Client Privacy

I work from a Regus office center. (I have a private office, not a shared workspace.) I received a package today and the front desk told me they had to log it in. I found out the following:

All Fedex and UPS packages are logged.
USPS Priority Mail etc are logged, but not regular first class mail.
Information logged is sender, recipient, tracking number and where & when the package was ultimately delivered.
Anything hand-delivered by a client is, I am told, not logged.
Packages, however delivered, are not opened by the front desk.

I have a handful of clients who mail their tax information to me each year, usually by USPS Priority Mail. So the client's name and my name get linked. It seems to me that, if I allow this to continue, it is a violation of s7216. am I getting over-excited about this or do I need to consider other routes for receiving client information sent through the mail?

I am not concerned about the package received today as it was just office supplies.

I'm surprised the attorneys haven't shut this down. Perhaps they don't know about it either.

There are only two attorneys in this building and one of them uses it about two days a month. The other is retiring in a couple of weeks. He keeps his door open when he leaves his office so I'm not sure how seriously he takes privacy.

So are you saying this is a breach?

I work from a Regus office center. (I have a private office, not a shared workspace.) I received a package today and the front desk told me they had to log it in. I found out the following:

All Fedex and UPS packages are logged.
USPS Priority Mail etc are logged, but not regular first class mail.
Information logged is sender, recipient, tracking number and where & when the package was ultimately delivered.
Anything hand-delivered by a client is, I am told, not logged.
Packages, however delivered, are not opened by the front desk.

I have a handful of clients who mail their tax information to me each year, usually by USPS Priority Mail. So the client's name and my name get linked. It seems to me that, if I allow this to continue, it is a violation of s7216. am I getting over-excited about this or do I need to consider other routes for receiving client information sent through the mail?

I am not concerned about the package received today as it was just office supplies.

So to my embarrassment, I’m not aware of why this is a violation? Can you explain?


I am in the middle of actually putting my entire desktop in the cloud. There will be zero on my laptop. No excel, no tax programs etc. I value client security so at 1st read, I didn’t see anything wrong with your process. I only have maybe 10 clients who mail stuff to my office.

Southparkcpa, my concern is that somewhere there is a piece of paper, that I cannot control, that has my name and my client's name and address on it. As 7216 violations go, it is not serious. Until it is.

I see it as a violation because it identifies the client as my client. Like I said, not serious but I make a great fuss to my clients about protecting their personal information.

Southparkcpa, my concern is that somewhere there is a piece of paper, that I cannot control, that has my name and my client's name and address on it. As 7216 violations go, it is not serious. Until it is.

I see it as a violation because it identifies the client as my client. Like I said, not serious but I make a great fuss to my clients about protecting their personal information.

Why is that different from us mailing a client their tax info etc????

I actually felt like your office was safe. The mail is attended. BUT ok, i need to read 7216.

So are you saying this is a breach?

Not necessarily. I don't know.

I was just suggesting that those records probably aren't protected by attorney-client privilege, and their existence might be a problem in certain situations. I would think most attorneys would either attempt to get that shut down or find an alternative solution that isn't burdensome.

I would question why they're doing this. Is it a liability issue?

Or are they selling your data so that you can be marketed to?

One solution would be to open a PO Box or a UPS box and use that for your mailing address. If you use street indexing for PO boxes, the post office will accept private delivery service (FedEx, UPS, et al) on your behalf.

ManVsTax, getting a straight answer from anyone at Regus these days is tough. My first thought was that a Regus office somewhere in the world had an issue with packages being delivered to the front desk but not making their way to the tenant, resulting in a new policy. I have yet to find out if this is recent or if I just happened to find out today about a practice that has been going on for a long time.

Regus already has my data in convenient electronic form, so I'm not sure how much more they could collect.

I will ponder a PO Box, although I wish I didn't have to. The one closest to my office is a pain to get to - five minutes there and back, which is shorter than the time spent sitting at the traffic light to get in and out of the post office. The one closest to my house has an unfortunate ZIP code locally.

This is no 7216 violation. That they wrote the information, themselves, signals consent -- they are not required to write their address at all, let alone required by you. There is no possibility that a person who voluntarily writes their name and address on something to be mailed should have any expectation of privacy. If they did (mistakenly) have this expectation, then this would not be considered a disclosure by a tax preparer.

Agreed.
A 7216 violation is YOUR disclosure of information. By a Regus employee logging a name/address and the existence of a package, there's nothing there that is being disclosed by you at all.
This is not a disclosure of information related to a tax return.

If you're a CPA AND you have such a specialized practice that someone simply knowing a person is a client of yours suggests something sensitive in nature (i.e. bankruptcy, criminal support, etc.), a third party discovering someone is a client of yours is unlikely to rise to any kind of professional standard violation.

Thanks for the reality check, all. I suppose what prompted this is that the client pays money to USPS or whomever and, at that point, I agree that there is no expectation of privacy as it relates to the carrier. However, I do not employ those who staff the front desk. Whatever informal arrangements I put in place with them can be overridden by instructions from Regus management. Regus has changed a lot of things since the turn of the year, most of which are a violation of the lease terms.

I am persuaded that this is not a 7216 violation. That does not mean I am happy about a list being maintained by a third party. So perhaps the starting point in finding a solution with which I am happy is to think about what things would look like with my own office.

Do you like working within a Regus property? I think I'm moving to one later this year.

If they handle a package, I would fully expect them to document receiving and delivering to you as the liability would be to great otherwise. Why would you expect them to NOT document it? If the letter went through the mail, the USPS has a digital copy of the envelope and they know when it was delivered. If it went through a carrier like FedEx, they have a digital copy of the envelope / box and they maintain your signature linking it to the package.

Beagle, the local center is fine. Current staff are adequate at doing their job. We had two really good center staff until just before Christmas last year. My office is round the corner from the elevator and pretty close to the front desk. I could hear the client dropping off and hear them get back into the elevator. Most of the time, by the time the elevator reached the ground floor, the package was in my hands, which, practically speaking, obviated the need for anything to be recorded. Delivery has slowed down with the new staff.

Regus corporate has changed a lot of things since the turn of the year. They removed the fax service without telling anyone. (I know the IRS is moving towards electronic communication but, let's be honest - we're not there yet.) We came in one morning to find that 8x8 had been replaced by Ooma. So the fax service and the app just disappeared. Because the Regus-allocated 'phone lines belong to Regus, one cannot set up an Ooma account to get a record of calls or to easily access voicemails. I do get an e-mail with the voicemail as an attachment but that is cumbersome.

Regus requires that rent be paid automatically. They bill on the first of the month, for payment by the 15th, for the following month. So the rent I paid earlier this week pays me up till the end of June. I set up automatic draft when I opened my practice and, one month, they took three months worth of rent. The only solution they offered was to not pay for two months. I had just set up after losing my job. Boy, that hurt my bank balance. The mandate to pay automatically only came out last week. It was supposedly effective from May 31st but you couldn't make payment on May 15th without setting up a means of automatic payment. My bank has set me up with a basic checking account with no monthly fee, into which I will pay enough to cover the rent and any other expenses, such as postage, each month.

Your experience may vary. I am a native Scot and we can start an argument in an empty room. However, you might consider starting with a virtual office so that mail gets delivered there and you can add on a package of days for a day office. There is one large CPA firm in the rural part of the county that does that, just to meet with city-based clients. I am mulling that for when my lease expires in almost exactly a year. I may do a month to month contract for full access between January to April and day office for the rest of the year. The full access would allow me to see clients in early evening. A day office requires you to be in after 8:30 and out by 5:00. Alternatively, I may decide to see what office space is available for myself. I have 100 sq ft and I pay just under $700 per month, inclusive of utilities, internet and telephone. That also includes cleaning, but the cleaner empties my bin and, very infrequently, vacuums the floor. I am in a decent area of town but I have one of the cheapest offices in a building that is the lowest rent of all Regus properties in the city. In my center, parking is really good and it is easy to access from a couple of main roads and a highway. So, the physical location is attractive.

Thanks for the info. I'm looking at a Regus property that isn't the Regus name (Spaces) and it's just a tad different. I'm certainly in a cheaper neighborhood as I can get a private office for $400 per month (they do go up to over $1k).

In my area (Raleigh, NC) the private offices at Spaces centers have very thin dividers - almost like plastic that can be reconfigured. Is that what you will have or is it an office with “proper” walls?

For the broadly equivalent space, Spaces is more expensive than Regus, at least in Raleigh. Mind you, the Spaces centers are in the high-end parts that come with a certain cachet, if one is into that sort of thing, which I’m not. Come to that, neither are my clients. A lot of them commented on how nice the place looks. I acquired the practice of a retiring EA four years ago. The clients moved down the hill from a building that was showing its age to the newest in the complex. It is bright and welcoming when you get out the elevator. Yet when you look at the woodwork and lighting very closely, you realize how inexpensive it is.

This particular Spaces has actual walls and is in a tower in a very popular part of town for living, entertainment and healthcare but not so much for business. For whatever reason, it's the cheapest Regus has to offer in our city. During covid this neighborhood took a huge hit with restaurants and businesses closing but it's beginning to rebound sharply.