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.