PaperClip Incorporated 3/7/06; Rev 8/12/14. PaperClip Compliant Service Whitepaper

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1 Incorporated 3/7/06; Rev 8/12/14 PaperClip Compliant Service Whitepaper

2 Contents Overview... 3 Adoption The Compliance Landscape... 4 PaperClip s Compliance Position... 6 PaperClip s Solution Approach... 6 Encryption Options... 9 The Relay Server em4 in the Clouds rd Party Shared Cloud Service Providers The Webmail Non Subscriber Service Administration Service Auditing Conclusion Update PaperClip Incorporated Page 2 of 21 8/12/2014

3 Overview The FTC Safeguard Rules require Financial, Insurance Medical and Education professionals to protect their customer s private information or Non Public Information (NPI). Updated regulations like HIPAA 2013 and Consumer Financial Protection Bureau (CFPB) rules along with other Federal and State laws makes it very clear that all electronic communications among third parties must be safeguarded. This requires special handling of electronic information specific to on the public Internet. messages must be encrypted before releasing them on the Internet. Many organizations have deployed solutions securing their internal domain traffic but either send in clear text to their trading partners or share their proprietary interface. Trading partners cannot effectively use and meet compliance. PaperClip proposes a compliant service that can address interoperability, compliance, ease of use and necessary auditing. Adoption 2014 Since 2007 Compliant Service has been widely adopted and proves that the industry advisors, who designed the service, got it right. We re excited about the future of and its evolution into a dynamic capture tool meeting the needs of efficiency while maintaining compliance. New services like C Cloud and XO CrossOver will continue Compliant as a leading solution solving today s challenges. We look forward to rolling out these new features in PaperClip Incorporated Page 3 of 21 8/12/2014

4 The Compliance Landscape The Internet has dramatically changed the way we conduct business today. The ability to deliver information, answer questions, and exchange ideas has benefited all who participate. One significant use of the Internet is electronic mail. The ability to replace a letter, fax or phone call with a simple electronic message has won the day. Storing and quickly retrieving these messages allow organizations to streamline its communications process and by today s business standards, has become a cornerstone of every business operations. In recent years, the United States Federal Government has passed new initiatives targeted at the way personal information must be handled on the public Internet. The major acts are Financial Services Modernization Act (GLB), Identity Theft Prevention Act of 2000, Health Insurance Portability and Accountability Act of 1996 (HIPAA 2013) and the Consumer Financial Protection Bureau (CFPB). These acts focus on different aspects of personal information but all have the same mandate, protecting customer s personal information from unwarranted access and the accountability for its use. Some of the strongest rules concern maintaining a six year audit of those who had access to the protected information. Further, technology providers hosting third party NPI (HIPAA 2013) are liable to these same agencies and subject to penalties and fines. PaperClip Incorporated Page 4 of 21 8/12/2014

5 Non Public Information (NPI) is defined as personal information, which by itself or with other information could allow access to private assets or health information. Items listed below are a representation of NPI; Social Security Number (9 digits) Address Demographic Information Phone Number Age Date of Birth Race Sex /gender Religion Mother's maiden name Driver's License Number Passport Number (9 digits) State identification card number Personal identification numbers Information commonly provided on an application for an insurance product or service. Logon IDs and Account passwords Digitized or other electronic signatures Employer assigned employment identification number AESC assigned ID (9 digits) Unique electronic identification number or routing code Government issued identification number Bank Account Number Debit Card Number (16 digits) Credit Card Number (15-16 digits) Payment History Account Balance Fund (investments) value/balance Factors around customer s income or assets Fact that person is a customer of a financial institution Fact that the customer is or has obtained insurance policy Financial account number or credit card or debit card number Information obtained when requesting or getting, collecting, or servicing a loan Information from a consumer or credit report Height or Weight Other medical specifics such as blood type Medical Conditions, Medical Diagnosis, Medical Test Results, Medications Used Past, present, or future physical, mental, or behavioral health Health care being provided Health-related policy premiums Health policy numbers Biometric data, such as fingerprints, retina, iris images or DNA profile PaperClip Incorporated Page 5 of 21 8/12/2014

6 PaperClip s Compliance Position Reviewing the compliance landscape outside of the box, PaperClip believes securing (encrypting) the message on the public Internet is the objective. Reasonable levels of authentication are satisfied with trust protocols around addressing. An individual that has an account (login and password) on a corporate sponsored infrastructure is a trusted individual therefore their address is secure and unique. If the reader is in agreement, simply sending an encrypted to a receiver which passes from and through respective firewalls decrypted and delivered to the receiver in clear text meets Safeguard Rule compliance requirements. PaperClip also believes a record of that transaction ( exchange) must be logged by and stored at a disinterested third party. The mere requirement for annual auditing implies impartiality. To only conduct internal audits on internal information can be considered a conflict of interest and typically receives the most scrutiny by regulatory agencies. Transactional information stored and made accessible to customers and authorized third parties provide a degree of integrity resulting in quicker, less expensive audits. The FTC s track record in legal settlements, have standard stipulation for monitoring and audits conducted by an independent third party every year for 10 to 20 years at the violator s expense. Adopting a third party auditing scheme as part of the service only enhances compliance. Conclusion - encrypting messages firewall to firewall and recording the transaction metadata with a third party meets the FTC and others Safeguard Rules. PaperClip Incorporated Page 6 of 21 8/12/2014

7 PaperClip s Solution Approach PaperClip believes any chance to overcome the current market solution shortcomings and gain wide adoption is to change the paradigm. Ten years ago PaperClip s Internet express was a new paradigm and its success today is measured with 500 plus customers exchanging over 4 million documents per month, a sixty percent growth year over year. PaperClip s approach again is to climb outside of the box and fix . Starting with some simple user requirements, a proven encryption algorithm, a vendor service track record with our eye on the target, a new paradigm is created (called for pronounced M4). The new approach resolves the many problems created in a diverse compliant industry: Encrypts s and their attachments firewall to firewall. Disinterested third party recording of transactions for auditing access. infrastructure independent, multiple deployment options. Ease of use accomplished, Subscriber s users don t have to learn something new. Commodity pricing, affordable by any size organization. s do not pass through the PaperClip Central Office. The Central Office serves only to manage encryption keys, subscribers and collect auditing information. PaperClip Incorporated Page 7 of 21 8/12/2014

8 The Technology The Relay, engineered as a closed relay provides the highest level of security from the Internet. The Relay sits between your server and your Smart Host (Firewall) for sending and receiving s. Relay communicates directly over the Internet via Secure Socket Layer (Port 443 only) to the Central Office. This CO exchange is done asynchronously and provides configuration changes, session keys and metadata updates. Depicted below as logical servers, Relay and if needed, a Smart Host can reside on one Microsoft server platform. Service is comprised of several types of Relay options and an Central Office (Host) managed by PaperClip Incorporated. The CO is a n-tier architecture with a mirrored site(s) for reliability. Each CO has functional servers which maintain HTTPS services (Port 443 exclusive), Transaction server, Database server, Portal server and other data center related resources. Relay Server is designed for the enterprise. Cloud Client is designed for the individual desktop client and Webmail hosted by PaperClip supporting the non subscriber. Enterprise Relay On Premise PaperClip Hosted Cloud Client Account Setup Mobile Device Support Webmail Authentication Options Sponsored Client PaperClip Incorporated Page 8 of 21 8/12/2014

9 Encryption Options The Service has two deployment options, encryption enabled or disabled. These two options adhere to specific rules regarding how to encrypt s. Encryption Enabled follows six rules as described below: 1. If an recipient s address domain is an Subscriber. 2. If one or more recipients address domains are Subscribers, is encrypted to all recipients (Subscribers & Non Subscribers) 3. If the wild card address appears as a recipient. 4. Microsoft Outlook AddIn Secure choice displaying a green ribbon. 5. If the wild card address appears as a recipient, the will not be encrypted but audited as an exception. 6. Microsoft Outlook AddIn Force Not Secure choice displaying a red ribbon. Encryption Disabled follows two rules described below: 1. If the wild card address appears as a recipient then encrypt the to all recipients. 2. Microsoft Outlook AddIn Force Secure choice displaying a green ribbon. Force Secure Force Not Secure Note: The addresses and can be supported with friendly names such as Secure and Not Secure supporting type ahead feature. The receiver of a decrypted Service will see appended to the bottom of the original a tag line Content protected by Paperclip Compliant System. PaperClip Incorporated Page 9 of 21 8/12/2014

10 The Relay Server The Relay Server has two basic configurations, Serial and Parallel. Serial configuration is the most simple requiring all s to pass through. In Parallel mode, Relay becomes a subsystem to your server. The host s rules decide what s are directed to the Relay for encrypting. Multiple Relays can be deployed to handle the largest traffic demands. Relay installed as a Serial process maintains locally a list of compliant receivers domains and Desktop subscribers maintained by the Central Office. In Serial operations the Sending server delivers the to the Relay. Relay applies the Serial Rules and encrypts or not. Relay then delivers the to the Smart Host for delivery across the Internet directly to the receiving Server. Receiving s start at the Smart Host and are forwarded to Relay(s) for decrypting as necessary. Relay then releases the to the internal Server. PaperClip Incorporated Page 10 of 21 8/12/2014

11 Relay deployed as a Parallel process to your Server allows your Server s rules engine to decide what s get encrypted going out. This method provides a centralized administration for more complex rules management leveraging existing resources. In this mode of operation, Relay adheres to the following rule: 1. All outgoing is encrypted. In Parallel operations the Sending Server decides what s are delivered to the Relay. Relay applies the Parallel Rules and encrypts all s. Relay then delivers the to the Smart Host for delivery across the Internet. Receiving s start at the Smart Host and are forwarded to the Internal Server. Internal Server rules identify it as an Relay encrypted and forward it on to the Relay(s) for decrypting. Relay(s) then releases the back to the Internal Server PaperClip Incorporated Page 11 of 21 8/12/2014

12 in the Clouds The Cloud can take on different forms depending on the services engaged. One approach is to fork lift your key servers including the Relay and co-locate them with a data center provider. Another approach is to replace your servers with data center provided applications or services. PaperClip s Comcast Cloud solution addresses both models. Verzion Optimum Time Warner Cable Cox Communications AT&T SaaS 3 rd Party Private Cloud Services Private Cloud Services are providers that host your server dedicated to your organization. Many will also host the Relay Server but those who will not, PaperClip has Software as a Service (SaaS) S Relay Service. This service offers access where the private provider connects to the SaaS S Relay Server via TLS. In this model, filtered s can be directed to the S Relay Server. Whether you re with a Private Hosting company or services such as Google Apps or Microsoft 365, the SaaS model seamlessly integrates. The S Service is available as a Full Subscription. This provides access to all Auditing features and Non Subscriber support. PaperClip Incorporated Page 12 of 21 8/12/2014

13 Cloud Client 3 rd Party Shared Cloud Service Providers Cloud vendors today are considered closed systems and do not entertain integration with other third party services. Some can provide webmail encryption services where all secured require access via a browser with login and password. This one too many model and associated user experience has not been well accepted. Remember, was designed by your peers who wanted most of all, one mail client and no passwords. solution for this Cloud environment leverages the Cloud solution. The User uses the same Client used for the Third Party Cloud provider and the User s proper address is maintained so no new addressing is required. The user s address is leveraged by the Cloud. The new C (Cloud) solution is designed to integrate with the user s Client as an Secure Account. This Account provides for secure tunnel transmission with the C Servers where encryption and decryption are performed. In support of the Client Account configuration, PaperClip provides an install for Microsoft Outlook for easy setup. Client Accounts can be setup manually with configuration information found in the User s WebMail Mailbox. In addition, the User has access to their C Mailbox where they can access sent and received s. PaperClip Incorporated Page 13 of 21 8/12/2014

14 When the User wants to send an encrypted to an Subscriber or Non Subscriber, they simply select the C Cloud Account as the sending account. Microsoft Outlook users have the option to install the Outlook Add In for a simple visual selecting to send encrypted or not. If compliance requires all s to go secure, simply select the C Cloud Account as your default account. s sent to the user will arrive at the C Cloud Servers, be decrypted, audited and securely delivered to the user s Client as clear text mail in their Inbox. Users requiring s to rest on their third party Cloud Servers can simply configure their Rules to forward to the same. PaperClip Incorporated Page 14 of 21 8/12/2014

15 The Webmail Non Subscriber Non Subscribers The Service has the ability to manage Non Subscribers (NonSubs) via PaperClip s Webmail hosted by PaperClip. Subscribers have the option to deploy Web Mail requiring receiver authentication. Recipient Validation (RV) is the preferred method of authentication by No Logins Subscribers ensuring the person No Passwords accessing the is the correct Decrypt Incoming s person and still not require logins or passwords. RV method is designed to Reply To: Supported stop the notice from being hijacked Revocation and illegally used to view s on Audited the PaperClip Webmail servers. With no authentication required, the receiver can select the link and view the in a secure browser. Users will receive their normal notice with a link to click on. This link will present a Captcha Code entry screen requiring the user to enter the Captcha Code. The page will refresh indicating a new will arrive immediately with the link to open the . Two principals are used to grant access to the Webmail, same location and same device. All validation data is recorded to the D3P audit. When Registration and Recipient Validation are used together, Two Factor authentication is achieved. Choosing authentication will require receivers to create and maintain credentials. NonSubs have the ability when registering to setup their Web Mail account. NonSubs will receive an with the appropriate link directing them back to the Service Web Mail host. NonSub will then have to login with their address or alias and authenticate with their password they registered with. The hosted Web Mail will secure the Internet pipe or tunnel via SSL. NonSubs will have the ability to save the and if desired, Reply to the sender securely. NonSub s will remain within the hosted environment for thirty days after receipt then they will be purged. Non Subscribers do not have access to Service portal. NonSubs will be able to manage their own Web Mail accounts as necessary (i.e., change password). Non Subs have the option to freely initiate encrypted s to the sponsoring Subscriber at any time. There is no registration requirement Non Subs can have more than one sponsor. PaperClip Incorporated Page 15 of 21 8/12/2014

16 Subscribers can control the content of the body with relevant compliance notices. In addition they can brand their browser presentation with a custom banner or logo. TLS Transport Layer Security is an encryption method whereby the connection between the mail servers is encrypted otherwise known as a secure tunnel. PaperClip utilizes Opportunistic TLS when delivering Webmail Notices to Non- Subscribers. This method will secure the tunnel to the receiving mail server and the notice is secure from outside criminal activities. Receiving mail servers not configured to support TLS will force a connection down grade to unsecure. The majority of cloud providers (Microsoft, Google, Yahoo, etc.) enable TLS on their servers therefore notices sent to these providers travel through an encrypted tunnel. PaperClip Incorporated Page 16 of 21 8/12/2014

17 Clear Text Notice Secured Browser Access PaperClip Incorporated Page 17 of 21 8/12/2014

18 Service Administration Subscriber administrators have access to the Service portal via a browser. The portal provides user functions for analyzing Subscriber s metadata (Auditing), sender and revocation and reporting. PaperClip Incorporated Page 18 of 21 8/12/2014

19 Service Auditing Auditing captures and maintains information regarding transactions and administration. Auditing starts with the data collected every time a request is made to encrypt or decrypt. Sender s Relay connects (SSL) to the Central Office ( CO) and updates the CO in an asynchronous manner. The initial Sender s request message file includes: Client Metrics Transaction ID 3DES Session Key Sender address Receiver(s) address Request Date/Time Stamps Subject Line Attachment Names Receiver s Relay connects to the CO (SSL) and completes the data record closing the transaction. Relay connects to the CO in an asynchronous manner to update. This update passes the following metadata recorded by the CO: Client Metrics Transaction ID Sender address Receiver address Request Date/Time Stamps Non Subscriber s Add-In or Web Mail connects to the CO (SSL) and updates the transaction data in an asynchronous manner. This update passes the following metadata recorded by the CO: Add-In Metrics Transaction ID Sender address Receiver address Request Date/Time Stamps Auditing allows for the isolation of an transaction and all the events associated. Filter on senders or receivers drilling deeper with date and time ranges as needed. Auditing reports or data can be exported to Subscribers for continued reconciliation. PaperClip Incorporated Page 19 of 21 8/12/2014

20 Proof of Delivery Proof of Delivery provides the means where document providers can send a secure with attachments to a receiver where compliance requires a confirmation that the person did receive the mail and documents (e.g., Voice Signature, Disclosures, etc.). Receiver clicks on the link provided and authenticate by answering a combination of simple questions of shared personal information (last four of SSN, Birth Date, etc.). Outlook Add-In provides the ability for Ad-Hoc questions and answers. Create a question using the Add-In and re-use it from a drop down list, then provide the answer(s) to the questions and submit. Receiver when receiving the mail will be asked to answer the questions and upon success, the mail and attachments are presented. PaperClip Incorporated Page 20 of 21 8/12/2014

21 Conclusion The need to encrypt s and their attachments across the public Internet protecting NPI is an undisputed requirement. Current deployed market solutions suffer from industry interoperability, deviate and burden trading partners workflow and require many IT resources not available to all. It s time to climb out of the box. PaperClip s new paradigm that meets compliance, makes it easy to use, distributes cost based on usage (not buying a gun to kill a fly) and eliminates the conflict of interest objection with a disinterested third party audit is ready. This new paradigm or Service can scale from one to thousands of users. It makes industry compliance affordable and uniform. It s simple Update The above conclusion remains more valid today than ever. These new features offer the ability to improve business communication from one secure paradigm which will set the stage for future enhancements for Archiving and one integrated user interface for all your documentation and communication needs. Are you in or outside the box? PaperClip Incorporated Page 21 of 21 8/12/2014

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