Auxiliary Software Consents
Your informed consent is important
Our Auxiliary Software Consents are just one of the ways we ensure you’re informed bout the tax return preparation process. As an onboarding client (and every year during re-engagement), we disclose to you the tech stack we use when preparing your Individual Tax Return.
Before we can get started on your tax return, we need your consent.
The information we include on the disclosure itself is relatively minimal. This is on purpose, so you’re not overwhelmed by information. It also helps us meet our requirements of the disclosure itself.
We recognize some people (maybe even you!) may want a bit more information about the software we’re using and why we’re using it. We’ve included significantly more details here.
What are these details, and why am I reading about them?
We understand some people may want to know and have more information about the software we’re presenting to you in our Auxiliary Software Consents. This expanded information will go into detail about how we use each piece of software, how it interacts with other software (if and as relevant) and how you may be impacted if you do not opt in to us using certain software.
Each page of the Auxiliary Software Consent is grouped a little bit differently so you can scan through the software in a different manner and have a better idea of how the different software is being used.
Why do you use so damn much software?
The software Crayon Advisory, LLC has selected for use keeps systems, returns, and Megan moving. We’ve selected software that’s flexible, useful, and supports multiple needs and goals of the firm.
In theory, we could decide to use a smaller tech stack by using All-In-One Firm Management software that comes with a CRM, Project Management, and a portal for our clients. While this sounds super slick, we’ve found these All-In-One tools just don’t stack up to our needs, or those of our clients.
We believe it’s better to use the software that’s fit for the job rather than forcing the job to fit how the software wants it done.
What happens if I don't consent to one or more pieces of software?
The implications of not consenting to a specific piece of software are dependent on the software you do not opt-in to as well as how that software fits into Crayon Advisory’s ecosystem. In some instances, you won’t experience any impact, either directly or in the services you receive. In others, there may be a significant impact to how we provide you with services, including but not limited to charging an additional fee as a result of additional time and care necessary to provide to your tax return.
If you do not consent to one or more of the Auxiliary Softwares we use and this will impact our ability to provide services to you, we will reach out to you as soon as we’re able to inform you of the consent you did not provide and the direct and immediate consequences.
We may charge an additional fee if you do not consent to the use of a specific piece of software. That fee may be significant, espeically if that piece of software is one we generally consider Necessary.
What happens after I give consent to use Auxiliary Software?
After you’ve completed the form, we’ll receive a notification and determine next steps for you based on your current needs:
- If you’re a new client, we’ll invite you to our portal and continue the onboarding process. This usually happens within two or three business days of receiving your consent;
- If you’re a returning client with an expired Auxiliary Software Consent (i.e. you’ve only granted consent through a specific date and that date is approaching or has passed), we’ll move forward with the re-engagement process;
- If you’re a returning client with an unexpired Auxiliary Software Consent (i.e. you checked the box to keep/allow the consent until one or the other of us revokes it), you likely won’t experience anything different.
How do you control access to your Auxiliary Software and my information?
We are a very small firm of one practitioner and (sometimes) one IT/Office Manager as a consultant. We do not outsource, hire out, or contract client work to anyone else. AS of right now, we do not have any employees. Because of their role, IT support does have access to all information and systems so they can provide the services they need to provide. IT follows best practices and does not access information they don’t need to. In other words: they’re looking at the back end of systems, not at your data.
We review our systems annually to ensure they are reset for the new year with any changes that impact the use of your data implemented. We test our systems during this reset, once inside of tax season, and again in May/June to ensure they are behaving as expected.
Will you provide me with updates if you change the software you're using?
If we start using new or additional auxiliary software, we will obtain your consent prior to using it.
If we’re dropping a piece of software and not replacing it, we generally won’t inform you of the decision. We don’t need your consent to stop using software, only to start using software.
As an example, in 2023 we started using RightSignature as our Knowledge Based Authentication (KBA) software in the middle of tax season, after we had already obtained Auxiliary Software Consents from most of our clients. It was an unfortunate necessity that caused each individual client esigning their tax return(s) to need to consent to the use of the software prior to using it.
What is PII, and why does it matter?
PII is, “Personally Idenitying Information.” It’s information that can be linked back to you directly, including but not limited ot your name, address, and email address.
We generally consider PII to be one of two types: Sensitive and Non-Sensitive.
Sensitivie PII is generally considered your social security number, full name, bank account number, birthday, and/or financial information when connected with and to each other. Additional PII may include, but is not limited to:
Your email address
Address(es) of Rental Properties
Other and more information
Like any other tax professional, we do use third party software to manage and maintain your relationship with us and the services we’re providing to you. In doing so, some of your PII will be used in that third party software. We limit that to the bare minimum necessary.
When working with us, we only use and disclose what we need to where, when, and how we need to. As part of our annual software review, we also look at the data connections that may have been made in the past and break anything that has become unnecessary.
What happens if I don't consent to giving my consent electronically?
The first step to obtaining your consent is for you to consent to giving your consent electronically. I know, it’s weird. It’s still what we have to do.
If you do not wish to give your consent electronically, you will need to leave some amount of information on the form so we know who you are and we can reach out to you directly and request your consent in another manner. Please note: if we do not have a name and a method of contact, we cannot reach out to you, and you will need to reach out to us. The Auxiliary Software Consent does include instructions as to how to reach out to us in the event you do not wish to give your consent electronically.
How do I know my wishes (consent) are being followed?
We are a consent based practice, and do not do things (take action) without your consent. We lean into automations that are based on these consents so we can reduce if not completely eliminate humane error. Part of those automations are tagging your account with your consent(s) so we can move your information as appropriate.
If you do not consent to one or more pieces of software, we will reach out to you directly to explain the alternative process(es) we will use to provide you with services as well as the fee for choosing not to opt-in to the software you have not consented to.
Terms & Definitions
There’s a whole lot of words throughout this FAQ that may also be used when we communicate with you during our relationship. Please be generous with these definitions and recognize these are provided to facilitate communication and may not be a complete and total definition.
Auxiliary Software – software we use in providing services to you that is not our tax return software. Our understanding of IRC 7216 is that we have a responsiblity to disclose the software we’re using to you and obtain your consent to make use of the software and tools for your benefit. Our disclosures are prepared in good faith to exist within the guidelines of this code section and any relevant Treasury Regulations, Revenue Procedures, IRS FAQs, and other guidance or information provided by the IRS/Department of Treasury. In selecting this software, we consider security and functionality – i.e. the software’s ability to meet the intended purpose – before anything else.
Documentation – We are required to gather information from you to prepare your tax return. WE are also required to maintain a record of that documentation for a period of time after the completion of your tax return.
Document Retention – Generally speaking, we are required to maintaint he doucmentation for any return we prepare for a minimum period of three (3) years after the return is filed (four (4) years for returns which include a California tax return). For non-currect clients, once the documentation reaches this age, it becomes eligible for purging from our records. We purge our records approximately twice per year, in May and again in November/December.
Due Diligence – We are required to perform certain due diligence procedures by the IRS and other authorities. In some instances, we will perform additional due diligence as guided by best practices for and within our industry. WE are required to maintain records of that due diligence and do so according to requirements and our record retention policies.
Non-Sensitive PII – Non-Sensitive PII includes information which may be available through Open Source Intelligence (OSINT), such as a Google Search. Non-sensitive PII may include your name, email address, rental property address(s), place(s) of work, birthday, occupation, and other or more information.
PII/Personally Identifying Information – PII or Personally Identifying information may be used to identify you from another person.
Sensitive PII – Information which should not ever be public information. This includes your social security number, financial information, bank account number(s), and your full name (first, middle, last), especially when any of the specified Sensitive PII is associated together.
We reset all of our systems and software every year in the latter half of October, November, and sometimes even into December. During this reset, some software selections may be in flux.
This post has been developed as a generic explanation of Auxiliary Software Consents and how Crayon Advisory, LLC handles them. This information is written to be informative and is not tax advice. You should consult with your tax advisor as to how this information applies to your situation. Your specific needs may vary and may cause specific attention to need to be given to your processes. You should speak with your tax professional regarding the applicability of these issues to you and your business (and, yes, that includes Crayon Advisory if you are a current or onboarding client).