The FTC Safeguards Rule requires you to designate a Qualified Individual (QI) to oversee your information security program. This individual does not need to be an employee—many organizations engage their managed service provider (MSP) or a virtual CISO (vCISO) to fulfill this role.

In practice, many firms designate:

• An external cybersecurity expert (e.g., MSP or vCISO) as the Qualified Individual responsible for managing and overseeing the security program, and
• An internal executive (such as a managing partner, COO, or CFO) who maintains organizational accountability and coordinates with the QI.

Regardless of who is designated, your organization remains ultimately responsible for compliance. The Qualified Individual must have the appropriate expertise and authority to oversee the program, and must provide regular reports, at least annually, to senior leadership.

All roles and responsibilities should be clearly documented in your Written Information Security Program (WISP), and the Qualified Individual should be prepared to support audits or regulatory inquiries if required.