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9. A business resiliency program which                •  Network security controls and perimeter infrastructure
          effectively addresses business continuity,              risk assessments, including the use of multi-tiered
          disaster recovery and incident response                 firewalls, intrusion prevention systems and web
                                                                  application firewalls designed to protect the network
          Empower takes a multi-tiered approach to resiliency
          that includes an Incident Response Plan (IRP). The IRP   from outside attack
          provides guidelines for specific scenarios, including cyber-  •  Distributed denial of service (DDoS) defense and
          attacks, facility or technology disruptions, and many other   mitigation, endpoint security and data loss prevention
          scenarios. The IRP also provides a framework to assess   (DLP) solutions
          and facilitate rapid remediation related to unknown   •  Malicious code protection, including anti-virus
          disruptions and defines roles, responsibilities and disaster   technology, Endpoint Detection and Response (EDR)
          declaration processes. A dedicated Enterprise Resiliency   and other systems and controls designed to protect
          team oversees updates to and validations of the IRP,    against malware
          Business Continuity, and Disaster Recovery plans. An
          annual Business Impact Assessment (BIA) is conducted.    •  Threat-management procedures, including security
          A multi-channel emergency communication system is       operation centers operate 24/7/365, are designed
          utilized allow rapid response and communication during   to detect and manage advanced computer security
          disruptions. Additional information is found here on our   incidents and persistent threats, and follow a formalized
          website: Business Continuity Plan.                      process for acting on identified threats
                                                                •  Regularly scheduled internal and external network and
          10. Encryption of sensitive data stored and             application development vulnerability scans performed
          in transit                                              by independent security assessment firms and Empower
                                                                  security administration teams
          Empower encrypts all sensitive data at rest (stored) and
          in transit. All data at rest within the Empower network,   •  An enterprise-wide computer security incident
          including mobile devices, removable media and backup    response team (CSIRT) linked with the enterprise crisis
          media, is encrypted. All Empower laptops and desktops   response team
          are fully encrypted. Empower does not allow copying of   •  Empower consumes numerous threat intelligence
          data to USBs, CDs, DVDs. Empower’s cloud data both in   sources to stay informed of the latest risks, including
          transit and at rest, is encrypted.                      solutions such as membership in threat intelligence

                                                                  sharing groups, monitoring of vendor announcements
          11. Strong technical controls implementing              and consuming intelligence feeds from security vendors
          best security practices
                                                                •  Encryption of sensitive information at rest
          We employ industry-leading technology and security      and when transferred electronically on public
          measures designed to defend against cybersecurity       communication networks
          threats and safeguard client-sensitive information.
          Protection methods and resources include, but are not
          limited to:













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