Privacy act notification rules apply to accountants involved in litigation/family law engagements.

On or before July 1, 2001, CPAs providing financial or tax preparation services to individual clients were required to notify all such clients of their privacy policy. The Gramm-Leach-Bliley Act and related Federal Trade Commission regulations broadly define the services giving rise to such notification requirements (The CPA Letter, June, Feb./Mar.).

Practitioners involved in litigation services, and family law in particular, have access to sensitive and highly confidential personal information about their clients, as well as their client's adversary or spouse. Often, this information is subject to confidentiality agreements. Whether or not confidentiality agreements are in effect, consideration should be given to providing all individual litigation clients, especially clients involved in divorce proceedings, a copy of the firm's privacy policies. It is suggested that CPAs provide the client with information about the firm's privacy policy when a signed engagement letter is obtained. Consideration should also be given to referring to receipt of the privacy policy notification in the engagement letter.

For more information about the FTC requirements and Gramm-Leach-Bliley regulations, visit the FTC Web site at www.ftc.gov/privacy/index.html and scroll down to the "Gramm-Leach-Bliley Act." Also, visit the AICPA's Web site at www.aicpa.org to view the Member Practice Guide on Privacy Protection Provisions of the Gramm-Leach-Bliley Act and a sample disclosure notice.