Process for Sensitive Payment Data | Monitoring and How it is Used | Access and Storing | Authorised Payment Institution API | Electronic Money Institution E-money EMI | Small Payment Institution SPI

Process for sensitive payment data

As an AEMI, we only accept e-wallet accounts to be credited by bank transfer and do not accept cash payments. This is due to the high risk involved in accepting alternatives forms of payment, and owing to these high risks, we have taken the aforementioned decision. Please also refer to Section 13, Security Policy – and Appendix 10.1.1 and Appendix 10.1.2.

Data Access. How data is accessed, stored and protected and how breaches are identified and addressed:

This data is only accessible to authorised staff who require all of five means in order to log in to our system:

1. A password
2. An access card with encrypted credentials
3. A code is generated on the system log-in interface. This code is then input into a tailored application on a mobile device which then generates a token.
4. This token is then input into the system which if correct, allows the user access into the system.
5. The aforementioned token generation is linked to the IMEI number of the mobile device, which ensures that only a specific mobile device may be used, which in itself also requires biometric and facial recognition to access the token generating application.

How the data stored on our server and how breaches are prevented and addressed:

Client (“user/customer/client e-wallet holder”) and transactional data is stored remotely on an AES 256 bit end-to-end encrypted device which allows access to devices with a specific MAC address. As each device has its own unique MAC address, no other devices will be allowed access to the file storage device, even if the correct credentials are provided. This eliminates the possibility of a data breach from external devices. Only two specific devices can be allowed access to the aforementioned file storage device. The file storage device self-destructs its data contents if physically connected to any other device except for the pre-registered two devices. The possibility of a breach is therefore reduced to practically nil. An identical device is used as a failsafe which follows the same security protocol in the event of a failure of the primary storage device.

Monitoring data and how data is used.

Monitoring algorithms as per the FCA handbook have been programmed to monitor in real-time all transactions, comparing them with previous transactions. An upper threshold of £5,000 per year per e-wallet holder has been pre-defined. This algorithm cross-references transactional information with the recipient of funds as well, which is set to the same threshold. This is to say, an e-wallet holder cannot make payment of more than £5,000 in a calendar year, nor receive more than £5,000 per calendar year into their account without review and approval from the Compliance Officer. Any attempt to surpass this limit is automatically denied by the system.

Data is not used for any other purposes internally nor externally.

Data is automatically monitored via in-built algorithms and any e-wallet holder attempting to exceed the yearly limit is automatically logged and a report is automatically generated to be sent to the FCA as per the reporting procedures detailed in the FCA guidelines. All log-in attempts, whether successful or otherwise are logged and reviewed on a weekly basis by senior staff and an accompanying report is filed.