Extract to table

Given the nature of the data processed and the regulatory posture of Skybridge's client base, the DPA and SCC package must be drafted to meet the highest standards of regulatory compliance applicable to financial services technology providers

Under GLBA and Regulation P, Meridian is required to ensure, by contract or otherwise, that its service providers maintain appropriate safeguards for the NPI that Meridian discloses to them

These obligations flow through to the DPA as contractual requirements that Skybridge must accept

DPA Implications The GLBA framework creates several specific requirements that must be addressed in the DPA: Safeguards Provisions

These safeguards must be consistent with the interagency guidelines on information security and must be sufficient to ensure the security, confidentiality, and integrity of NPI

The DPA must include provisions expressly restricting Skybridge's use and disclosure of NPI to the purposes authorized by Meridian and the underlying subscription agreement