Effective: April 4, 2024 · Next independent review: October 2024
Data Sources
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Real-time equities/derivatives feeds delivered through
customer-managed VPN tunnels.
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Internal investment memos and risk ratings synced via hardened
SFTP pull jobs.
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User profile data limited to role, desk, and regulatory
restrictions; no personal trading history is collected.
Processing Controls
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Each data source receives a dedicated tokenization policy with
irreversible surrogate keys.
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Alert payloads store only context needed for supervision and
expire within 30 days unless escalated to audit.
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Model training environments are segmented between surveillance
and research workloads to maintain SOX and Chinese Wall
constraints.
Security & Access
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Conditional access integrates with client IdPs to enforce trader
entitlements and MFA.
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Feed ingestion endpoints employ signed requests, hardware root
of trust, and immutable audit logs retained for seven years.
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Quarterly red-team exercises validate insider threat
monitoring, with findings shared under NDA.
Customer Oversight
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Clients configure custom retention, jurisdiction, and trade
surveillance rules before activation.
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Daily privacy posture reports summarize ingestion status,
alerting volume, and outstanding purge tickets.
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Dedicated XM operator ensures alignment with SEC, FINRA, and
SOX requirements throughout the deployment lifecycle.