Information Security Program

GLBA Safeguards Rule · 16 C.F.R. Part 314 · v1

Designated coordinator

A named Information Security Coordinator oversees this program and reports annually.

Risk assessment

Reviewed at least annually and after any material system change. Threats include: credential theft, key loss, insider misuse, third-party compromise, and Stellar network outages.

Technical safeguards

  • TLS 1.2+ in transit. AES-256 at rest for sensitive payloads.
  • Row-level security on every customer-facing table; service-role access scoped to verified webhooks.
  • SHA-256 hashing of every legally significant document; hashes anchored to Stellar memos.
  • Webhooks authenticated with HMAC-SHA256 and constant-time comparison.
  • Daily seal-integrity job re-verifies document hashes against the ledger.

Administrative safeguards

  • Role-based access (grantor, trustee, beneficiary, attorney, admin).
  • Quarterly access review.
  • Mandatory background screening for any role with admin database access.
  • Incident response runbook with 72-hour notification target.

Service provider oversight

Database hosting, KYC, OFAC, payments, and notary partners are contractually bound to safeguards consistent with this program. We review their attestations annually.

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