insurers, improving eligibility and potential premium outcomes.
- Vendor Trust: Shows clients and partners that your organization meets security expectations in procurement and third-party risk reviews.
- Internal Accountability: Reinforces security culture through training, enforcement mechanisms, and clearly documented policies.
- Breach Investigation Support: Provides evidence of due diligence in the event of regulatory inquiries following an incident.
- Operational Efficiency: Streamlines processes like employee onboarding, vendor assessments, and compliance reporting.
📌 A WISP is not just a security document—it’s a strategic asset for building trust, proving compliance, and minimizing risk.
How to Create a WISP: Step-by-Step Guide
Whether you’re building your first WISP or refining an outdated one, this step-by-step process will help ensure your documentation meets both regulatory and operational standards.
- Conduct a Risk Assessment
Identify the systems, applications, data types, threats, and vulnerabilities within your organization. Document findings to inform policy development. - Inventory and Classify Data
Create a data map to understand where sensitive information lives (on-prem, cloud, third-party). Classify data by sensitivity—PII, ePHI, NPPI, etc. - Draft Core Policies
Start with the foundational elements: access control, incident response, employee training, and vendor risk management. These anchor your WISP. - Document Operational Procedures
Write supporting SOPs (e.g., user onboarding/offboarding, remote access, password resets) to standardize how policies are executed in daily operations. - Assign Roles and Responsibilities
Designate accountable individuals or teams, such as a Data Security Coordinator or Data Protection Officer (DPO), for ongoing WISP oversight. - Align with Regulatory Requirements
Cross-reference relevant laws such as the FTC Safeguards Rule (GLBA), HIPAA, IRS Publication 5708, and state-specific data protection laws to ensure coverage. - Train Staff Continuously
Incorporate security awareness into onboarding and conduct periodic refresher training. Track participation to demonstrate compliance. - Plan Review and Update Cycles
Schedule annual reviews and trigger-based updates (e.g., new systems, regulatory changes, breach events). Maintain version control and approval logs.
💡 Pro Tip: Treat your WISP as a living document—not a one-time deliverable. Build review cycles into your compliance calendar.
Maintaining Your WISP
A WISP is not a one-time project—it requires ongoing maintenance to remain effective, compliant, and aligned with current threats and business processes. Here’s how to keep your WISP up to date:
- Conduct Annual and Event-Driven Reviews
Schedule annual WISP reviews and conduct immediate updates following major changes (e.g., new infrastructure, regulatory updates, data breaches). - Update Policies Based on Regulatory and Threat Changes
Monitor evolving compliance requirements (e.g., FTC Safeguards Rule updates, state privacy laws) and cybersecurity trends to keep your WISP current. - Maintain Version Control and Change History
Document each WISP update with version numbers, change logs, and approval records. This demonstrates due diligence during audits. - Log Incidents and Link to Incident Response Plan (IRP)
Record security incidents, including outcomes and lessons learned, and use them to refine your IRP and related WISP components. - Ensure Continuous, Documented Training for Staff
Provide regular security awareness training and track participation to validate organizational readiness and regulatory compliance. - Assign Ownership for WISP Maintenance
Designate a responsible individual or team (e.g., Data Security Officer, CISO) to oversee WISP updates, coordination, and review cycles.
🛡️ Maintaining your WISP is just as important as creating it. Regulators, auditors, and insurers expect evidence of ongoing oversight and adaptability.
Tools to Simplify WISP Management
Creating and maintaining a Written Information Security Program (WISP) can be resource-intensive—especially for small security teams or organizations navigating complex compliance environments. Fortunately, a range of software platforms and templates can help streamline the process from start to finish.
Here are some categories and examples of tools that can simplify WISP management:
📋 Policy & Documentation Builders
These tools offer guided workflows and editable templates to help you draft WISP policies and supporting documents.
- WISP Builder
A dedicated platform for creating customizable WISPs, including preloaded templates and dynamic forms. Ideal for small businesses or service providers needing a quick start. - Conformio
A compliance documentation toolkit designed for ISO 27001, but adaptable for U.S. privacy and cybersecurity frameworks. Includes templates, workflows, and cloud storage. - OneTrust Policy Management
Enterprise-grade platform offering centralized management of data privacy and security policies, including version control and workflow automation.
🧰 GRC Platforms (Governance, Risk, and Compliance)
These provide a broader view of organizational risk and often include WISP functionality as part of their cybersecurity compliance modules.
- Ostendio
Designed for high-trust industries like healthcare and finance, Ostendio offers live collaboration, policy approval workflows, and auditor-ready reporting. - Drata or Vanta
Primarily known for SOC 2 and ISO 27001 automation, these tools can support WISP documentation through customizable policy libraries and continuous monitoring.
📂 Secure File Repositories & Version Control
If you prefer a manual WISP build with lightweight tooling, consider using:
- Notion or Confluence
Useful for building living documents with internal links, version tracking, and collaborative editing. - SharePoint or Google Workspace
Enable secure access, permissions, and version control for storing and sharing WISP documents across teams and auditors.
🛡️ Office Heroes WISP Readiness Bundle (Premium Clients)
- Custom WISP co-development
- Risk & compliance automation
- Role-based training and attestation
- Real-time change detection and reporting
Ideal for CPA firms, credit unions, and regulated SMBs.
🛠️ Looking to get started fast? Download our [WISP Compliance Checklist] or use it alongside these tools to jumpstart your documentation process.
💡 Pro Tip: Choose a tool based on your organization’s size, regulatory scope, and internal resources. For example, a fintech startup might benefit from Compliance Manager GRC, while a nonprofit may prefer a lightweight solution like WISP Builder.
FAQs: Written Information Security Program (WISP)
❓ Is a WISP required by law?
Yes. A WISP is legally required for organizations subject to regulations such as the Gramm-Leach-Bliley Act (GLBA), HIPAA, and state-level mandates like Massachusetts 201 CMR 17.00, New York DFS 500, and California’s CPRA. It is also commonly required by cyber insurance providers as part of security due diligence.
❓ What’s the difference between a WISP and a security policy?
A WISP is a comprehensive, organization-wide program that includes multiple policies, procedures, and operational controls related to data protection. A security policy, by contrast, typically addresses a specific area (e.g., access control or acceptable use) as part of the broader WISP.
❓ Do I need a WISP if I use a cloud provider?
Yes. Even when using cloud services, your organization remains responsible for securing sensitive data under most privacy and cybersecurity regulations. Cloud providers handle infrastructure, but data protection, access controls, and compliance documentation remain your responsibility.
❓ How often should I update my WISP?
You should review and update your WISP at least annually, and also after any of the following:
- A significant change in IT systems or infrastructure
- A major regulatory update (e.g., FTC Safeguards Rule changes)
- A security incident or data breach
- A new business process involving sensitive data
❓ What are the risks of not having a WISP?
Failing to implement a WISP can result in:
- Increased breach liability and reputational harm
- Regulatory penalties or failed audits
- Cyber insurance claim denials due to lack of formal controls
- Vendor and client distrust
WISPs serve as both a compliance defense and a proactive risk mitigation tool.
Conclusion
A well-maintained Written Information Security Program (WISP) is more than a compliance document—it’s a strategic asset for cybersecurity governance, legal defensibility, and stakeholder trust.
Whether required by regulators or expected by clients, your WISP should act as a living blueprint for how your organization protects sensitive data across people, processes, and technology.
By keeping your WISP aligned with GLBA, HIPAA, FTC regulations, and evolving state privacy laws, your organization can:
- ✅ Avoid fines, penalties, and audit failures
- ✅ Improve breach response readiness and resilience
- ✅ Satisfy vendor and cyber insurance security requirements
- ✅ Demonstrate maturity and accountability in data protection
🎯 Need help creating your WISP?
Download our [WISP Compliance Checklist] or get in touch to accelerate your documentation process.
Last updated: April 2025
📌 Bookmark this guide for quarterly reviews or use during compliance audit prep.
