Virtual StrongBox End User File and Account Deletion Policy

 
Virtual StrongBox’s (VSB) End User License Agreement, Privacy Policy and Access to Digital Accounts, and Digital Asset Policy govern the data stored in the VSB platform. As a general rule and for liability reasons, VSB does not delete any records, files, or accounts or grant non-VSB employees access to the live database or the ability to delete records for any reason.


The table below outlines the various account statuses and provides information on when an account can be deleted
 
Account Status Description Document Ownership Deletion Process
Incomplete There are no documents in the End User’s account, and the End User has not activated their account No documents in account Accounts in an Incomplete status can be deleted in the Administration Console by authorized users with the correct role. The admin should 1) select the “User Module” from the left-hand menu 2) Select the “Registrations” tab and search for the incomplete account(s) to be closed and 3) click on the trash can action icon on the left-hand side of the row with the End User’s external account number.
 
Pending Invalid Account with the Service Provider There are documents in the account that have been placed there by the Provider of the Service via the “Send Document to VSB” API. The account number is not a valid account number when checked by the “Get Info” API. The End User has not activated the account and taken possession of the account and documents Provider of the Service owns all documents in an account with an invalid account number Pending Invalid Accounts can be deleted in the Administration Console by VSB authorized users with a special role that allows for pending accounts with documents to be deleted. The provider of the service needs to research and report why the accounts are invalid and identify which accounts need to be deleted by VSB. Once these accounts are identified and a Hold Harmless waiver is executed by the provider’s CEO, VSB will grant a VSB employee a  special role that will allow them to 1) select the “User Module” from the left-hand menu 2) Select the “Registrations” tab and search for the Pending Invalid Account(s) to be removed and 3) click on the trash can action icon on the left-hand side of the row with the End User’s external account number. The End User’s account will then be permanently deleted and all files that were placed into the user's account will be securely shredded.

A Professional Services Quote will be provided to the Provider of the Service based on the time needed to complete the process
 
 
Pending Live/Valid Account with the Service Provider There are documents in the account that have been placed there by the Provider of the Service via the “Send Document to VSB” API. The account number is a valid account number when checked by the “Get Info” API. The End User has not activated the account and taken possession of the account and documents End-User owns all documents in their VSB account Pending Valid Accounts cannot be deleted by the Provider of the Service or by VSB. To close accounts or delete documents in this status the End-User will need to access their personal digital vault via online or mobile banking to active their registration. Prior to closing the online or mobile banking account, the End User can download or delete any documents as needed. Once done, the End User needs to go to “My Profile” inside VSB and select the option to “Close Account.”

VSB will run a secure shredder process on an agreed-upon frequency set by the Provider of the Service that deletes all accounts and files that are marked closed by the End-User.
Complete End-User has activated the account, may or may not have documents stored for them, and still has access to VSB from online or mobile banking End-User owns all documents in their VSB account To close accounts in a Complete status, the End User will need to access their personal digital vault via online or mobile banking prior to closing the online or mobile banking account. The End User can download or delete any documents as needed. Once done, the End-User needs to go to “My Profile” inside VSB and select the option to “Close Account.”

VSB will run a secure shredder process on an agreed-upon frequency set by the Provider of the Service that deletes all accounts and files that are marked closed by the End User.
 
Complete – No Access End-User has activated the account, may or may not have documents stored for them, and does not have access to VSB via online or mobile banking End-User owns all documents in their VSB account Accounts in a Complete No Access status can be deleted in the Administration Console by authorized users that have been assigned the “delete user” role that allows them to delete completed user accounts that may or may not have documents stored in the account. The admin with the authorized role should 1) select the “User Module” from the left-hand menu; 2) Select the “Registrations” tab and search for the completed End-User account(s) to be closed and 3) click on the trash can action icon on the right-hand side of the row with the End-User’s external account number.

The End-User’s account and all stored files will then be moved to the deleted user section where the SSO String and key no longer work. Should the End User’s online or mobile banking account be reactivated, and they try to access VSB, they will be given a message instructing them to contact the Provider of the Service to have their account restored. Admin users can then login to the Administration Console, select the “User Module”, go to the deleted user tab and restore the End User’s account.

NOTE: The actions above DO NOT free up storage space in the Provider of the Service’s account since the account has not been closed by the end-user and files are still stored on the platform.