Resources
Compliance
Trust and Security Program Summary
Trooth's security, governance, privacy and compliance program at a glance.
GDPR Compliance Statement
Trooth's GDPR obligations as processor and controller, article by article.
CCPA / CPRA Compliance Statement
Trooth's position under the CCPA as amended, including that it does not sell personal information.
NIST Cybersecurity Framework 2.0 Profile
Trooth's profile against the six CSF functions: outcomes met and not yet met.
NIST SP 800-171 Self-Assessment
A self-assessment against the 110 requirements: results, method and requirements marked not applicable.
Security, Privacy and Compliance Self-Assessment (CAIQ and SIG)
Trooth's completed self-assessment in the two questionnaire formats buyers send most.
CISA Secure by Design Pledge
Trooth's signed pledge. CISA publishes the roster; this document is not an entry, and Trooth has not yet confirmed one.
Information Security Risk Register
Tracked risks with owners, likelihood, impact, treatment and review dates.
Information Asset Inventory
Cataloged systems and data assets by classification.
Policies
POL-01 Information Security Policy
The parent policy: principles, roles, the policy set and how it is kept current.
POL-02 Access Control Policy
Who is granted access to what, on what basis, and how it is removed.
POL-03 Password and Authentication Policy
Password strength, storage, multi-factor authentication, lockout and session rules.
POL-04 Data Classification and Handling Policy
The four classification levels and the handling each one requires.
POL-05 Encryption and Key Management Policy
Cryptography in transit and at rest, permitted algorithms, keys and secrets.
POL-06 Secure Development and Change Management Policy
The one permitted path to production: gates, review, rollback and emergency change.
POL-07 Vulnerability Management Policy
How vulnerabilities are found, given a severity and fixed, with remediation timelines.
POL-08 Logging, Monitoring and Access Review Policy
What is logged, how records are protected, alerting, and the access-review schedule.
POL-09 Incident Response Policy
Severities, response times, containment, customer notice and the post-mortem.
POL-10 Business Continuity and Disaster Recovery Policy
Recovery objectives, failure scenarios and what happens if Trooth's operators are unavailable.
POL-11 Backup and Data Retention Policy
Nightly encrypted backups, the restore rehearsal, and the retention schedule with disposal events.
POL-12 Asset Management Policy
How systems, data, code, domains, credentials and devices are inventoried and retired.
POL-13 Risk Management Policy
How risks are identified, assessed, treated and reviewed, and where the register is kept.
POL-14 Vendor and Third-Party Risk Management Policy
Due diligence before a vendor is engaged, the DPA requirement, review and exit.
POL-15 Acceptable Use Policy (Personnel)
What people with access may and may not do with Company systems and data.
POL-16 Human Resources Security Policy
Screening, agreements, training and offboarding for anyone who acts for the Company.
POL-17 Physical and Environmental Security Policy
Physical controls inherited from the providers, and the rules for devices the Company holds.
POL-18 Data Residency and Regional Processing Policy
Where data rests and is processed, and how customers are told before either changes.
POL-19 AI Governance and Acceptable AI Use Policy
Where AI is used, the decisions a person always makes, and the rules for AI tools.
Security
Security Overview
Authentication, sessions, keys, tenant isolation, the audit ledger, encryption and monitoring.
Access Monitoring and Logging Statement
What access and use is recorded, where, how it is protected and who reads it.
Automated Backup and Data Retention Statement
Nightly encrypted backups, the monthly restore proof, recovery objectives and the retention schedule.
Encryption in Transit and at Rest Assurance Statement
TLS, HSTS and AES-256, permitted algorithms, and checks anyone can run.
Network Architecture and Data Flow Disclosure
Components, request path, data flows, trust boundaries and residency region.
Vulnerability Disclosure Policy
How to report a vulnerability, the scope, and the safe harbor for good-faith research.
security.txt
Machine-readable contact and policy pointers at the standard well-known location.
Business Continuity Statement
Recovery objectives, backup cadence, the failure scenarios and the recovery path for each.
Incident Response Runbook
The runbook behind the Incident Response Policy: who does what, in what order, with which accounts.
Business Continuity and Disaster Recovery Plan
The full plan behind the published statement, including the operator-unavailability runbook.
AI Governance
AI System Fact Sheet (Model Card)
What Trooth's AI-assisted features do, for whom, their inputs, outputs and limitations.
AI Use Policy
Where generative AI is and is not used, decisions a person always makes, and no training on customer content.
AI Disclosure
The Network's automated systems and what each does and does not do.
EU AI Act Transparency and Risk Classification
Trooth's role, each AI feature's risk category, and how each transparency obligation is met.
EU AI Act Compliance Statement
Trooth's position under the Regulation as a provider of limited-risk AI features.
EU AI Pact Commitments
The commitments Trooth signed with the European Commission ahead of the AI Act's application.
NIST AI RMF Alignment Statement
Trooth's AI governance mapped to the framework's four functions, with the gaps named.
Regulatory
REG-01 Data Protection Impact Assessment
The Network's risk assessment: nine risks, measures, residual risk, and three measures not yet in place.
REG-02 United States State Privacy Laws Statement
Trooth's position under comprehensive state privacy laws outside California, and the universal answers each asks for.
REG-03 Fair Credit Reporting Act Non-Applicability Statement
Why Trooth is not a consumer reporting agency and the Network is not a consumer report, element by element, and the limits that keep it true.
REG-04 PIPEDA Compliance Statement (Canada)
Canada's ten PIPEDA principles, and that Canadian data is stored outside Canada, mainly in the United States.
REG-05 India Digital Personal Data Protection Act Statement
Trooth's position under India's Digital Personal Data Protection Act, 2023, obligation by obligation.
REG-06 Written Information Security Program (FTC Safeguards Rule)
A voluntary written information security program in FTC Safeguards Rule form; the Rule does not reach Trooth.
REG-07 23 NYCRR Part 500 Third-Party Service Provider Statement
Section 500.11 answered point by point, for a NYDFS Covered Entity doing its third-party due diligence.
REG-08 NIS 2 Directive Supplier Statement
Article 21(2) measures answered as a supplier to an entity in NIS 2 scope; Trooth itself is not in scope.
REG-09 HIPAA Non-Applicability and Business Associate Readiness
Why HIPAA does not reach Trooth, its Security Rule position, and its BAA terms.
REG-10 EU AI Act Article 53 Non-Applicability and Model Transparency
Why Article 53 model-provider obligations fall on the model providers, not Trooth, and what Trooth can say about the models it calls.
REG-11 DORA ICT Third-Party Service Provider Statement
What a financial entity needs for its DORA register, with Article 30 provisions answered one by one.
REG-12 APRA CPS 230 Service Provider Statement (Australia)
Materiality under CPS 230, the paragraph 53 provisions answered, and the CPS 234 gaps a regulated entity should weigh.
Privacy
Privacy Policy
What is collected, why, for how long, by whom, and how to exercise your rights.
Data Processing Addendum (DPA)
Processor terms with the standard contractual clauses, incorporated into customer terms without negotiation.
Sub-processor List
Every third party processing customer personal data, with purpose, region and change log.
Data Retention Summary
The maximum retention period and the disposal event for each kind of data.
Data Subject Rights Request Procedure
How to exercise access, correction, portability and erasure rights, and what happens within 30 days.
Records of Processing Activities (RoPA)
GDPR Article 30 records: purposes, categories, recipients and retention.
Data Protection Impact Assessment (DPIA)
The risk assessment for the Network's processing of company and buyer data.
Data Retention and Disposal Schedule
The internal schedule behind the published summary, with disposal methods for each system.
Legal
Terms of Service
The terms every account accepts.
Acceptable Use Policy
What may and may not be done with the product.
End User License Agreement
License terms for the software.
Service Level Agreement
Availability commitments and the remedy when they are missed.
API Terms
Terms for programmatic access, keys and rate limits.
Accessibility Statement
Trooth's conformance target, what the build tests, and how to report a barrier.
Abbreviations used in the Trust Center
- AES
- Advanced Encryption Standard
- AI
- artificial intelligence
- API
- application programming interface
- APRA
- Australian Prudential Regulation Authority
- AWS
- Amazon Web Services
- BAA
- business associate agreement (HIPAA)
- CAIQ
- Consensus Assessments Initiative Questionnaire (Cloud Security Alliance)
- CCPA
- California Consumer Privacy Act
- CISA
- Cybersecurity and Infrastructure Security Agency (United States)
- CPRA
- California Privacy Rights Act
- CSA
- Cloud Security Alliance
- CSF
- Cybersecurity Framework (NIST)
- CPS
- Cross-Industry Prudential Standard (APRA)
- DORA
- Digital Operational Resilience Act (European Union)
- DPA
- data processing agreement
- DPDP
- Digital Personal Data Protection Act (India)
- DPIA
- data protection impact assessment
- DSS
- Data Security Standard (PCI)
- EU
- European Union
- FTC
- Federal Trade Commission (United States)
- GDPR
- General Data Protection Regulation (European Union)
- HIPAA
- Health Insurance Portability and Accountability Act
- HSTS
- HTTP Strict Transport Security
- HTTP
- Hypertext Transfer Protocol
- HTTPS
- HTTP over TLS
- ICT
- information and communication technology
- IEC
- International Electrotechnical Commission
- ISO
- International Organization for Standardization
- LLC
- limited liability company
- NDA
- non-disclosure agreement
- NIS
- Network and Information Security Directive (European Union)
- NIST
- National Institute of Standards and Technology (United States)
- NYCRR
- New York Codes, Rules and Regulations
- NYDFS
- New York State Department of Financial Services
- PBKDF2
- Password-Based Key Derivation Function 2
- PCI
- Payment Card Industry
- PIPEDA
- Personal Information Protection and Electronic Documents Act (Canada)
- RMF
- Risk Management Framework (NIST)
- SHA
- Secure Hash Algorithm
- SIG
- Standardized Information Gathering questionnaire (Shared Assessments)
- SOC
- System and Organization Controls (AICPA)
- SP
- Special Publication (NIST)
- STAR
- Security, Trust, Assurance and Risk registry (Cloud Security Alliance)
- TLS
- Transport Layer Security
- TOTP
- time-based one-time password
- URL
- web address (uniform resource locator)