You serve as the designated information security coordinator for Advanced Compliance Technology, Inc.. As BSA/AML Compliance Officer, you are responsible for protecting all customer nonpublic personal information generated through check cashing, money transmission, payment instrument sales, foreign currency exchange operations.
\nAdvanced Compliance Technology, Inc. classifies customer data in three tiers. Restricted data includes government-issued ID copies, Social Security numbers, check images, transaction records, and SAR/CTR workpapers. Restricted data must be stored encrypted. Access to restricted data is limited to you and personnel you designate. Confidential data includes customer names, contact information, risk ratings, and check cashing history. Access to confidential data is limited to operational staff with a documented need to know. Internal data covers general business records; standard employee access controls apply.
\nYou assign system access based on each employee's role and operational need. Shared credentials are prohibited. You revoke access within 24 hours of employment termination or role change. Prompt revocation prevents former employees from accessing sensitive customer and compliance records.
\nYou provide each customer an initial privacy notice at the time of their first transaction. You provide an annual privacy notice to all customers thereafter. The notice must identify: categories of nonpublic personal information collected; parties with whom it may be shared; and applicable opt-out rights. You honor opt-out requests within 30 days. Timely processing preserves customers' legal rights under federal privacy law.
\nYou review access logs for all systems holding customer or compliance data monthly. You investigate any anomalies. Antivirus, firewall, and patch management controls must be applied to all systems processing nonpublic personal information. Critical security patches must be applied within 72 hours of release. Regular log review detects unauthorized access before it escalates to a reportable breach.
\nYou review the information security program annually. You also review it following any material change in operations or systems. Annual review ensures controls remain effective as business conditions change.
\nUpon discovering a security incident involving nonpublic personal information, you immediately assess the scope and isolate affected systems. You engage legal counsel within 24 hours to evaluate notification obligations. An incident affecting 500 or more Florida residents requires notification to the Florida Department of Legal Affairs. You must complete that notification within 30 days of breach determination. Affected individuals receive written notice within the statutory deadline. You document the incident, all response actions, and remediation steps. You retain that documentation for five years. If the breach involved exploitation of customer accounts to facilitate financial crime, you file a SAR. A structured breach response limits legal exposure and satisfies regulatory notification requirements.
\nBefore sharing customer nonpublic personal information with any service provider, you execute a written data security agreement. The agreement must require the vendor to maintain safeguards consistent with federal information security requirements. Service providers include check verification services, IT vendors, and document storage providers. Check images are not shared with third parties except as required by law or under a qualifying data security agreement. You review vendor security controls annually and at each contract renewal. You replace vendors that cannot demonstrate adequate controls before the next contract term begins. Vendor oversight prevents third-party weaknesses from undermining Advanced Compliance Technology, Inc.'s security obligations.
\nUpon expiration of the retention period, you destroy records containing nonpublic personal information in a manner that prevents reconstruction. Paper documents are cross-cut shredded. Digital media is electronically wiped using a certified process or physically destroyed. You log and verify each disposal. Documented destruction creates an auditable record that records were not improperly retained or disclosed.
", "narration_text": "You serve as the designated information security coordinator for Advanced Compliance Technology, Inc.. As BSA/AML Compliance Officer, you are responsible for protecting all customer nonpublic personal information generated through check cashing, money transmission, payment instrument sales, foreign currency exchange operations.\r\n\r\nAdvanced Compliance Technology, Inc. classifies customer data in three tiers. Restricted data includes government-issued ID copies, Social Security numbers, check images, transaction records, and SAR/CTR workpapers. Restricted data must be stored encrypted. Access to restricted data is limited to you and personnel you designate. Confidential data includes customer names, contact information, risk ratings, and check cashing history. Access to confidential data is limited to operational staff with a documented need to know. Internal data covers general business records; standard employee access controls apply.\r\n\r\nYou assign system access based on each employee's role and operational need. Shared credentials are prohibited. You revoke access within 24 hours of employment termination or role change. Prompt revocation prevents former employees from accessing sensitive customer and compliance records.\r\n\r\nYou provide each customer an initial privacy notice at the time of their first transaction. You provide an annual privacy notice to all customers thereafter. The notice must identify: categories of nonpublic personal information collected; parties with whom it may be shared; and applicable opt-out rights. You honor opt-out requests within 30 days. Timely processing preserves customers' legal rights under federal privacy law.\r\n\r\nYou review access logs for all systems holding customer or compliance data monthly. You investigate any anomalies. Antivirus, firewall, and patch management controls must be applied to all systems processing nonpublic personal information. Critical security patches must be applied within 72 hours of release. Regular log review detects unauthorized access before it escalates to a reportable breach.\r\n\r\nYou review the information security program annually. You also review it following any material change in operations or systems. Annual review ensures controls remain effective as business conditions change.\r\n\r\nUpon discovering a security incident involving nonpublic personal information, you immediately assess the scope and isolate affected systems. You engage legal counsel within 24 hours to evaluate notification obligations. An incident affecting 500 or more Florida residents requires notification to the Florida Department of Legal Affairs. You must complete that notification within 30 days of breach determination. Affected individuals receive written notice within the statutory deadline. You document the incident, all response actions, and remediation steps. You retain that documentation for five years. If the breach involved exploitation of customer accounts to facilitate financial crime, you file a SAR. A structured breach response limits legal exposure and satisfies regulatory notification requirements.\r\n\r\nBefore sharing customer nonpublic personal information with any service provider, you execute a written data security agreement. The agreement must require the vendor to maintain safeguards consistent with federal information security requirements. Service providers include check verification services, IT vendors, and document storage providers. Check images are not shared with third parties except as required by law or under a qualifying data security agreement. You review vendor security controls annually and at each contract renewal. You replace vendors that cannot demonstrate adequate controls before the next contract term begins. Vendor oversight prevents third-party weaknesses from undermining Advanced Compliance Technology, Inc.'s security obligations.\r\n\r\nUpon expiration of the retention period, you destroy records containing nonpublic personal information in a manner that prevents reconstruction. Paper documents are cross-cut shredded. Digital media is electronically wiped using a certified process or physically destroyed. You log and verify each disposal. Documented destruction creates an auditable record that records were not improperly retained or disclosed." }