Gap Assessment

Identify where your security posture falls short of expectations
— before auditors or threats do.

How We Help

  • Two people sitting at a white table working on a project. One person is using a smartphone, and the other is writing on paper with a pen. A laptop and a monitor are on the table, and there is a notebook nearby.

    Define What You’re Actually Required to Do

    We determine which regulatory, programmatic, or contractual requirements apply to your organization—and which do not. This step eliminates guesswork and overengineering by grounding your security and compliance obligations in the standards that actually govern your operations.

  • Desk with open laptop displaying code, smartphone, coffee mug, headphones, desk lamp, and potted plant in a bright office.

    Assess What You Have Today

    We review your existing policies and SOPs to identify gaps, inconsistencies, and unsupported claims. This assessment focuses on whether your documentation accurately reflects your environment and whether it would hold up under regulatory or third-party review.

  • Two people using a laptop, one person is pointing at the screen with their finger.

    Correct and Strengthen Your Documentation

    We provide revised and aligned policies and procedures proposals that will address gaps and bring your documentation back into compliance. The result is a coherent, standards-aligned set of documents that accurately represent your controls and provide a clear path forward.

Define the Requirements

Most firms understand that they are required to safeguard sensitive information. Far fewer understand what that obligation actually requires of them, in practice, given their specific size, systems, data types, and operating model.

IRS publications, the FTC Safeguards Rule, and e-file participation requirements do not prescribe a single security model. They establish principle-based obligations that require firms to implement safeguards that are reasonable, appropriate to risk, and proportionate to the firm’s operations. The same guidance that governs a multi-office practice also applies to a sole practitioner—but not in the same way.

This distinction is routinely misunderstood. Firms often rely on generic templates, vendor recommendations, or borrowed “best practices” without first determining whether those controls are required, expected, or even relevant. The result is documentation that is either bloated with unnecessary safeguards or missing controls that are actually expected.

Provenient begins by clarifying the firm’s obligation set.

We review applicable IRS guidance, FTC requirements, and related e-file expectations and interpret them in the context of how your firm actually operates. This includes examining the types of data you handle, how that data is accessed and stored, the systems and vendors involved, the roles and responsibilities within the firm, and the realistic threat environment you face.

Through this process, we distinguish between:

  • safeguards that are explicitly required by regulation or program participation,

  • safeguards that are expected based on identifiable risk, and

  • safeguards that are optional, situational, or inapplicable.

This is not a checklist exercise. It is an act of interpretation and scoping. The goal is to establish a clear, defensible baseline that reflects regulatory intent rather than folklore.

The outcome is clarity: a defined set of security expectations that your firm can implement deliberately, explain consistently, and rely on when making future security decisions. Without that clarity, every downstream control, policy update, or review effort rests on unstable ground.

Assess the Reality

Security programs rarely fail because safeguards are entirely absent. They fail because documentation, implementation, and day-to-day practice have quietly diverged.

As firms evolve, controls are introduced informally, exceptions accumulate, vendors change, and workflows adapt to operational pressure. Remote access expands. New tools are adopted. Responsibilities shift. Yet the WISP and SOPs often lag behind these changes, updated only when prompted—or updated piecemeal without reassessing the whole.

This creates a distorted picture of the firm’s security posture. Documentation may overstate maturity in some areas while overlooking safeguards that exist but are undocumented. Policies may describe controls that are no longer enforced, or assume conditions that no longer exist. Individually, these discrepancies feel minor. Collectively, they erode credibility.

Provenient’s assessment is designed to surface that drift.

We review your WISP, SOPs, and supporting materials as an integrated system, not as standalone documents. We examine how safeguards are described, how responsibilities are assigned, and how controls are meant to operate—then compare that against how your firm actually functions today.

This includes examining:

  • how access is granted, reviewed, and removed in practice,

  • how data is handled across systems and workflows,

  • how vendors and service providers are actually used,

  • how incidents, near misses, or exceptions are addressed, and

  • how review and update obligations are carried out, if at all.

Where discrepancies exist, we document them precisely. Where safeguards are partially implemented, we distinguish between intent and execution. Where controls exist informally, we identify whether they should be formalized or deliberately excluded.

This is not a benchmarking exercise and not a pass-fail test. The objective is to establish an accurate, defensible baseline, one that reflects reality rather than aspiration, and one that can support informed decisions about remediation, documentation, and governance.

Only once reality is clearly understood can defensibility be built.

Make It Defensible

Defensibility is not a function of how many safeguards exist. It is a function of whether the security program can be understood, justified, and sustained under scrutiny.

Regulators, auditors, and reviewers do not evaluate security programs in isolation. They look for internal logic: how responsibilities are assigned, how safeguards were selected, how risks are evaluated, and how the program adapts when conditions change. Breaks in that logic are far more damaging than the absence of any single control.

In many firms, documentation undermines defensibility unintentionally. Roles are vaguely defined. Safeguards are listed without rationale. Review requirements exist on paper but lack structure or evidence. Supporting documents contradict the core WISP or introduce requirements that are never operationalized.

Provenient focuses on restoring coherence.

We restructure and update your WISP, SOPs, and supporting artifacts so they function as a single, governed system. Safeguards are clearly scoped to identified risks. Responsibilities are explicit and traceable. Review and update mechanisms are documented in a way that reflects how decisions are actually made inside the firm.

This includes clarifying:

  • who owns the security program and specific decisions,

  • how risk-based judgments are made and revisited,

  • how incidents, near misses, or operational changes feed back into the program, and

  • how supporting records reinforce, not dilute, the firm’s stated safeguards.

We are deliberate about what is included and what is excluded. Controls are not added for optics. Language is not inflated to sound “more compliant.” Every element must serve a purpose: to explain intent, demonstrate consistency, or support review.

The outcome is documentation that can withstand questions without improvisation. A program that supports annual review and management attestation without rework. And a structure that can evolve as systems, personnel, or services change without breaking its own internal logic.

That is what makes a security program defensible.

Ensure Your Continuity of Business

Engage an Expert Gap Assessment


An expert gap assessment is not about identifying every possible improvement. It is about establishing clarity: clarity of obligation, clarity of implementation, and clarity of responsibility. When those elements are defined, security decisions become deliberate rather than reactive, documentation remains coherent as the firm evolves, and review no longer depends on explanation or improvisation. Engaging an Expert Gap Assessment establishes that baseline before assumptions harden into risk.