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#46: Cash in the Cyber Sheets - FTC Safeguards Checklist - Monitor, Review, & Test Controls

Season #1

Welcome back to Cash In the Cyber Sheets. This episode is a continuation of our FTC Safeguards Rule Checklist for Compliance series, and we’re diving into a part of the Safeguards Rule that too many companies overlook until it’s too late: ongoing monitoring and testing.

In this episode, we break down § 314.4(d) of the FTC Safeguards Rule—what it actually requires, what regulators expect, and how to move from "set it and forget it" to "set it, test it, monitor it, and update it." Spoiler alert: hope is not a strategy, and ignorance is definitely not compliance.

We’ll explore:

  • What counts as "regular testing" and how often it’s required

  • The difference between vulnerability assessments and penetration testing (yes, you need both)

  • How to build a proactive, risk-based monitoring program that aligns with real-world threats

  • And how to ensure your security program doesn’t just exist on paper—but actually works

If you're serious about protecting sensitive data and staying on the right side of regulators, this is one episode you don’t want to miss.

🔍 Download our FTC Safeguards Rule Checklist Infographic to follow along and track your compliance progress step-by-step.

Also, check out our companion article at:

FTC Safeguards Rule Checklist Compliance Series: Monitoring, Reviewing, and Testing Controls