Notify the sponsor bank immediately of a breach and keep it informed to closure

Incident Response policy, §5.1, §5.3, §5.4

Any breach at the Company or a critical service provider that discloses account holder data or other sponsor bank confidential information is reported to the sponsor bank immediately, with the nature of the breach and the corrective action taken, and the disclosure is stopped or limited at once. Any Critical incident is reported to the bank’s chief compliance officer and chief risk officer within four hours of confirmation, updated at least daily until resolution, and closed with a written report within ten business days. The bank may send an assessor, and the Company gives the access requested.

Event-driven

Immediately on a breach; within 4 hours of confirming a Critical incident; daily until resolved; closure report within 10 business days

Send the initial notice to the bank’s named contacts, log the time, deliver a daily update while the incident is open, and file the closure report with the timeline, root cause, remediation, and customer-notice evidence.

• Sponsor bank notice

  Initial notice with the time sent, against the confirmation time

• Update log

  Daily updates with dates until resolution

• Incident closure report

  Written report delivered within 10 business days of resolution

Compliance Officer

Leela can draft the notice, the daily updates, and the closure report from the incident record, keep each clock, and hand every message to the Compliance Officer to send.

Tell Leela about your company to see whether this applies.