Vendor due-diligence package
Supports credit-union third-party risk management and ongoing monitoring.
1. Data-flow overview
- Guardian → hosted co-branded portal (credit-union link, QR or access code). No core-banking, transaction feed or SSO required.
- Child activity stays inside the guardian's household; credit-union dashboards read aggregate counts only.
- Facilitators receive minimum-necessary rosters for their own sessions.
2. Privacy practices
- Data minimization: nickname + age band for children; no birthdate, contact details or financial data.
- Verifiable guardian consent gates child profile activation; guardians export or delete data in-product.
- No sale of data, targeted advertising, or use of learning data for credit, lending or marketing.
- Purpose-linked retention with deletion after inactivity.
3. Security controls
- Tenant isolation on every query; role-based access for parent, facilitator, curriculum creator, reviewer, CU admin and Innorve admin.
- Passwords hashed (scrypt); httpOnly session cookies; audit log for consent, publishing, takedown and privacy actions.
- Encryption in transit (TLS) and at rest via the hosting provider (deployment-specific).
4. Subprocessors
- Hosting and managed Postgres provider (deployment-specific)
- Transactional email provider for guardian notifications (planned)
- No advertising or data-broker subprocessors
5. Incident & takedown process
- Security incidents: triage, containment, notification to affected institutions per contract.
- Content: facilitators can quarantine a curriculum item with a high-severity flag; reviewers can unpublish instantly while preserving audit history.
- Safeguarding disclosures in live sessions follow the facilitator escalation procedure.
6. Accessibility statement
- Designed toward WCAG 2.2 AA: read-aloud, keyboard navigation, focus management, contrast-safe brand colors, reduced motion.
- Alternate response methods (tap-to-choose) on every mission step.
7. Insurance & certifications
- Provided under NDA during procurement (insurance certificates, security assessments).
8. Product boundaries
- Education, not financial advice, counseling or therapy.
- No child bank/debit/credit connections; play money only.
- No unrestricted generative-AI chat for children; AI is used on the creator side with human approval.
- Curriculum efficacy is not claimed until supported by outcome evidence.
- NCUA does not approve or certify vendor technology.