Security & Data-Retention Policy

Security Program

We apply administrative, technical, and organizational safeguards designed to protect the platform and the confidential project, capital, and organizational information it holds. These include access controls, transport encryption, security headers and a content-security policy, least-privilege administration, and audit logging of sensitive actions. No system is perfectly secure, and we do not guarantee absolute security.

What We Monitor

For authenticated platform accounts we record the in-app activity listed below, for auditability and support. Two limits are stated here rather than left to inference: this activity stream is written to local storage in the browser you are using and is read back from there — it is not yet a server-side log — and the platform events written to a server-side audit table today are limited to the following: administrative decisions on registrations, access requests and data-room requests, and the welcome email sent to a registered account; an administrator assuming another persona; and the creation, amendment or removal of a project record, which any member of that project can do and which records the field values submitted.

• Sessions & environment — a locally generated session identifier, the start of a session in a browser tab, and the device type, browser, operating system, and screen size your browser reports. Sign-out, session duration, IP address, IP-based location, and network provider are not recorded in this platform activity record: it has fields for IP address and IP-based location, which are left empty, and no field at all for sign-out, session duration, or network provider. An earlier version of this page listed them as recorded, which overstated what is implemented.
• In-app activity — pages and modules opened, projects and capital rooms viewed, documents viewed or downloaded, and searches. Form submissions are not recorded in this stream; an access request and the decision on it are stored with the request itself, not here.
• Security events — the browser-local activity stream carries a result field and a coarse in-app risk weighting, but no permission-denied or error outcome is written to it today. Detection of failed sign-ins, unusual download volume, and new-device or new-location logins is not yet implemented: a failed sign-in writes no record anywhere today. An earlier version of this page described those as monitored.

Where we do derive location from an IP address — for public-site page requests, not for in-platform activity — it is approximate and is not a verified physical address. We do not conduct covert screen recording; where activity reconstruction is needed, it is assembled from the event log described above. We do not sell activity data.

Administrative Access (Tiered)

Access to monitoring and analytics is restricted by role, on a need-to-know basis. Administrative decisions — approving or rejecting a registration, sending a welcome email — are recorded in an append-only audit table. Administrative reads are not yet recorded: an administrator opening the visitor analytics or a project workspace leaves no audit entry today. An earlier version of this page said every administrative access was logged, which overstated what is implemented.

• Analytics Viewer — aggregate analytics only.
• Security Admin — login, IP, security, and risk records.
• Compliance Admin — audit logs, legal flags, and public-records review.
• Platform Admin — operational and usage analytics.
• Super Admin — full visibility across the platform.

Data-Retention Schedule

The following are baseline targets; exact periods are reviewed by counsel and may vary by jurisdiction and legal hold:

• Security event logs — 1–7 years (a target for server-side security logging, which does not exist today)
• Audit records of administrative decisions — 3–7 years
• Login / session records — 1–3 years (a target; no login or session record is created today — see What We Monitor)
• Document access logs — 3–7 years
• Page & interaction analytics — 12–24 months
• Aggregated / de-identified analytics — retained longer
• Export logs — 3–7 years
• Support records — 2–5 years
• Deleted-account records — only as legally necessary
• Sensitive Tribal Affairs records — special retention and deletion rules approved by governance, with data-sovereignty protections and strict access controls.

Safeguards & Governance

• Role-based access to all monitoring and analytics.
• Data minimization — we collect what oversight and security require, and no more.
• Sensitive-field masking and export controls, with approval required for sensitive exports.
• Legal review for any surveillance-sensitive feature before release.
• No sale of user-activity data; no hidden tracking beyond what we disclose.

Server-side capture is active

Server-side capture is deployed. Page requests are recorded on our servers, including the country, region, city and time zone derived from your IP address and the network provider it belongs to. Your IP address itself is not stored: it is salted and hashed so a visit can be counted without retaining an identifier. The Privacy Policy describes what is collected and why. An earlier version of this notice said server-only signals such as IP address and geolocation were not collected; that described a prototype phase that has ended and was inaccurate while server-side analytics were live.

Reporting a Concern

To report a security vulnerability or a concern about how activity is monitored or retained, contact applied@thecefa.org.