Common use of Cybersecurity Program Clause in Contracts

Cybersecurity Program. Without limiting any other obligations hereunder, Investment Adviser has implemented and will maintain an information security program that includes reasonable and appropriate physical, technical and administrative measures to safeguard information it obtains under this Agreement, including but not limited to: (i) Written information security policies and procedures; (ii) Industry standard access controls to limit access to the information and systems containing the information only to those who need such access to perform the services hereunder, including requiring the use of multi-factor authentication for any remote access to the information or systems with access to the information; (iii) User identification and password standards, including length and configuration attributes (character composition, expiration term, no sharing of accounts, separate privileged user accounts from non-privileged user accounts, etc.); (iv) Industry accepted methods of secure encryption of the information in transit over public networks and, where applicable to Investment Adviser’s services, of data storage and backups of information at rest;