Data Security Framework

Effective Date: August 27, 2025
Last Updated: August 27, 2025
Classification: Public

ARTICLE I. EXECUTIVE SUMMARY AND SCOPE

Section 1.01 Framework Purpose and Commitment

Assivo, Inc., an Illinois corporation ("Assivo," "Company," "we," "us," or "our"), maintains a comprehensive Data Security Framework designed to protect the confidentiality, integrity, and availability of information assets across our global operations. This Framework establishes enterprise-grade security standards, technical controls, and governance processes that safeguard client data, proprietary information, and business-critical systems.

Section 1.02 Security Philosophy and Approach

Our security approach is founded on industry-leading practices, regulatory compliance requirements, and continuous improvement principles. We have designed our security program to meet or exceed the standards established by recognized frameworks including ISO/IEC 27001 Information Security Management Systems and SOC 2 security and availability control objectives.

Section 1.03 Global Application and Scope

This Framework applies comprehensively to all Assivo entities, personnel, contractors, business partners, and third-party service providers handling information assets on our behalf across our global operations in Chicago, Mexico City, Mumbai, and Chennai.

ARTICLE II. INFORMATION SECURITY GOVERNANCE

Section 2.01 Security Governance Structure and Leadership

2.01.1 Executive Security Leadership

Our information security governance incorporates multi-tiered accountability:

Technology Officer: Executive accountability for information security strategy, implementation, and enterprise-wide security performance
AI & Technology Committee: Cross-functional governance body comprising senior leadership from Information Technology, Legal, Operations, and Risk Management functions
Regional IT Managers: Local implementation of security requirements, incident response coordination, and regional compliance management
General Counsel: Specialized oversight for privacy regulations, legal compliance, and stakeholder protection obligations

2.01.2 Executive Oversight and Strategic Direction

Security governance responsibilities are distributed across executive leadership:

Executive Leadership: Strategic oversight of information security risks, investment priorities, and organizational security posture
Principal: Ultimate resource allocation authority, policy approval, and security strategy alignment with business objectives
Audit & Risk Committee: Independent assessment of security control effectiveness, compliance validation, and risk management oversight

Section 2.02 Security Policy Framework and Standards

2.02.1 Comprehensive Policy Architecture

Our security governance is supported by a comprehensive policy framework including:

Information Security Policy: Overarching principles, responsibilities, and organizational security requirements
Data Classification and Handling Standards: Information categorization methodologies and protection requirement specifications
Access Control Policy: User authentication, authorization, privilege management, and identity governance requirements
Incident Response Policy: Security event detection, response procedures, recovery protocols, and stakeholder communication frameworks
Third-Party Security Policy: Vendor assessment criteria, contractual security requirements, and ongoing relationship management standards

2.02.2 Standards Alignment and Benchmarking

Our security policies and procedures are designed to align with and exceed industry-recognized frameworks:

ISO/IEC 27001 Alignment: Information Security Management Systems principles, control objectives, and continuous improvement methodologies
SOC 2 Control Framework: Security, availability, processing integrity, confidentiality, and privacy control objectives and implementation guidance
Regulatory Compliance Standards: Alignment with applicable data protection regulations including GDPR, CCPA, HIPAA, and sector-specific requirements
Industry Best Practices: Integration of emerging security practices, threat intelligence, and technological advancement considerations

ARTICLE III. DATA CLASSIFICATION AND PROTECTION FRAMEWORK

Section 3.01 Information Classification Methodology

3.01.1 Confidential Information Classification

Definition and Scope: Information assets requiring the highest level of protection due to potential for significant organizational, client, or stakeholder harm if disclosed, modified, or destroyed without authorization.

Representative Examples: Client proprietary data and trade secrets, financial information and commercial terms, strategic business plans and competitive intelligence, personally identifiable information and protected health information, intellectual property and proprietary methodologies.

Mandatory Protection Requirements:

Advanced Encryption Standard (AES-256) or equivalent cryptographic protection for data at rest and in transit
Multi-factor authentication requirements for all system access and user verification
Comprehensive access logging, monitoring, and behavioral analytics
Strict need-to-know access restrictions with regular access certification and review processes
Enhanced incident response procedures and stakeholder notification protocols

3.01.2 Internal Information Classification

Definition and Scope: Information intended for internal organizational use that could cause moderate business harm, competitive disadvantage, or operational disruption if disclosed without authorization.

Representative Examples: Employee personal information and personnel records, internal business processes and operational procedures, vendor contracts and supplier relationships, performance metrics and operational analytics, training materials and internal communications.

Standard Protection Requirements:

Industry-standard encryption for sensitive data elements and transmission security
Role-based access controls aligned with organizational hierarchy and functional responsibilities
Regular access reviews, certification processes, and privilege validation procedures
Standard monitoring, logging, and anomaly detection capabilities
Incident response procedures proportionate to information sensitivity and business impact

3.01.3 Public Information Classification

Definition and Scope: Information approved for public disclosure and external distribution with minimal organizational risk if broadly accessible or redistributed.

Representative Examples: Marketing materials and promotional content, published financial statements and regulatory filings, general company information and public communications, industry thought leadership and educational content.

Basic Protection Requirements:

Standard information technology security controls and infrastructure protection
Version control systems and publication approval processes
Data integrity protection measures and authenticity verification
Basic monitoring for unauthorized modification or system compromise

Section 3.02 Data Lifecycle Management and Protection

3.02.1 Creation and Collection Phase

Data Minimization Principles: Collection and creation of information assets limited to data necessary for legitimate business purposes and authorized processing activities, with clear documentation of collection purposes, legal basis, and intended use restrictions.

Quality Assurance and Validation: Implementation of systematic data validation procedures, accuracy verification processes, completeness assessments, and integrity checking mechanisms during initial data capture and processing activities.

Immediate Classification and Protection: Automatic application of appropriate classification levels upon data creation or receipt, with immediate implementation of corresponding protection measures and access controls based on sensitivity determinations.

3.02.2 Processing and Utilization Phase

Authorized Access Management: Restriction of data access to authorized personnel with legitimate business needs, supported by comprehensive identity management systems, privilege verification processes, and continuous access monitoring capabilities.

Processing Activity Documentation: Maintenance of detailed logs documenting all data processing activities, including user access patterns, system interactions, modification events, and data sharing activities for audit trail and compliance verification purposes.

Quality Maintenance and Integrity: Regular verification of data accuracy, completeness, and currency through automated validation systems, manual review processes, and stakeholder feedback mechanisms to ensure continued data quality and reliability.

3.02.3 Storage and Retention Management

Secure Storage Infrastructure: Implementation of enterprise-grade storage systems with appropriate technical controls, environmental protections, physical security measures, and redundancy capabilities commensurate with data classification and business criticality.

Retention Schedule Implementation: Application of systematic retention schedules based on legal requirements, business needs, regulatory obligations, and stakeholder expectations, with regular review and validation of continued retention necessity and legal justification.

Archive Management and Long-term Storage: Secure long-term storage solutions with appropriate access controls, environmental protections, media integrity monitoring, and retrieval capabilities for archived information assets requiring extended retention periods.

3.02.4 Disposal and Secure Destruction

Cryptographic Erasure and Secure Deletion: Implementation of cryptographically secure data destruction methods, including secure key destruction for encrypted data and multi-pass overwriting techniques for magnetic storage media to ensure complete data elimination.

Physical Media Destruction: Certified destruction of physical storage devices using industry-standard destruction methods, with certificate of destruction documentation and chain of custody verification for high-sensitivity information assets.

Third-Party Destruction Services: Engagement of certified data destruction service providers operating under comprehensive service agreements, security requirements, and audit provisions for off-site data destruction and media disposal activities.

ARTICLE IV. TECHNICAL SECURITY CONTROLS AND SAFEGUARDS

Section 4.01 Network Security Architecture

4.01.1 Defense-in-Depth Network Design

Network Segmentation and Isolation: Implementation of logical network separation creating security zones based on data classification, system criticality, and functional requirements, with controlled inter-zone communication and traffic monitoring capabilities.

Multi-Layered Firewall Architecture: Deployment of enterprise-grade firewall systems with rule-based traffic filtering, deep packet inspection capabilities, intrusion detection integration, and centralized management and monitoring functions.

Intrusion Detection and Prevention Systems: Real-time network monitoring and automated threat response capabilities, including signature-based detection, behavioral analysis, and machine learning-enhanced anomaly identification with rapid containment and mitigation procedures.

Secure Remote Access Infrastructure: Virtual Private Network (VPN) solutions utilizing industry-standard encryption protocols, certificate-based authentication, and comprehensive access logging for secure remote connectivity and distributed workforce support.

4.01.2 Wireless Network Security and Management

Enterprise Wireless Infrastructure: WPA3 encryption standards with certificate-based authentication, enterprise-grade access point management, and comprehensive network access control integration for secure wireless connectivity.

Guest Network Isolation and Control: Segregated guest network infrastructure with restricted access capabilities, bandwidth limitations, content filtering, and comprehensive monitoring to prevent unauthorized access to internal systems and resources.

Wireless Security Monitoring and Management: Continuous scanning for unauthorized wireless devices, rogue access point detection, signal strength monitoring, and automated security policy enforcement across all wireless infrastructure components.

Section 4.02 Endpoint Security and Device Management

4.02.1 Advanced Endpoint Protection

Endpoint Detection and Response (EDR): Next-generation endpoint security solutions providing real-time threat detection, behavioral analysis, automated incident response, and comprehensive forensic capabilities for all organizational devices and systems.

Multi-Layered Anti-Malware Protection: Advanced malware prevention incorporating signature-based detection, heuristic analysis, behavioral monitoring, machine learning threat identification, and cloud-based threat intelligence integration.

Device Encryption and Data Protection: Full-disk encryption implementation for all devices handling sensitive information, with centralized key management, encryption policy enforcement, and regular compliance verification procedures.

Automated Patch Management: Systematic security update deployment processes with vulnerability assessment integration, testing procedures, rollback capabilities, and comprehensive reporting on patch compliance and security posture.

4.02.2 Mobile and Remote Access Security

Mobile Application Management (MAM): Controlled deployment and management of business applications on mobile devices, with application-level security policies, data loss prevention integration, and remote management capabilities.

Remote Access Security Controls: Multi-factor authentication requirements, device compliance verification, session monitoring, and conditional access policies based on user behavior, location, and device trust levels.

Data Loss Prevention (DLP): Comprehensive monitoring and prevention of unauthorized data transmission, with content inspection, policy enforcement, user education, and incident response integration across all communication channels and storage systems.

Section 4.03 Application Security and Development

4.03.1 Secure Software Development Lifecycle

Security-by-Design Principles: Integration of security considerations throughout the entire application development lifecycle, from initial requirements gathering through deployment, maintenance, and eventual decommissioning of software systems.

Code Review and Security Testing: Comprehensive static and dynamic code analysis, security vulnerability scanning, penetration testing, and security architecture review procedures for all internally developed and third-party software applications.

Third-Party Component Management: Systematic assessment and management of open-source and commercial software components, including vulnerability scanning, license compliance verification, and ongoing security monitoring of external dependencies.

4.03.2 Application Runtime Protection

Web Application Firewalls (WAF): Advanced protection against common web application attacks including SQL injection, cross-site scripting, and other OWASP Top 10 vulnerabilities, with real-time threat detection and automated response capabilities.

Application Programming Interface (API) Security: Comprehensive API security controls including authentication, authorization, rate limiting, input validation, encryption, and monitoring for all internal and external API endpoints and integrations.

Database Security and Access Control: Multi-layered database protection including access controls, encryption, activity monitoring, vulnerability assessment, and data masking capabilities for all database systems containing sensitive information.

Section 4.04 Cloud Security and Infrastructure Protection

4.04.1 Multi-Cloud Security Architecture

Cloud Security Strategy: Comprehensive security approach spanning multiple cloud service providers with vendor-specific security optimization, shared responsibility model implementation, and consistent security policy enforcement across all cloud environments.

Identity and Access Management (IAM): Centralized identity management and authentication services spanning on-premises and cloud environments, with single sign-on capabilities, privilege management, and comprehensive access governance procedures.

Cloud Configuration Management: Automated security configuration management, compliance monitoring, policy enforcement, and drift detection across all cloud infrastructure components and service configurations.

4.04.2 Cloud Data Protection and Governance

Customer-Managed Encryption Keys: Implementation of customer-controlled encryption key management using hardware security modules (HSMs) and key management services to ensure organizational control over cryptographic materials and data protection.

Data Residency and Sovereignty Controls: Geographic restrictions and data localization capabilities to meet regulatory requirements, client specifications, and organizational data governance policies across multiple jurisdictions and regulatory frameworks.

Cloud Access Security Broker (CASB): Monitoring and policy enforcement for cloud service usage, with visibility into sanctioned and unsanctioned cloud applications, data loss prevention, and threat protection across all cloud service interactions.

ARTICLE V. PHYSICAL AND ENVIRONMENTAL SECURITY

Section 5.01 Facility Security and Access Control

5.01.1 Physical Access Control Systems

Multi-Factor Facility Authentication: Implementation of sophisticated access control systems requiring multiple authentication factors including badge access, biometric verification, and visitor management systems for all facility access points and secure areas.

Physical Security Barriers and Perimeter Protection: Appropriate perimeter security measures, secure area designation, equipment protection systems, and environmental monitoring to prevent unauthorized physical access to information systems and sensitive areas.

Comprehensive Surveillance and Monitoring: Professional-grade camera systems with recording capabilities, motion detection, access event logging, and integration with central monitoring systems for continuous facility security oversight and incident response.

5.01.2 Environmental Controls and Infrastructure Protection

Climate Control and Environmental Monitoring: Advanced HVAC systems with temperature and humidity monitoring, automated environmental controls, alerting systems, and backup environmental systems to protect information technology infrastructure and equipment.

Fire Suppression and Emergency Systems: Sophisticated fire detection and suppression systems specifically designed for information technology environments, with early warning systems, automated suppression activation, and coordination with emergency response services.

Power Protection and Backup Systems: Uninterruptible power supplies (UPS), backup generator systems, power conditioning equipment, and redundant power distribution to ensure continuous operation of critical information systems and infrastructure components.

Section 5.02 Equipment Security and Asset Management

5.02.1 Information Technology Asset Protection

Comprehensive Asset Inventory and Tracking: Systematic inventory management and tracking of all information technology assets, security equipment, and infrastructure components, with regular reconciliation, lifecycle management, and disposal tracking procedures.

Secure Equipment Disposal and Data Destruction: Certified destruction procedures for storage devices and equipment containing sensitive information, with certificate of destruction documentation, chain of custody procedures, and environmentally responsible disposal methods.

Maintenance Security and Service Provider Management: Secure handling of equipment during maintenance activities, service provider background verification, supervised maintenance procedures, and secure storage of equipment awaiting service or disposal.

ARTICLE VI. ACCESS CONTROL AND IDENTITY MANAGEMENT

Section 6.01 Identity and Access Management Framework

6.01.1 Comprehensive Identity Lifecycle Management

Automated Identity Provisioning and De-provisioning: Systematic user account creation, modification, and termination processes based on employment status changes, role transitions, and access requirement modifications, with integration to human resources systems and workflow automation.

Single Sign-On (SSO) and Federated Identity Management: Centralized authentication services enabling secure access to multiple systems and applications through unified identity credentials, with support for industry-standard authentication protocols and cross-domain identity federation.

Multi-Factor Authentication (MFA) and Risk-Based Access: Implementation of context-aware authentication systems requiring multiple verification factors, with risk assessment capabilities considering user behavior, location, device trust, and access patterns for dynamic security policy application.

Privileged Access Management (PAM): Enhanced security controls and monitoring for administrative access rights, including privileged account management, session recording, just-in-time access provisioning, and comprehensive audit trail maintenance for all elevated privilege activities.

6.01.2 Access Control Principles and Policy Framework

Principle of Least Privilege Enforcement: Systematic implementation of minimum necessary access rights aligned with specific job functions, with regular access reviews, privilege certification, and automated access right adjustments based on role changes and business requirements.

Need-to-Know Access Restrictions: Information access controls based on legitimate business requirements and authorized processing activities, with clear documentation of access justifications and regular validation of continued access necessity.

Segregation of Duties and Conflict Prevention: Implementation of role-based controls preventing conflicts of interest, unauthorized transaction processing, and concentration of critical functions, with systematic monitoring for potential control violations and compensating controls where segregation is not feasible.

Regular Access Reviews and Certification: Systematic and periodic reviews of user access rights, system permissions, and privilege assignments, with formal certification by data owners, access right validation, and prompt remediation of inappropriate or unnecessary access permissions.

Section 6.02 Authentication and Authorization Technologies

6.02.1 Advanced Authentication Mechanisms

Strong Multi-Factor Authentication: Implementation of sophisticated authentication systems combining knowledge factors (passwords, PINs), possession factors (tokens, mobile devices), and inherence factors (biometrics) for robust identity verification across all system access points.

Certificate-Based Authentication: Digital certificate deployment for system-to-system communication, automated processes, and high-security access scenarios, with public key infrastructure (PKI) management, certificate lifecycle management, and revocation procedures.

Risk-Based and Adaptive Authentication: Dynamic authentication requirement adjustment based on real-time risk assessment considering user behavior patterns, geographic location, device characteristics, and access context for optimal security and user experience balance.

6.02.2 Authorization Framework and Policy Engine

Role-Based Access Control (RBAC): Comprehensive role definition and management system aligning access permissions with organizational hierarchy, job functions, and business responsibilities, with role inheritance, constraint management, and separation of duties enforcement.

Attribute-Based Access Control (ABAC): Advanced access control system enabling dynamic access decisions based on user attributes, resource characteristics, environmental conditions, and policy rules for fine-grained access control and complex authorization scenarios.

Zero Trust Architecture Principles: Implementation of continuous verification and minimal trust assumptions, with every access request authenticated, authorized, and encrypted regardless of user location or network connection, supported by comprehensive monitoring and behavioral analysis.

Section 6.03 Privileged Access Management and Monitoring

6.03.1 Administrative Access Controls and Oversight

Privileged Account Management: Centralized management and control of administrative accounts, service accounts, and elevated privilege assignments, with account lifecycle management, password management, and regular account review and validation procedures.

Session Recording and Audit Trail Maintenance: Complete recording of privileged user sessions, administrative activities, and system modifications, with secure storage, searchable audit logs, and comprehensive forensic capabilities for security investigation and compliance verification.

Break-Glass Emergency Access Procedures: Documented emergency access procedures for critical system access during security incidents or business emergencies, with enhanced logging, approval workflows, and post-incident review and validation processes.

6.03.2 Third-Party Access Management and Vendor Controls

Vendor Access Management and Oversight: Controlled and monitored access for third-party service providers, with time-limited access permissions, activity monitoring, session recording, and comprehensive audit trail maintenance for all external party system interactions.

Remote Support Security and Session Management: Secure channels and comprehensive session monitoring for remote technical assistance, with approval workflows, session recording, activity logging, and immediate access termination capabilities upon session completion.

Contractor Access Controls and Lifecycle Management: Time-limited access provisioning for contractors and temporary personnel, with regular access review, automatic expiration, reauthorization procedures, and prompt access removal upon engagement termination.

ARTICLE VII. INCIDENT RESPONSE AND BUSINESS CONTINUITY

Section 7.01 Security Incident Response Framework

7.01.1 Incident Response Team and Governance Structure

Dedicated Incident Response Team: Cross-functional team comprising information security professionals, technical specialists, legal counsel, communications personnel, and executive leadership with clearly defined roles, responsibilities, and escalation authorities for comprehensive incident management.

Incident Classification and Severity Assessment: Standardized incident categorization methodology based on potential impact, affected systems, data sensitivity, stakeholder implications, and regulatory requirements, with corresponding response procedures and timeline requirements for each severity level.

Response Coordination and Communication Protocols: Structured communication plans for internal stakeholder notification, client communication, regulatory reporting, law enforcement coordination, and media relations, with pre-approved messaging templates and escalation procedures.

7.01.2 Incident Response Process and Procedures

Detection and Analysis Phase: Rapid incident identification through automated monitoring systems, manual reporting procedures, threat intelligence integration, and systematic analysis to determine incident scope, impact, and appropriate response measures.

Containment and Eradication Activities: Immediate response protocols to limit incident impact, prevent further system compromise, preserve digital evidence, eliminate threats, and restore system integrity while maintaining comprehensive documentation of all response activities.

Recovery and Restoration Procedures: Systematic restoration of affected systems and services, validation of system integrity, implementation of enhanced monitoring, and gradual return to normal operations with continued vigilance for recurring incidents or related threats.

Post-Incident Activities and Lessons Learned: Comprehensive post-incident review process including root cause analysis, response effectiveness evaluation, process improvement identification, stakeholder communication, and integration of lessons learned into incident response procedures and security controls.

Section 7.02 Business Continuity and Disaster Recovery

7.02.1 Business Impact Analysis and Recovery Planning

Critical Process Identification and Dependency Mapping: Systematic identification of essential business functions, technology dependencies, resource requirements, and interdependencies to inform recovery prioritization and resource allocation during business disruption events.

Recovery Time and Point Objectives: Establishment of maximum acceptable downtime periods (Recovery Time Objectives) and maximum acceptable data loss thresholds (Recovery Point Objectives) for critical systems and business processes, with corresponding technology investments and recovery procedures.

Resource Requirements and Capacity Planning: Comprehensive assessment of personnel, technology, facility, and financial resources necessary for effective business continuity and disaster recovery, with resource pre-positioning, vendor agreements, and capacity management procedures.

7.02.2 Continuity Implementation and Testing

Backup and Recovery System Architecture: Comprehensive data backup systems with geographically distributed storage, automated backup processes, regular restoration testing, and recovery validation procedures to ensure data availability and system recovery capabilities.

Alternate Site and Infrastructure Management: Geographically distributed alternate facilities and infrastructure capabilities for business continuity, with appropriate technology resources, communication systems, and personnel accommodation for sustained operations during extended disruptions.

Regular Testing and Validation Programs: Systematic testing of business continuity and disaster recovery procedures through tabletop exercises, technical recovery tests, and comprehensive business continuity simulations to validate plan effectiveness and identify improvement opportunities.

Section 7.03 Crisis Management and Stakeholder Communication

7.03.1 Crisis Response Team and Decision-Making Authority

Executive Crisis Response Team: Senior leadership team with ultimate decision-making authority for strategic crisis response, resource allocation, stakeholder communication, and business continuity decisions during major incidents affecting organizational operations or reputation.

Multi-Channel Communication Systems: Redundant communication capabilities for crisis coordination including voice, data, and video communication systems, with backup communication methods, mobile coordination capabilities, and integration with emergency services and regulatory authorities.

7.03.2 External Communication and Regulatory Coordination

Media Relations and Public Communication: Coordinated public relations response for reputation management during security incidents, with pre-approved messaging, media training for spokespeople, social media management, and stakeholder communication coordination.

Regulatory Authority and Law Enforcement Liaison: Established procedures for coordination with regulatory authorities, law enforcement agencies, and industry partners during security incidents, with appropriate legal counsel involvement and compliance with notification requirements.

ARTICLE VIII. PERFORMANCE MEASUREMENT AND CONTINUOUS IMPROVEMENT

Section 8.01 Security Metrics and Key Performance Indicators

8.01.1 Technical Security Metrics and Monitoring

Security Incident Management Metrics: Comprehensive measurement of incident frequency, severity distribution, response times, resolution effectiveness, and recovery performance to assess security program effectiveness and identify improvement opportunities.

Vulnerability Management Performance: Systematic tracking of vulnerability identification, assessment, prioritization, and remediation activities, including time-to-patch metrics, vulnerability age distribution, and risk reduction effectiveness measurements.

System Availability and Performance Monitoring: Continuous monitoring of critical system uptime, availability percentages, performance benchmarks, and service delivery metrics to ensure security controls do not adversely impact business operations and service quality.

8.01.2 Governance and Compliance Performance Indicators

Training and Awareness Program Effectiveness: Measurement of security awareness training completion rates, knowledge retention assessment, behavioral change indicators, and phishing simulation performance to evaluate security culture development and training program effectiveness.

Policy Compliance and Adherence Monitoring: Regular assessment of organizational compliance with security policies, procedures, and control requirements, with compliance rate tracking, exception management, and corrective action implementation monitoring.

Vendor and Third-Party Security Performance: Systematic evaluation of vendor security compliance, performance against contractual security requirements, incident frequency, and security assessment results to ensure third-party relationships maintain appropriate security standards.

Section 8.02 Regular Assessment and Audit Programs

8.02.1 Internal Assessment and Self-Evaluation

Security Control Effectiveness Reviews: Systematic internal evaluation of security control implementation, effectiveness, and alignment with business requirements, with regular testing procedures, control validation, and improvement opportunity identification.

Risk Assessment and Management Evaluation: Periodic assessment of security risk landscape, control effectiveness, residual risk levels, and risk management program performance to ensure appropriate risk mitigation and business protection.

8.02.2 External Validation and Independent Assessment

Third-Party Security Assessments: Regular engagement of qualified external security professionals for independent evaluation of security posture, control effectiveness, and compliance with industry standards and regulatory requirements.

Professional Penetration Testing and Vulnerability Assessment: Systematic engagement of ethical hackers and security testing professionals to identify vulnerabilities, assess attack resistance, and validate security control effectiveness through simulated attack scenarios.

Regulatory and Compliance Auditing: Formal assessment by qualified auditors for compliance validation with applicable regulations, industry standards, and client security requirements, with audit finding remediation and continuous improvement implementation.

Section 8.03 Continuous Improvement and Enhancement

8.03.1 Gap Analysis and Enhancement Planning

Security Posture Gap Analysis: Regular identification of security gaps, control deficiencies, and improvement opportunities through comparison with industry benchmarks, regulatory requirements, and evolving threat landscapes.

Technology Evolution and Enhancement Integration: Systematic evaluation and adoption of emerging security technologies, methodologies, and best practices to maintain security effectiveness and competitive advantage in threat protection capabilities.

8.03.2 Process Optimization and Enhancement

Security Process Improvement and Automation: Continuous optimization of security procedures, workflow automation, efficiency enhancement, and resource optimization to improve security effectiveness while reducing operational overhead and complexity.

Stakeholder Feedback Integration: Systematic collection and analysis of feedback from clients, employees, partners, and other stakeholders to identify security program improvements, service enhancements, and stakeholder satisfaction optimization opportunities.

ARTICLE IX. CONTACT INFORMATION AND GOVERNANCE

Section 9.01 Security Program Leadership and Contact Information

For questions, concerns, or communications regarding this Data Security Framework and our information security practices:

Technology Officer - Information Security
Assivo, Inc.
444 West Lake Street, Suite 1700
Chicago, Illinois 60606
Telephone: (312) 416-8649
Email: security@assivo.com

Section 9.02 Security Incident Reporting and Response

Security Incident Response Team
24/7 Incident Response Hotline: (312) 416-8649
Email: security@assivo.com
Secure Incident Reporting: Available through designated client communication channels

Section 9.03 Regional Security Coordination

Global Security Coordination:

Americas Operations: americas@assivo.com
Mexico Operations: mexico@assivo.com
India Operations: india@assivo.com

This Data Security Framework represents our comprehensive commitment to maintaining enterprise-grade information security standards and protecting stakeholder information assets. It serves as the foundation for our security program and should be implemented alongside applicable legal requirements, regulatory standards, and industry best practices.