Security Program

Physical Security

• Badge access to locked facilities.
• Controlled access to all areas where confidential information is stored.
• 24/7 fire and burglar alarm monitoring.
• Camera surveillance throughout the operations facility.
• Visitor sign in, temporary badge, and escort while on site.

Data Security

• Logical application and data access controls.
• Regular and frequent penetration tests.
• Information security program review by third-party.
• Firewalls and IDS/IPS systems for intrusion detection and prevention.
• Encrypted email exchange.
• Real-time virus and malware scanning.
• Ongoing patch and vulnerability management.
• Data transmissions through encrypted channels.
• 24-hour on-call access to IT personnel.

Cash Handling Security

• All mail is opened within view of the surveillance cameras.
• Dual access and sign off controls.
• Leading-edge "smart safe" to securely and accurately handle cash transactions.
• The smart safe is the same type of currency counter used in the cash processing centers of banks and armored carriers.
• The smart safe verifies the currency, checks for counterfeits, and automatically tracks the cash deposit.

Gramm-Leach-Bliley Act (GLBA) Privacy Compliance

• Criminal background and consumer credit checks on all employees.
• Signed confidentiality agreements with all employees.
• Clean desk policies.
• Mandatory annual security training for all employees.
• Comprehensive GLBA Risk Assessment.
• Multi-factor authentication of non-public client information.
• Third-party confidentiality agreements.
• Vendor review and management.

Compliance Programs

• Extensive internal audit program.
• Annual SSAE 16 (SOC1), formerly SAS 70 Type II Audits.
• Regulatory examinations by the FDIC and other governmental agencies.

Business Continuity Planning

• Comprehensive contingency plan for all operational departments.
• Annual testing program.
• Regularly scheduled data replication to the recovery site.

Disaster Recovery Site

• Data replication.
• Internet services including web, email, and FTP hosting.
• Remote access and other computer services.