Information Security Policy

  

The protection of customers’ financial and personally identifying information is the highest priority of Paymaster Exchange, Inc. (“Paymaster Exchange”). The integrity of security protocols and strict compliance with governing regulations are regularly evaluated to ensure the protection of sensitive information. The objectives of this comprehensive written information security program ("WISP") include defining, documenting, and supporting the implementation and maintenance of the administrative, technical, and physical safeguards Paymaster Exchange has selected to protect the personal information it collects, creates, uses, and maintains. This WISP has been developed in accordance with the requirements of the Massachusetts Data Security Regulation [201 Code Mass. Regs. 17.00], the Gramm-Leach-Bliley Act [15 USC 6801(b) and 6805(b)(2)], the Federal Trade Commission [16 CFR Part 314], and other similar US state laws. In the event of a conflict between this WISP and any legal obligation or other Paymaster Exchange policy or procedure, the provisions of this WISP shall govern, unless the Information Security Coordinator specifically reviews, approves, and documents an exception (see Section 3).

1. Purpose. The purpose of this WISP is to:

(a) Ensure the security, confidentiality, integrity, and availability of personal [and other sensitive] information Paymaster Exchange collects, creates, uses, and maintains;

(b) Protect against any anticipated threats or hazards to the security, confidentiality, integrity, or availability of such information;

(c) Protect against unauthorized access to or use of Paymaster Exchange-maintained personal [and other sensitive] information that could result in substantial harm or inconvenience to any customer or employee; and

(d) Define an information security program that is appropriate to Paymaster Exchange's size, scope, and business; its available resources; and the amount of personal [and other sensitive] information that Paymaster Exchange owns or maintains on behalf of others, while recognizing the need to protect both customer and employee information.

2. Scope. This WISP applies to all employees, contractors, officers, and directors of Paymaster Exchange. It applies to any records that contain personal [and other sensitive] information in any format and on any media, whether in electronic or paper form.

(a) For purposes of this WISP, "personal information" means either a US resident's first and last name or first initial and last name in combination with any one or more of the following data elements, or any of the following data elements standing alone or in combination, if such data elements could be used to commit identity theft against the individual:

(i) Social Security number;

(ii) Driver's license number, other government-issued identification number, including passport number, or tribal identification number;

(iii) Account number, or credit or debit card number, with or without any required security code, access code, personal identification number, or password that would permit access to the individual's financial account, and any personally identifiable financial information or consumer list, description, or other grouping derived from personally identifiable financial information, where personally identifiable financial information includes any information:

(A) A consumer provides Paymaster Exchange to obtain a financial product or service;

(B) About a consumer resulting from any transaction involving a financial product or service with Paymaster Exchange; or 

(C) Information Paymaster Exchange otherwise obtains about a consumer in connection with providing a financial product or service;

(iv) Biometric data collected from the individual and used to authenticate the individual during a transaction, such as an image of a fingerprint, retina, or iris; or

(v) Email address with any required security code, access code, or password that would permit access to an individual's personal, medical, insurance, or financial account. 

(b) Personal information does not include lawfully obtained information that is available to the general public, including publicly available information from federal, state, or local government records.

(c) For purposes of this WISP, "sensitive information" means data that:

(i) Paymaster Exchange considers to be highly confidential information; or

(ii) If accessed by or disclosed to unauthorized parties, could cause significant or material harm to Paymaster Exchange, its customers, or its business partners.

(iii) Sensitive information includes, but is not limited to, personal information.

3. Information Security Coordinator. Paymaster Exchange has designated the President/CEO to implement, coordinate, and maintain this WISP (the "Information Security Coordinator"). The Information Security Coordinator shall be responsible for: 

(a) Initial implementation of this WISP, including:

(i) Assessing internal and external risks to personal [and other sensitive] information and maintaining related documentation, including risk assessment reports and remediation plans (see Section 4);

(ii) Coordinating the development, distribution, and maintenance of information security policies and procedures (see Section 5);

(iii) Coordinating the design of reasonable and appropriate administrative, technical, and physical safeguards to protect personal [and other sensitive] information (see Section 6);

(iv) Ensuring that the safeguards are implemented and maintained to protect personal [and other sensitive] information throughout Paymaster Exchange, where applicable (see Section 6);

(v) Overseeing service providers that access or maintain personal [and other sensitive] information on behalf of Paymaster Exchange (see Section 7);

(vi) Monitoring and testing the information security program's implementation and effectiveness on an ongoing basis (see Section 8);

(vii) Defining and managing incident response procedures (see Section 9); and

(viii) Establishing and managing enforcement policies and procedures for this WISP, in collaboration with Paymaster Exchange human resources and management (see Section 10). 

(b) Employee, contractor, and (as applicable) stakeholder training, including:

(i) Providing periodic training regarding this WISP, Paymaster Exchange's safeguards, and relevant information security policies and procedures for all employees, contractors, and (as applicable) stakeholders who have or may have access to personal [or other sensitive] information;

(ii) Ensuring that training attendees formally acknowledge their receipt and understanding of the training and related documentation, through [written acknowledgement forms; and

(iii) Retaining training and acknowledgment records.

(c) Reviewing the WISP and the security measures defined herein at least annually, or whenever there is a material change in Paymaster Exchange's business practices that may reasonably implicate the security, confidentiality, integrity, or availability of records containing personal [or other sensitive] information (see Section 11). 

(d) Defining and managing an exceptions process to review, approve or deny, document, monitor, and periodically reassess any necessary and appropriate, business-driven requests for deviations from this WISP or Paymaster Exchange's information security policies and procedures. 

(e) Periodically reporting to Paymaster Exchange management regarding the status of the information security program and Paymaster Exchange's safeguards to protect personal [and other sensitive] information.

4. Risk Assessment. As a part of developing and implementing this WISP, Paymaster Exchange will conduct a periodic, documented risk assessment[, at least annually, or whenever there is a material change in Paymaster Exchange's business practices that may implicate the security, confidentiality, integrity, or availability of records containing personal [or other sensitive] information]. 

(a) The risk assessment shall:

(i) Identify reasonably foreseeable internal and external risks to the security, confidentiality, integrity, or availability of any electronic, paper, or other records containing personal [or other sensitive] information.

(ii) Assess the likelihood and potential damage that could result from such risks, taking into consideration the sensitivity of the personal [and other sensitive] information.

(iii) Evaluate the sufficiency of relevant policies, procedures, systems, and safeguards in place to control such risks, in areas that include, but may not be limited to:

(A) Employee, contractor, and (as applicable) stakeholder training and management;

(B) Employee, contractor, and (as applicable) stakeholder compliance with this WISP and related policies and procedures;

(C) Information systems, including network, computer, and software acquisition, design, implementation, operations, and maintenance, as well as data processing, storage, transmission, retention, and disposal; and

(D) Paymaster Exchange's ability to prevent, detect, and respond to attacks, intrusions, and other security incidents or system failures.

(b) Following each risk assessment, Paymaster Exchange will:

(i) Design, implement, and maintain reasonable and appropriate safeguards to minimize identified risks;

(ii) Reasonably and appropriately address any identified gaps.

(iii) Regularly monitor the effectiveness of Paymaster Exchange's safeguards, as specified in this WISP (see Section 8).

5. Information Security Policies and Procedures. As part of this WISP, Paymaster Exchange will develop, maintain, and distribute information security policies and procedures in accordance with applicable laws and standards to relevant employees, contractors, and (as applicable) other stakeholders to:

(a) Establish policies regarding:

(i) Information classification; 

(ii) Information handling practices for personal [and other sensitive] information, including the storage, access, disposal, and external transfer or transportation of personal [and other sensitive] information; 

(iii) User access management, including identification and authentication (using passwords or other appropriate means); 

(iv) Encryption; 

(v) Computer and network security;

(vi) Physical security; 

(vii) Incident reporting and response; 

(viii) Employee and contractor use of technology, including Acceptable Use and Bring Your Own Device to Work (BYOD); and 

(ix)Information systems acquisition, development, operations, and maintenance. 

(b) Detail the implementation and maintenance of Paymaster Exchange's administrative, technical, and physical safeguards (see Section 6).

6. Safeguards. Paymaster Exchange will develop, implement, and maintain reasonable administrative, technical, and physical safeguards in accordance with applicable laws and standards to protect the security, confidentiality, integrity, and availability of personal [or other sensitive] information that Paymaster Exchange owns or maintains on behalf of others. 

(a) Safeguards shall be appropriate to Paymaster Exchange's size, scope, and business; its available resources; and the amount of personal [and other sensitive] information that Paymaster Exchange owns or maintains on behalf of others, while recognizing the need to protect both customer and employee information. 

(b) Paymaster Exchange shall document its administrative, technical, and physical safeguards in Paymaster Exchange's information security policies and procedures (see Section 5). 

(c) Paymaster Exchange's administrative safeguards shall include, at a minimum: 

(i) Designating one or more employees to coordinate the information security program (see Section 3); 

(ii) Identifying reasonably foreseeable internal and external risks, and assessing whether existing safeguards adequately control the identified risks (see Section 4); 

(iii) Training employees in security program practices and procedures, with management oversight (see Section 3); 

(iv) Selecting service providers that are capable of maintaining appropriate safeguards, and requiring service providers to maintain safeguards by contract (see Section 7); and 

(v) Adjusting the information security program in light of business changes or new circumstances (see Section 11); 

(d) Paymaster Exchange's technical safeguards shall include maintenance of a security system covering its network (including wireless capabilities) and computers that, at a minimum, and to the extent technically feasible, supports: 

(i) Secure user authentication protocols, including: 

(A) Controlling user identification and authentication with a reasonably secure method of assigning and selecting passwords (ensuring that passwords are kept in a location or format that does not compromise security) or by using other technologies, such as biometrics or token devices;

(B) Restricting access to active users and active user accounts only, including preventing terminated employees or contractors from accessing systems or records; and 

(C) Blocking access to a particular user identifier after multiple unsuccessful attempts to gain access or placing limitations on access for the particular system. 

(ii) Secure access control measures, including: 

(A) Restricting access to records and files containing personal [or other sensitive] information to those with a need to know to perform their duties; and 

(B) Assigning unique identifiers and passwords (or other authentication means, but not vendor-supplied default passwords) to each individual with computer or network access that are reasonably designed to maintain security. 

(iii) Encryption of all personal [or other sensitive] information traveling wirelessly or across public networks. 

(iv) Encryption of all personal [or other sensitive] information stored on laptops or other portable or mobile devices [, and to the extent technically feasible, personal [or other sensitive] information stored on any other device or media (data-at-rest)].

v) Reasonable system monitoring for preventing, detecting, and responding to unauthorized use of or access to personal [or other sensitive] information or other attacks or system failures. 

(vi) Reasonably current firewall protection and software patches for systems that contain (or may provide access to systems that contain) personal [or other sensitive] information. 

(vii) Reasonably current system security software (or a version that can still be supported with reasonably current patches and malware definitions) that (1) includes malicious software ("malware") protection with reasonably current patches and malware definitions, and (2) is configured to receive updates on a regular basis. 

(e) Paymaster Exchange's physical safeguards shall, at a minimum, provide for: 

(i) Defining and implementing reasonable physical security measures to protect areas where personal [or other sensitive] information may be accessed, including reasonably restricting physical access and storing records containing personal [or other sensitive] information in locked facilities, areas, or containers. 

(ii) Preventing, detecting, and responding to intrusions or unauthorized access to personal [or other sensitive] information, including during or after data collection, transportation, or disposal.

(iii) Secure disposal or destruction of personal [or other sensitive] information, whether in paper or electronic form, when it is no longer to be retained in accordance with applicable laws or accepted standards.

7. Service Provider Oversight. Paymaster Exchange will oversee each of its service providers that may have access to or otherwise create, collect, use, or maintain personal [or other sensitive] information on its behalf by: 

(a) Evaluating the service provider's ability to implement and maintain appropriate security measures, consistent with this WISP and all applicable laws and Paymaster Exchange's obligations. 

(b) Requiring the service provider by contract to implement and maintain reasonable security measures, consistent with this WISP and all applicable laws and Paymaster Exchange's obligations. 

(c) Monitoring and auditing the service provider's performance to verify compliance with this WISP and all applicable laws and Paymaster Exchange's obligations.

8. Monitoring. Paymaster Exchange will regularly test and monitor the implementation and effectiveness of its information security program to ensure that it is operating in a manner reasonably calculated to prevent unauthorized access to or use of personal [or other sensitive] information. Paymaster Exchange shall reasonably and appropriately address any identified gaps. 

9. Incident Response. Paymaster Exchange will establish and maintain policies and procedures regarding information security incident response (see Section 5). Such procedures shall include: 

(a) Documenting the response to any security incident or event that involves a breach of security;

(b) Performing a post-incident review of events and actions taken; and 

(c) Reasonably and appropriately addressing any identified gaps. 

10. Enforcement. Violations of this WISP will result in disciplinary action, in accordance with Paymaster Exchange's information security policies and procedures and human resources policies

11. Program Review. Paymaster Exchange will review this WISP and the security measures defined herein at least annually, or whenever there is a material change in Paymaster Exchange's business practices that may reasonably implicate the security, confidentiality, integrity, or availability of records containing personal [or other sensitive] information.  Paymaster Exchange shall retain documentation regarding any such program review, including any identified gaps and action plans.

12. Effective Date. This WISP is effective as of July 2, 2018.  Revised December 3, 2018.