AI & Data Handling Policy
Supplement to Form 7216 Consent
Incorporated by Reference into the Hopkins CPA Firm Engagement Letter
Effective Date: 01/01/2026
Version: 1.1
Document Type: Form 7216 Supplement
Owner: Hopkins CPA Firm P.C.
1. Purpose & Relationship to Form 7216 Consent
This AI & Data Handling Policy (“Policy”) supplements the Form 7216 Consent included in the Hopkins CPA Firm P.C. Engagement Letter.
It governs the Firm’s use of artificial intelligence tools—specifically Anthropic PBC (Claude AI)—when processing client tax return information.
By executing the Form 7216 Consent, you authorize the Firm to disclose your tax return information to Anthropic PBC (Claude AI) as an identified authorized party, subject to the safeguards outlined in this Policy.
This Policy:
- Does not expand the Firm’s legal obligations
- Does not create additional rights beyond applicable law and the Engagement Letter
2. Scope
This Policy applies to all services where the Firm processes client data using AI tools or integrated platforms, including:
- Individual tax preparation (Form 1040 series)
- Business tax preparation (Forms 1120, 1120-S, 1065, 990)
- Tax planning and advisory
- Bookkeeping and accounting services
- Any service involving AI tools or MCP-connected platforms
3. Regulatory Framework
The Firm complies with the following authorities:
| Authority | Relevance |
|---|---|
| IRC § 7216 & Treas. Reg. §§ 301.7216-1–3 | Governs disclosure of tax return information; requires consent |
| IRC § 6713 | Civil penalties for unauthorized disclosure |
| Rev. Proc. 2013-14 | Defines consent format and requirements |
| GLBA Safeguards Rule | Requires written data security program (WISP) |
| IRS Pub. 4557 | Security guidance for tax professionals |
| AICPA Code § 1.700 | Confidential client information standards |
4. Authorized Parties
The following entities are authorized under your Form 7216 Consent:
4.1 Anthropic PBC (Claude AI — Team Plan)
- Role: AI assistant for research, drafting, and analysis
- Use: Always under Firm supervision
- Terms:
- Inputs/outputs not used for model training
- No BAA or zero-retention agreement
4.2 Zoho One (Integrated Platform)
- Role: CRM, document storage, workflow system
- Integration: Connected to Claude via MCP Connector
- Terms: Standard Data Processing Addendum (DPA)
5. Key Definitions
| Term | Definition |
|---|---|
| Tax Return Information | All data used for tax preparation (e.g., SSNs, W-2s, K-1s) |
| Disclosure | Making information available to third parties, including AI tools |
| AI Tool | Machine learning software used for processing data |
| MCP Connector | Integration allowing controlled data exchange between systems |
6. Data Protection Practices
6.1 No Disclosure Without Consent
No tax return information is shared without:
- Valid Form 7216 Consent, or
- A legal exception
6.2 Specific Consent Requirements
Consent must:
- Identify Anthropic PBC explicitly
- Define purpose and data categories
- Meet Rev. Proc. 2013-14 requirements
6.3 Data Minimization (Sanitization)
The Firm removes sensitive identifiers before using AI tools, unless required:
- SSNs
- EINs
- Addresses
- Account numbers
6.4 Access Controls (MCP Governance)
- Role-based permissions
- Logged data access
- Quarterly review of permissions
6.5 Vendor Protections
- AI inputs/outputs are not used for training
- No BAA or zero-retention agreements
6.6 Prohibited Data (Never Entered into AI Tools)
- Full SSNs, EINs, ITINs
- Government ID numbers
- Bank or payment card numbers
- HIPAA-protected health information
- Credentials, API keys, or passwords
7. Data Retention
| System | Retention Period | Notes |
|---|---|---|
| Zoho Client Files | Minimum 7 years | Firm-controlled storage |
| Claude AI | Per vendor terms | No training usage |
| Email & Messaging | Per Firm policy | Encrypted when required |
8. Security Incident Response
In the event of a data security incident, the Firm will:
- Contain and investigate the issue
- Engage IT and legal experts
- Notify affected clients and regulators (as required)
- Provide remediation guidance
9. Client Rights
You have the right to:
- Request your Form 7216 Consent
- Revoke consent (prospectively)
- Opt out of AI usage
- Ask questions or request clarification
📧 Contact: Info@HopkinsCPA.Tax
10. Important Disclosures
- This Policy is informational, not contractual
- It does not guarantee outcomes
- Practices and tools may change over time
- Material changes require updated consent
11. Client Acknowledgment
By signing the Form 7216 Consent, you confirm that:
- You have received and reviewed this Policy
- You understand its terms
- You authorize the use of Anthropic PBC (Claude AI) as described
Contact Information
Hopkins CPA Firm P.C.
6262 Weber Rd STE 101
Corpus Christi, TX 78413
📧 Info@HopkinsCPA.Tax
📞 361-360-3855
