GEP Trust Centre
- Introduction
- Security
- GDPR
- Cardholder Data
- Product security
- Data security
- Privacy
- Data Processing Q&A
- Incident & management response
- Availability & reliability
- Organisational security
- Infrastructure
- Multi tenant architecture
- Threat management
- Artificial intelligence
Vistra believes that a strong business reputation depends on a robust data protection and information security framework. We view data protection and information security as fundamental components of doing business. We are committed to protecting information assets, personal data, and client information. You may find out more information about our Global Data Protection framework here.
Vistra takes security of our and our customer data seriously and is ISO 27001
certified. For an overview of applicable security measures, please see:
GDRP
Vistra complies with applicable data protection laws. For an overview, please see:
Vistra does not store, process, or transmit any Cardholder Data (CHD) either as part of providing our services or in processing payments from our customers.
In addition, for our own e-commerce services where Vistra is taking credit card payments from our customers and is the merchant of record, we use Stripe to fully outsource the processing of payments.
Audit Logs
Vistra logs and stores every change, every action and every event, including the deletion of data, for easy auditing and root cause analysis.
Multi-Factor Authentication
Vistra customers can choose to use multi-factor authentication for their access to Vistra´s service by either using SAML to integrate with their own identity management system, or by using Google or Microsoft SSO.
Also note that Vistra employees use multi-factor authentication for access to all systems containing customer and other sensitive data.
Role-Based Access Control (RBAC)
Vistra lets you set granular access controls to grant and restrict capabilities based on specific roles and authorities.
Google and MS SSO
In addition to SAML SSO, Vistra also supports Google and Microsoft Authentication. If a user´s Google and Microsoft email and Vistra login addresses match, authentication may be required through Google or Microsoft. Authentication through Google or Microsoft also supports two-factor authentication.
SAML SSO
SAML support is provided on request. Please see this page for guidance on how to configure SAML SSO in your environment.
Data Encrypted At-Rest
All data hosted by Vistra is encrypted. Vistra uses industry-accepted encryption products to protect data at rest, with AES-256 encryption.
Data Encrypted In-Transit
TLS 1.2/1.3, and HTTPS are used to protect data in transit.
Privacy Policy – https://www.vistra.com/privacy-notice
Data Retention Policy
By default, we retain Personal Data about you for 10 years as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Data Removal Requests
Vistra supports data deletion requests for both the data we control and the data we process.
Data Privacy Officer (DPO)
Lucy Archer is our Group Data Privacy Officer (DPO). She is responsible for defining and enforcing Vistra’s privacy policies across the company.
Queries and Contact Details
Requests for access, correction, complaints, or other queries relating to how your personal data is processed should be addressed to us via the contact details set out below:
By post:
Group Data Privacy Officer
7th Floor, 50 Broadway, London SW1H 0DB, UK
By email:
[email protected]
By telephone:
+44 20 3872 7310
Incident Response Plan (IRP)
Policies and procedures for operational and incident response management require incidents to be logged and reviewed with appropriate action (e.g. system changes) taken if necessary.
A formal incident response plan and standard incident reporting form are documented to guide employees in the procedures to report security failures and incidents. The incident response plan enforces a process of resolving and escalating reported events. Its provisions include consideration of needs to inform internal and external users of incidents and advising of corrective actions to be taken on their part as well as a “post mortem” review requirement.
Auto Scaling
Vistra’s global entity platform leverages AWS' Elastic Beanstalk for deploying and autoscaling our application.
Service Monitoring
Vistra utilises tools that measure processing queues to verify the timeliness of processing incoming data while monitoring real-time results. Data lost during processing is detected, and automatically creates an alert to the Engineering team. Alerts are addressed by the Engineering team. Upon occurrence of processing errors within Vistra’s application, the change management process is followed with a change ticket initiated and the error investigated and resolved.
- Employee Background Screenings and Confidentiality Agreements
- Regular Security Training for Employees
- Limited Access and Principle of Least Privilege
- Physical Access Control to Office Locations
AWS employ industry-leading security controls and are extensively audited. Both hold multiple certifications, including SOC2 Type II, ISO 27001, PCI, and FedRAMP. For more information about their security practices, see below:
AWS TRUST CENTRE - https://aws.amazon.com/compliance/
Data submitted to Vistra and Vistra’s application are processed and stored in a secure, multi-tenant environment. Logical segmentation techniques, such as having separate namespaces for each customer, are used to prevent co-mingling of customer data.
ISO 27001 - Data Center
Vistra itself is ISO 27001 certified, and our services are built upon Amazon Web Services platform services and hosted in AWS’s data centre facilities. Amazon Web Services is also ISO 27001 certified, more details about their compliance can be found here.
Penetration Testing
On at least an annual basis, Vistra undergoes third-party penetration testing using well established consulting firms. Management addresses all vulnerabilities identified within defined timeframes based on severity level. A summary of the annual penetration test report can be provided under NDA.
Vulnerability Scanning
On at least a weekly basis, Vistra executes vulnerability scan to detect vulnerabilities in Vistra’s application. Dynamic and Static Application Security Testing (DAST and SAST) tools are used to conduct these scans.
Security, Privacy, and Ethics Principles for AI
Guided by our core values, our AI principles reflect our commitment to innovation and the safe, responsible, and ethical use of artificial intelligence with the Vistra Platform.
- AI Governance: Vistra will be responsible stewards of our customers’ and their users data throughout AI model development lifecycles. AI capabilities are built using Vistra’s established security and privacy frameworks combined with ensuring fairness, accountability and human oversight on outputs generated by AI solutions. Data will only be collected, used, and stored in alignment with individual privacy rights and preferences, fundamental rights, and segregated from other customers.
- Customer-Centric Approach: Vistra's AI systems will be designed and developed to elevate our customers' and their end users' experience with software, focusing on identifying opportunities for optimisation, personalisation, and enhanced usability. Vistra will actively seek feedback from customers to inform the development of AI-powered features.
- Transparency and Open Communication: Vistra is committed to AI transparency and will openly communicate with our community about the AI features that we develop and deploy within our services. We will ensure our customers understand and are informed about the presence, capabilities, and limitations of AI-powered features and functionalities.
- Optionality and Customisation: Vistra customers are in control of how they want to leverage AI in Vistra services. We understand that customers have diverse needs and preferences. Our AI features are optional and customisable, allowing customers to modify, fine-tune, or opt out as they see fit.
- Compliance with Legal and Regulatory Frameworks: Vistra will comply with all applicable laws, regulations, and standards governing AI development and deployment, promoting a culture of legal and ethical responsibility.
- Fairness and Equity: Vistra will actively work to identify and mitigate potential biases throughout the model development lifecycle, ensuring fair and equitable product experiences for all users.
- Thought Leadership: Vistra recognises the importance of staying at the forefront of technological advancements and will actively seek opportunities to push the boundaries of innovation. By fostering a culture of continuous learning and exploration, we aim to become a leading voice in the industry.
- Setting the Tone from the Top: Vistra’s executive team is engaged, sets our goals and is accountable for ensuring these principles are implemented and followed throughout all uses of AI technologies in our services and internal processes.
Vistra AI 2024: Security & Privacy FAQ
At Vistra, performance, security, and data privacy are first-order considerations, the north star for how we design our products and policies as an organisation. We understand that artificial intelligence is a new and unfamiliar technology, and that you, a Vistra customer, may have questions about our 2024 launch of AI-powered products and features. You can learn more about our security and privacy practices related to this launch below and, as our practices evolve, we will strive to continue to provide you with such transparency.
Vistra AI Products: AI Technologies Used
Task Wizard, Amazon Bedrock, Anthropic Claude, Amazon Sagemaker
Vistra AI Q&A
Q: Has Vistra developed its own AI technology, or is it using AI technologies provided by third party service providers?
A: Vistra is mainly using Amazon Web Services (AWS) technologies, namely LLMs offered within Amazon Bedrock, a fully managed service that makes Foundational Models from leading AI startups and Amazon available via an API, and potentially HuggingFace models that will run on Amazon Sagemaker.
Q: Are you training models using my company's product usage data?
A: Yes. Your company’s usage data will be used to fine-tune Vistra’s LLM and not any models that are available to any organisation outside of Vistra. This is done to create a product that can better serve your needs.
Q: Are you sure that Vistra is not using my company’s product usage data to train any large language models or other artificially intelligent tools? If so, how are you using our data?
A: As above, Vistra will use your company’s product usage data to fine-tune our proprietary LLM. However, all foundation models (FMs) available through Amazon Bedrock are hosted directly on AWS infrastructure managed and owned by AWS. Model providers do not have access to customer data such as prompts and continuations, or Amazon Bedrock service logs. Additionally, Amazon Bedrock doesn't store or log your prompts and completions. Amazon Bedrock doesn't use your prompts and completions to train any AWS models and doesn't distribute them to third parties.
Q: Will I be able to choose if and when I make use of Vistra’s AI-powered products? Or will my company’s data be processed by these AI-powered products the moment that Vistra launches them?
A: If you are an administrative user, when you go into Vistra in your left-hand navigation you can access your subscription Settings page to learn more about each of Vistra’s AI-powered products, which AI technology is in use, which third-party service provider if any is providing such AI technology, and to choose to opt into or out of each product individually or set of products based on the provider. Go to our AI Features Support page for more information on how to do so.