DG3 Security and Data Policy

Summary of DG3’s privacy policy and procedures for handling of confidential information:

  • Since its inception, DG3 has been constructed around the handling and producing of highly sensitive data for our clients. Our facility is perimeter secured.  Every visitor must provide identification and sign in.  Suppliers are not permitted beyond the front office area. All areas are hand scan access (biometric) controlled and all cameras are digitally managed and provide facial recognition.  Cameras are monitored and security personnel guard the property 24 hours per day.
  • DG3’s facilities and processes are audited no less than two times yearly by the Infosec and Security departments of two of the world’s leading financial institutions. These teams evaluate physical and electronic security and require adherence to the same standard as their facilities and processes.  DG3 has never failed one of these audits.
  • Employees: Every employee of DG3 worldwide is subjected to a criminal background check that is at least as stringent as the standard of DG3’s investment banking and financial services clients.
  • Data security: All data is housed behind firewalls.  All DG3 data networks are penetration tested on a regular basis.  In the course of conducting our business and providing services, DG3 receives, maintains, processes, and transmits large amounts of DG3 and client confidential information.  DG3 is firmly obligated and committed to protect the confidentiality of this information.
  • Internal: All client data is considered confidential.  All physical and electronic access to IT systems, networks and confidential information, is limited to DG3 associates with a business need.
  • Internal network access to DG3 and client data is gated by USER ID/Password authentication. Typically dual perimeter User ID authentication is the rule.  All password protection includes lockouts, minimum lengths, and alphanumeric composition and where applicable two-factor authentication techniques.
  • Client Data is not used for development, testing, training, or any purpose other than providing production service, client specific acceptance testing, or production diagnostics.
  • Actual or requested document archiving is conducted in accordance with the DG3 Record Retention Policy.
  • All physical and electronic access is immediately reviewed upon any change in job assignment and all access is terminated immediately leaving DG3 employment.
  • External: External transmission of client data is conducted utilizing approved secure methods.  Such methods include, but not limited to, Secure FTP, PGP/FTP HTTPS, Secure NDM, dedicated point to point data lines, etc.  All encryption algorithms, modes of operation, and security key management systems are consistent with internal standards issued by the Corporate Security Group.
  • Web-Based products and platforms are domain name registered (with the domain name registration authority) and where applicable utilize approved data transmission methods (SSL, IPsec, HTTPS, etc). Appropriate security measures are used to protect DG3’s infrastructure, including using firewalls and perimeter LAN/WAN infrastructures to control Internet access to the appropriate web and/or back end devices.  These same products and platforms undergo attack and penetration testing before becoming operational and periodically thereafter.
Area of Focus DG3 Approach
Audit Trail We receive encrypted files via our Secure FTP site or PGP encryption.  This is logged on our servers that collect files.  From there, files are locked down via Active Directory permissions and a disclaimer is presented upon logging into these systems.
Archiving, Purging Intervals The data archiving and purging differs as it is an agreement made with each customer.
Data Transfer Options Email, FTP, HTTPS, WAMNET, Virtual Private Network, Point to Point
Disposal of Data Hard disks are magnetically erased, disassembled and then destroyed. CD’s and tapes are destroyed.  In some cases, with customer data, we use one of our vendors to properly destroy and dispose of customer data, using DOD scrub with written evidence.
Technology Perimeter Defense: Best in Class Firewalls and IDS. Routers with ACL’s.
Data Retention Logs are kept in our Syslog server for 6 months and they are unalterable.
Securing Backups Backups are written to tape and off-sited by our Disaster Recovery and Storage Vendor “GRM” – Guarantee Records Management Corp.
Employee back-ground checks performed: Every employee of DG3 Worldwide is subjected to a criminal background check that is at least as stringent as the standard of DG3’s investment banking and financial services clients.

As part of the DG3 North Pre-employment Procedures, all new hired employees are required to sign a release authorization authorizing DG3 North America to run an investigative consumer report. The employee is also given a written summary of their rights under the Fair Credit Reporting Act. The following items are requested on all background checks:

  • Verification of Address
  • Verification of Social Security #
  • Verification of past or present education
  • Verification of Criminal background (Nationwide)
  • Verification of name
  • Verification of past credit

Once the authorization is received from the employee, we electronically process the request and receive the detailed report within 15 minutes to 1 hour depending on the extent of the background history.

 

Data safeguard On systems that contain customer data, the security is locked down via Active Directory permissions; which is reviewed regularly and a disclaimer is presented upon logging into these systems.
File Transfer Protocol (ftp) site specification We use SSL 128-bit encryption on our FTP server and transmission.
Preferred encryption protocols PGP and 128-bit SSL
What procedures are in place for setting, controlling, and modifying vendor access? We have standards according to our DG3 Information Security Policy that is reviewed regularly.  These procedures are also audited by an outside audit firm, Grant Thornton, as well as approved and managed by our InfoSec team.
Environmental controls Alarming is currently setup and auto-notifications are sent to our team.
Are procedures in place for notification and escalation in the event of a security incident? Alarming is currently setup and auto-notifications are sent to our team.
Perimeter defense devices configured for least access Implicit denies are on all firewall rule bases and ACL’s
Network devices and critical hosts monitoring We use Juniper SSG520’s for IDS with alarming and notifications to our Management Console.
Anti virus software Sophos Enterprise Anti-virus is installed and configured.  All updates are pushed hourly.
Multi-factor authentication (e.g. RSA Tokens) We use RSA 2-factor tokens for outside VPN access.  This access is only granted to employees with restricted access.  We also use MD5 encryption on the VPN tunnels.
Penetration testing We use accredited third party firms for regular penetration tests.
SOC Audits Our systems and facilities are subjected to SOC audits annually by an accredited third part firm.

Data Handling and Privacy Agreement

1. Confidentiality and Data Protection

1. DG3 and its DG3 Personnel will treat as confidential all information and data, of whatever nature, relating to our clients (including but not limited to information and data regarding our clients operations, research, policies, procedures, data, techniques, accounts and its personnel) or used by our clients or any of our client’s personnel in carrying on business, which is obtained or accessed by DG3 or its DG3 Personnel, or disclosed to DG3 or its DG3 Personnel in connection with the performance by DG3 of DG3’s obligations under an agreement; (c) all information and data which are proprietary to a third party (including but not limited to our client’s customers and suppliers) and which our clients is obligated to treat as confidential, obtained by DG3 or its DG3 Personnel, or disclosed to DG3 or its DG3 Personnel in connection with the performance by DG3 of DG3’s obligations under an agreement; and (d) Customer Information (individually and collectively, “Confidential Information”).  “Customer Information” means all information, in any form (e.g., written, verbal, electronic), provided to, or collected or generated by, the DG3 or to which the DG3 or its DG3 Personnel have been given access by or on behalf of our clients, that uniquely identifies a current, former or prospective our clients customer or customer of any correspondent bank or customer financial institution and includes, but is not limited to, Personal Information.  Customer Information further includes, but is not limited to, whole or partial copies of such information or materials derived from such information.  DG3 shall immediately by phone and promptly in writing (but in no event more than twenty-four (24) hours of discovery), notify our clients if it becomes aware of: (i) any loss of Customer Information; (ii) any attempt to obtain unauthorized access to, disclosure of or use of Customer Information; or (iii) any attempt to alter or destroy Customer Information and, in such event, at no additional cost to our clients shall cooperate fully with our clients and follow our client’s instructions regarding actions to be undertaken to address such loss or breach.

2. DG3 and its DG3 Personnel shall not disclose, use, publish or otherwise reveal, directly or indirectly through any third party, any Confidential Information (including without limitation Personal Information) to any third person or to any of DG3’s DG3 Personnel that do not have a need to know such Confidential Information for the purpose of their role in performing DG3’s obligations under an agreement.  DG3 shall exercise the same degree of care to keep confidential any Confidential Information disclosed to DG3 as DG3 exercises to keep confidential its own information of like nature, but in no event less than a reasonable standard of care. DG3 will instruct its DG3 Personnel to comply with their individual obligations as well as DG3’s obligations set forth in this Section 11, and DG3 will obtain a signed agreement substantially in the form of Exhibit B hereto from any DG3 Personnel performing Services or with access to Customer Information.

3. DG3 and its DG3 Personnel shall not use any Confidential Information to obtain an unauthorized benefit for DG3, our clients or any third party.

4. Notwithstanding the foregoing, for Confidential Information that is not Customer Information, the above restrictions on disclosure shall not apply solely with respect to information and material that: (i) is received from any third party source that is properly authorized to disclose it without restriction on such disclosure; (ii) is or becomes generally known to the public by publication or other means other than a breach of duty under an agreement or any other agreement by DG3 or any of its DG3 Personnel; or (iii) is required by law, regulation or court order to be divulged, provided that the request for such disclosure is proper and the disclosure does not exceed that which is required.  In no event shall Customer Information be subject to the preceding exceptions.  In the event of any disclosure under (iii) above, a copy of this agreement shall be furnished to anyone to whom such disclosure is required and the disclosing party shall promptly, prior to disclosure, advise the other party in writing of each such disclosure and, at the other party’s cost, shall reasonably cooperate with the other party to prevent or limit such disclosure as permitted by law.

5. DG3 hereby acknowledges that enforcement of this agreement through claims for damages would be inadequate and that, in the event of a breach or threatened breach of this Section 11, our clients shall be entitled to any necessary judicial relief, including without limitation injunctive relief, without the necessity of having to post a bond.

6. Upon our clients’s request, and in any event upon termination of an agreement, DG3 shall return the original and any copies of the Confidential Information which it, or any of its DG3 Personnel are holding in tangible form, written or otherwise, to our clients or, at our clients’s option, shall destroy such information and shall certify in writing to our clients that such Confidential Information has been destroyed.

7. DG3 will comply with data privacy laws in relation to the processing of personal data in connection with an agreement.  DG3 will not, by any act or omission, place any member of our client’s group in breach of the data privacy laws.  For the purpose of an agreement “data privacy laws” means all relevant provisions of the worldwide directives and any other relevant and applicable data protection legislation, guidelines and industry standards (to the extent applicable) in the jurisdictions from which and to which the relevant Services are to be performed

8. DG3 will comply with, and only act on, instructions from and on behalf of the relevant member of the our client regarding the processing of our clients Personal Data and DG3 will not process the our clients Personal Data for any purposes other than to provide the Services to the relevant member of the our clients Group.  For the purpose of an agreement “our clients Personal Data” means any personal data supplied by any our clients Group Member or on its behalf to Supplier and/or processed in connection with an agreement.

9. DG3 will ensure that appropriate technical and organizational measures are taken to avoid unauthorized or unlawful processing of our clients Personal Data and against loss or destruction of or damage to our clients Personal Data.  DG3 must ensure that the technical and organizational measures it implements ensures a strict separation between our clients Personal Data, and other personal data in respect of which DG3 is a data controller or a data processor.

10. DG3 will inform the relevant member of the our clients immediately of any suspected or confirmed data protection breaches, unauthorized or unlawful processing, loss, or destruction of, or damage to, our clients Personal Data.

11. DG3 will comply with any reasonable request made by our clients to ensure compliance with the measures set out in this agreement.

12. DG3 will take reasonable steps to ensure the reliability of its DG3 Personnel who obtain access to our clients Personal Data pursuant to, or in connection with, the provision of the Services.

13. DG3 will ensure that its DG3 Personnel are suitably informed, trained and instructed in respect of data privacy laws as well as obliged to observe data secrecy regulations pursuant to the relevant applicable data protection laws. DG3 will procure that its Personnel observe any applicable data secrecy regulations beyond their respective periods of employment with DG3.

DG3 will not, unless requested by our clients or obliged by law, disclose our clients Personal Data to any third party.  If DG3 is obliged by law to disclose the our clients Personal Data to any third party, DG3 will (to the extent permitted by law) inform our clients of such intended disclosure and co-operate with our clients to limit the scope of the disclosure to what is strictly required by law.