Security Notice

1. Technical & Organizational Measures

• Transport Layer Security (TLS 1.3) for all data in transit.
• AES-256 encryption for data at rest.
• Row-level access control and least-privilege staff access.
• Tamper-evident, append-only audit logging.
• Multi-factor authentication for staff accounts.
• Encrypted, geo-redundant backups.
• Regular vulnerability scanning and patching.

2. Mandatory Staff Badge Verification

Effective October 29, 2026, staff, Board members, and other authorized users must scan a valid Heartline employee badge before the staff portal enables password or passkey sign-in. The badge is verified server-side, revoked badges are rejected, and access attempts are logged. QR scanning is the standard method; supported NFC, USB scanner, and manual secure-token fallbacks may be used when a camera is unavailable. This pre-authentication requirement is an access control and does not replace the user's password, passkey, or other authentication factor.

3. Policy on Orders to Seal and Unseal Files

This policy implements the organization's bylaws, applicable OMI resolutions, and related governance, privacy, records-retention, and information-security policies. The Board of Directors may issue an order to seal a whole case file, a defined part of a file, or selected attachments when restricted handling is necessary to protect the integrity of the matter, the people involved, confidential information, or the organization's legal and governance obligations. The order must identify the scope, reasons, effective date, responsible authority, and review or release conditions.

A client may submit a governance request through the client portal to ask the Board to review a seal or consider unsealing. The request is recorded with the related case, the client's stated reasons, and the submission timestamp. Filing a request does not itself change access. The Board or Sole Member must issue the applicable written resolution or order, and the decision is recorded in the audit trail before any restriction is changed.

Sealing procedure

• Before issuing a seal order, the authorized officer identifies the linked case, the exact file or attachment scope, the legal or governance basis, the reason for restriction, the effective date, and the review or release condition. A whole-case seal is used only when a narrower restriction would not protect the stated interest.
• A Sealed File Order must be attached to the case before issue. When issued, the system changes the linked case status to Sealed, records the order number and effective timestamp, and applies the restriction to the selected file or the full case scope.
• The case owner receives the applicable notice, while staff, administrators, officers, and contractors retain no access merely because of role or seniority. Access checks are enforced server-side and recorded.
• A client may request a partial unseal for a named file or a full unseal for the case. The request must state a reason of at least 20 characters and remains pending until the Board records a decision.
• The Board may approve the requested scope, narrow a full request to a specific file, approve a full unseal, or deny the request. The Board records written notes and the exact approved file scope; approval alone does not authorize unrelated files.
• Only after the required written Board resolution or Sole Member order is recorded may the approved file scope be restored. Every seal, request, decision, scope change, access event, and rescission remains in the tamper-evident audit trail.
• Staff members may not view, download, retrieve, copy, export, disclose, or otherwise access a sealed file through the case portal or another internal system.
• This restriction applies equally to the Executive Director and other officers or administrators; role or seniority alone does not override a seal.
• Access may be restored only after the Sole Member issues a written order or the Board of Directors issues a resolution or order expressly authorizing access or unsealing.
• Requests to unseal or access a sealed file must be submitted through the case portal for Board review, with the reason recorded in the audit trail.
• Every seal, request, approval, denial, resolution, order, and access event is recorded in a tamper-evident audit trail. Unauthorized attempts may be investigated as a security and governance incident.

4. Breach Notification

European Union & Romania

Pursuant to GDPR Art. 33–34 and Romanian Law 190/2018, personal data breaches are reported to ANSPDCP within 72 hours and to affected data subjects without undue delay where the breach is likely to result in a high risk.

United States

We comply with the breach-notification statutes of all 50 US states, including Iowa Code §715C, California Civil Code §1798.82, New York SHIELD Act, and—where protected health information is involved—the HIPAA Breach Notification Rule (45 C.F.R. §§164.400-414).

5. Electronic Signatures

Electronic signatures captured through this portal are legally binding under the US E-SIGN Act (15 U.S.C. §7001), EU Regulation 910/2014 (eIDAS), and Romanian Law 455/2001 on electronic signatures. We retain the signature, IP address, device fingerprint, and timestamp in a tamper-evident audit trail.

6. Data Localization & Transfers

Primary storage is in the European Union with redundancy in the United States. Cross-border transfers use Standard Contractual Clauses (Commission Decision 2021/914).

7. Reporting a Security Issue

If you believe you have discovered a vulnerability or experienced unauthorized access, contact us immediately at office@heartlineromania.org with subject 'Security report'.

8. Registered Agent (Iowa)

9. Operator