FinovatePro Information Security Policy

(Version 1.0 — Approved by Executive Management)

1. Purpose

The purpose of this Information Security Policy is to establish the security requirements, controls, and responsibilities necessary to protect the confidentiality, integrity, and availability of FinovatePro systems, data, and technology resources. This policy forms part of FinovatePro’s overall security and risk management framework.

2. Scope

This policy applies to:

• All FinovatePro employees, contractors, consultants, and third-party service providers
• All systems, applications, cloud environments, networks, and data assets used or managed by FinovatePro
• All customer financial data accessed through Plaid or other authorized integrations

3. Governance & Oversight

FinovatePro maintains a formal information security program overseen by executive leadership.

• The CEO provides strategic oversight and accountability.
• The Information Security & Compliance Manager maintains policies, risk assessments, and internal controls.
• The Technical Security Lead manages cloud infrastructure security, application security, encryption standards, and access management.

FinovatePro’s security program is reviewed at least annually or upon significant business changes.

4. Risk Management

FinovatePro maintains a documented risk management process that includes:

• Periodic risk assessments
• Identification of threats and vulnerabilities
• Evaluation of likelihood and impact
• Implementation of risk mitigation controls
• Continuous monitoring and improvement

Risks are reviewed quarterly and documented within our internal governance system.

5. Data Protection Requirements

FinovatePro is committed to protecting customer data and information assets through the following measures:

5.1 Data Classification

Data is classified into:

• Public
• Internal
• Confidential
• Restricted (e.g., financial data)

5.2 Data Handling

Restricted and confidential data must be:

• Stored only in approved systems
• Accessed only for legitimate business purposes
• Logged, monitored, and encrypted

5.3 Data Minimization

Only the minimum necessary data required to provide services is collected.
No unnecessary retention or over-collection of financial data is permitted.

6. Encryption Requirements

FinovatePro enforces industry-standard encryption:

• In Transit: TLS 1.2+
• At Rest: AES-256 or equivalent
• Secrets & Keys: Stored in encrypted vaults (AWS Secrets Manager or equivalent)
• Credentials: Never stored, logged, or accessible to FinovatePro personnel

All access tokens, including Plaid access tokens, are securely stored and encrypted.

7. Access Control

FinovatePro maintains strict access control policies:

7.1 Least Privilege

Users are granted the minimum access necessary to perform their assigned duties.

7.2 Role-Based Access Control (RBAC)

Access is managed through documented roles and regularly reviewed.

7.3 Multi-Factor Authentication (MFA)

MFA is required for all administrative and engineering accounts.

7.4 Offboarding Controls

Access removal occurs immediately upon role change or termination.

8. Secure Software Development (SDLC)

FinovatePro follows a secure development lifecycle:

• Code reviews for all changes
• Automated vulnerability scanning
• Dependency and package monitoring
• Separation of development, staging, and production environments
• Strict segregation of duties for code deployment

Third-party libraries are continuously monitored for security patches.

9. Logging & Monitoring

FinovatePro maintains continuous monitoring of system activity:

• Centralized logging of system and application events
• Monitoring for anomalous behavior, unauthorized access, and errors
• Retention of logs for a minimum of 12 months for security review
• Alerts routed to engineering and security teams

10. Incident Response Plan

FinovatePro maintains a documented Incident Response Plan (IRP), including:

• Identification and triage
• Containment and eradication
• Recovery and restoration
• Root cause analysis
• Notification procedures aligned with regulatory requirements

All security incidents are logged and reviewed by the security team.

11. Vendor & Third-Party Risk Management

All vendors that store or process data on behalf of FinovatePro must:

• Undergo due diligence reviews
• Meet required security and compliance standards
• Sign appropriate contracts and DPAs
• Be monitored annually

Cloud vendors must adhere to SOC 2, ISO 27001, or equivalent frameworks.

12. Physical & Cloud Security

FinovatePro’s infrastructure is hosted in secure, audited cloud environments with:

• SOC 2 / ISO 27001 certification
• Redundant availability zones
• Encrypted storage
• Network segmentation
• DDoS protection

No customer data is stored on local employee devices.

13. Data Retention & Deletion

Customer data is retained only as long as required to deliver services or meet legal obligations.
Upon termination or user request, data is securely deleted in accordance with policy.

14. Employee Security Training

All employees receive mandatory security and privacy training covering:

• Data protection
• Secure handling of financial data
• Phishing and social engineering
• Password hygiene
• Incident reporting procedures

Training is refreshed annually.

15. Policy Enforcement

Failure to comply with this policy may result in access revocation, disciplinary action, or contract termination.
This policy is reviewed annually as part of FinovatePro’s governance framework.