Information Security Policy

SeaCoast Financial LLC

Effective Date: May 31, 2025

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This Information Security Policy defines the principles, practices, and governance SeaCoast Financial LLC adheres to in order to safeguard its information assets, with a specific emphasis on protecting cardholder data in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and other applicable regulations.

SeaCoast Financial LLC recognizes its responsibility to ensure the confidentiality, integrity, and availability of sensitive information, including data entrusted to it by customers, partners, and service providers. This document establishes minimum information security requirements for all personnel, technologies, and third-party interactions.

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This policy applies to all employees, contractors, consultants, temporaries, and other workers at SeaCoast Financial LLC, including all personnel affiliated with third parties. All users of SeaCoast Financial LLC’s information systems are required to adhere to the standards outlined herein.

The policy will be reviewed and updated annually or upon significant organizational or regulatory change. All personnel must acknowledge their understanding and compliance through a signed agreement as outlined in Appendix A.

For questions regarding the content or implementation of this policy, please contact the Chief Information Security Officer (CISO) or the Information Security team.

Contents

Introduction.
Information Security Policy.
Acceptable Use Policy.
Disciplinary Action.
Compliance Policy.
Information Security Procedures and Standards Policy.
Protect Stored Data.
Information Classification.
Access to the sensitive cardholder data.
Physical Security.
Protect Data in Transit
Disposal of Stored Data.
Security Awareness and Procedures.
Network security.
System and Password Policy.
Anti-virus policy.
Patch Management Policy.
Remote Access policy.
System Administration Access policy.
Vulnerability Management Policy.
Configuration standards:
Change control Process.
Audit and Log review.
Secure Application development
Penetration testing methodology.
Incident Response Plan.
Roles and Responsibilities.
Third party and security of card holder data.
User Access Management
Access Control Policy.
Wireless Policy.
Encryption Policy.

Appendix A.

Appendix B.

1. Introduction

This Policy Document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and understand this policy fully. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and distribute it all employees and contracts as applicable.

2. Information Security Policy

SeaCoast Financial LLC handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect them, to protect cardholder privacy, to ensure compliance with various regulations and to guard the future of the organisation.

SeaCoast Financial LLC commits to respecting the privacy of all its customers and to protecting any data about customers from outside parties. To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.

Employees handling Sensitive cardholder data should ensure:

Handle Company and account data including cardholder information in a manner that fits with their sensitivity;
Limit personal use of SeaCoast Financial LLC information and telecommunication systems and ensure it doesn’t interfere with your job performance;
SeaCoast Financial LLC reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
Do not disclose personnel information unless authorised;
Protect sensitive cardholder information;
Do not use e-mail or other end messaging technologies such as messenger WhatsApp, Signal to share sensitive data including account data in the form of cardholder information.
Keep passwords and accounts secure;
Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.

We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.

3. Acceptable Use Policy

The Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to SeaCoast Financial LLC’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and SeaCoast Financial LLC from illegal or damaging actions by individuals, either knowingly or unknowingly. SeaCoast Financial LLC will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.

Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies
Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
Employees should ensure that technologies should be used and setup in acceptable network locations
Keep passwords secure and do not share accounts.
Authorized users are responsible for the security of their passwords and accounts.
All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.
All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
Because information contained on portable computers is especially vulnerable, special care should be exercised.
Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of SeaCoast Financial LLC, unless posting is in the course of business duties.
Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.

4. Disciplinary Action

Violation of the standards, policies and procedures presented in this document by an employee will result in disciplinary action, from warnings or reprimands up to and including termination of employment. Claims of ignorance, good intentions or using poor judgment will not be used as excuses for non compliance.

5. Compliance Policy

This policy aims to ensure that SeaCoast Financial LLC conducts its business in full compliance with all national and international laws and regulations that pertain to its industry, as well as professional standards, accepted business practices, and internal standards.

The data processed by SeaCoast Financial LLC need to be identified along with the relevant laws, regulations and industry standards.
The scope including assets, network diagrams, dataflow diagrams and data storage repositories need to be documented in accordance with identified laws and regulations.

6. Information Security Procedures and Standards Policy

In relation to this Information security policy and relevant laws regulation and industry standards SeaCoast Financial LLC need to maintain up to date documentation and ensure they are relevant and updated when changes are made as well as reviewed for accuracy on an annual basis.

The documents include procedures, standards, asset lists, network diagrams, cardholder flow diagrams.

7. Protect Stored Data

All sensitive cardholder data stored and handled by SeaCoast Financial LLC and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by SeaCoast Financial LLC for business reasons must be discarded in a secure and irrecoverable manner.
If there is no specific need to see the full PAN (Primary Account Number), it has to be masked when displayed.
PAN’S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like email, WhatsApp, messenger, signal and other chat programs.

It is strictly prohibited to store:

The contents of the payment card magnetic stripe (track data) on any media whatsoever.
The sensitive authentication data in form of CVV2/CVC2/CAV2/CID (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
The PIN or the encrypted PIN Block under any circumstance.

8. Information Classification

Data and media containing data must always be labelled to indicate sensitivity level

Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to SeaCoast Financial LLC if disclosed or modified. Confidential data includes account data and cardholder data.
Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure;
Public data is information that may be freely disseminated.

9. Access to the sensitive cardholder data

All Access to sensitive cardholder should be controlled and authorised. Any Job functions that require access to cardholder data should be clearly defined.

Any display of the card holder should be restricted at a minimum of the first 6 and the last 4 digits of the cardholder data.
Access rights to privileged user ID’s should be restricted to least privileges necessary to perform job responsibilities
Privileges should be assigned to individuals based on job classification and function (Role based access control)
Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
No other employees should have access to this confidential data unless they have a genuine business need.
If cardholder data is shared with a Third Party Service Provider (TPSP) or a TPSP can affect the security of cardholder data then a list of such TPSP’s will be maintained as detailed in Appendix B.
SeaCoast Financial LLC will ensure a written agreement that includes an acknowledgement is in place that the TPSP will be responsible for the for the cardholder data that the TPSP possess or can affect the security off.
SeaCoast Financial LLC will ensure that a there is an established process including proper due diligence is in place before engaging with a TPSP.
SeaCoast Financial LLC will have a process in place to monitor the PCI DSS compliance status of the TPSP.

10. Physical Security

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.

Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies
Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
Employees should ensure that technologies should be used and setup in acceptable network locations
A list of devices that accept payment card data should be maintained.
The list should include make, model and location of the device
The list should have the serial number or a unique identifier of the device
The list should be updated when devices are added, removed or relocated
POS devices (POI/Terminals) surfaces should be periodically inspected to detect tampering or substitution.
Personnel using the devices should be trained and aware of handling the POS devices
Personnel using the devices should verify the identity of any third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel.
A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.
Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.
Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.
Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on SeaCoast Financial LLC sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
Network Jacks located in public and areas accessible to visitors must be disabled and enabled when network access is explicitly authorised.
All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
Strict control is maintained over the storage and accessibility of media
All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.

11. Protect Data in Transit

All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.

Card holder data (PAN, track data etc) must never be sent over the internet via email, instant chat or any other end user technologies.

If there is a business justification to send cardholder data via email or via the internet or any other modes then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, GSM, GPRS, Wireless technologies etc.,).
The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.

12. Disposal of Stored Data

All data must be securely disposed of when no longer required by SeaCoast Financial LLC, regardless of the media or application type on which it is stored.

An automatic process must exist to permanently delete on-line data, when no longer required.
All hard copies of cardholder data must be manually destroyed as when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
SeaCoast Financial LLC will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
SeaCoast Financial LLC will have documented procedures for the destruction of electronic media. These will require:
- All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
- If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.

All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” – access to these containers must be restricted.

13. Security Awareness and Procedures

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.

Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A)
All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with SeaCoast Financial LLC.
All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
Company security policies must be reviewed annually and updated as needed.
Security awareness training need to include awareness on phishing.
The security awareness training need to be updated at least annually.

14. Network security

Firewalls must be implemented at each internet connection and any demilitarized zone and the internal company network.
A network diagram detailing all the inbound and outbound connections must be maintained and reviewed every 6 months.
A firewall and router configuration document must be maintained which includes a documented list of services, protocols and ports including a business justification.
Firewall and router configurations must restrict connections between untrusted networks and any systems in the card holder data environment.
Stateful Firewall technology must be implemented where the Internet enters SeaCoast Financial LLC Card network to mitigate known and on-going threats. Firewalls must also be implemented to protect local network segments and the IT resources that attach to those segments such as the business network, and open network.
All inbound and outbound traffic must be restricted to that which is required for the card holder data environment.
All inbound network traffic is blocked by default, unless explicitly allowed and the restrictions have to be documented.
All outbound traffic has to be authorized by management (i.e. what are the whitelisted category of sites that can be visited by the employees) and the restrictions have to be documented
SeaCoast Financial LLC will have firewalls between any wireless networks and the cardholder data environment.
SeaCoast Financial LLC will quarantine wireless users into a DMZ, where they will be authenticated and firewalled as if they were coming in from the Internet.
Disclosure of private IP addresses to external entities must be authorized.
A topology of the firewall environment has to be documented and has to be updated in accordance to the changes in the network.
The firewall rules will be reviewed on a six months basis to ensure validity and the firewall has to have clean up rule at the bottom of the rule base.
SeaCoast Financial LLC have to quarantine wireless users into a DMZ, where they were authenticated and firewalled as if they were coming in from the Internet.
No direct connections from Internet to cardholder data environment will be permitted. All traffic has to traverse through a firewall.

15. System and Password Policy

All users, including contractors and vendors with access to SeaCoast Financial LLC systems, are responsible for taking the appropriate steps, as outlined below, to select and secure their passwords.

A system configuration standard must be developed along industry acceptable hardening standards (SANS, NIST, ISO)
System configurations should be updated as new issues are identified (as defined in PCI DSS requirement 6.3)
System configurations must include common security parameter settings
The systems configuration standard should be applied to any news systems configured.
All vendor default accounts and passwords for the systems have to be changed at the time of provisioning the system/device into SeaCoast Financial LLC network and all unnecessary services and user/system accounts have to be disabled.
All unnecessary default accounts must be removed or disabled before installing a system on the network.
Security parameter settings must me set appropriately on System components
All unnecessary functionality (scripts, drivers, features, subsystems, file systems, web servers etc.,) must be removed.
All unnecessary services, protocols, daemons etc., should be disabled if not in use by the system.
Any insecure protocols, daemons, services in use must be documented and justified.
All users with access to card holder data must have a unique ID.
All user must use a password to access SeaCoast Financial LLC network or any other electronic resources
All user ID’s for terminated users must be deactivated or removed immediately.
The User ID will be locked out if there are more than 5 unsuccessful attempts. This locked account can only be enabled by the system administrator. Locked out user accounts will be disabled for a minimum period of 30 minutes or until the administrator enables the account.
All system and user level passwords must be changed on at least a quarterly basis.
A minimum password history of four must be implemented.
A unique password must be setup for new users and the users prompted to change the password on first login.
Group, shared or generic user account or password or other authentication methods must not be used to administer any system components.
Where SNMP is used, the community strings must be defined as something other than the

Standard defaults of “public,” “private” and “system” and must be different from the passwords used to log in interactively.

All non-console administrative access will use appropriate technologies like ssh,vpn etc or strong encryption is invoked before the administrator password is requested
System services and parameters will be configured to prevent the use of insecure technologies like telnet and other insecure remote login commands
Administrator access to web based management interfaces is encrypted using strong cryptography.
The responsibility of selecting a password that is hard to guess generally falls to users. A strong password must:

1. 1. 1. Be as long as possible (never shorter than 12 characters).
    2. Include mixed-case letters, if possible.
    3. Include digits and punctuation marks, if possible.
    4. Not be based on any personal information.
    5. Not be based on any dictionary word, in any language.

If an operating system without security features is used (such as DOS, Windows or MacOS), then an intruder only needs temporary physical access to the console to insert a keyboard monitor program. If the workstation is not physically secured, then an intruder can reboot even a secure operating system, restart the workstation from his own media, and insert the offending program.
To protect against network analysis attacks, both the workstation and server should be cryptographically secured. Examples of strong protocols are the encrypted Netware login and Kerberos.

16. Anti-virus policy

All machines must be configured to run the latest anti-virus software as approved by SeaCoast Financial LLC. The preferred application to use is XXXX Anti-Virus software, which must be configured to retrieve the latest updates to the antiviral program automatically on a daily basis. The antivirus should have periodic scanning enabled for all the systems.
The antivirus software in use should be cable of detecting all known types of malicious software (Viruses, Trojans, adware, spyware, worms and rootkits)
All removable media (for example floppy and others) should be scanned for viruses before being used.
All the logs generated from the antivirus solutions have to be retained as per legal/regulatory/contractual requirements or at a minimum of PCI DSS requirement 10.7 of 3 months online and 1 year offline.
Master Installations of the Antivirus software should be setup for automatic updates and periodic scans
End users must not be able to modify and any settings or alter the antivirus software
E-mail with attachments coming from suspicious or unknown sources should not be opened. All such e-mails and their attachments should be deleted from the mail system as well as from the trash bin. No one should forward any e-mail, which they suspect may contain virus.
E-mails need to be checked for phishing attempts.

17. Patch Management Policy

All Workstations, servers, software, system components etc. owned by SeaCoast Financial LLC must have up-to-date system security patches installed to protect the asset from known vulnerabilities.
Where ever