Security Policy

Last Updated Aug 30, 2023

Organizational Security

Cloud Security

Access Security

Vendor and Risk Management

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Organizational Security

Information Security Program

We have a best-in-class information security program that is validated by our unqualified SOC 2 Type 2 report and ISO 27001 certification. These external validations provide independent assurance of Sparrow’s dedication to providing enterprise-level security to customer data, as they require the regular assessment and confirmation of the protections and effective security practices Sparrow has in place.

SOC 2 Type II

Service Organization Controls (SOC) Reports are frameworks established by the American Institute of Certified Public Accountants (AICPA) for reporting on internal controls implemented within an organization. Sparrow has successfully completed the AICPA SOC 2 Type 2 audit. The independent third-party audit and unqualified opinion confirms that Sparrow’s information security practices, policies, procedures, and operations meet the highest standard of security and compliance. Our SOC 2 Type 2 report provides customers with a detailed level of controls-based assurance, covering all five Trust Service Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy.

ISO 27001 (Information Security Management)

The International Organization for Standardization (ISO) has developed a series of world-class standards for information and societal security to help organizations develop reliable and innovative products and services. Sparrow is proudly ISO 27001 certified. ISO 27001 is recognized as the premier information security management system (ISMS) standard around the world. This certification demonstrates Sparrow’s commitment to continually and comprehensively managing and improving our physical, technical, and legal controls.

Third-Party Audits

Our organization undergoes independent third-party assessments to test our security and compliance controls.

Third-Party Penetration Testing

We perform an independent third-party penetration test at least annually to ensure that the security posture of our services is uncompromised.

Roles and Responsibilities

Roles and responsibilities related to our information security program and the protection of our customer’s data are well defined and documented. Our team members are required to review and accept all of the security policies.

Security Awareness Training

Our team members are required to go through employee security awareness training covering industry standard practices and information security topics such as phishing and password management.


All team members are required to sign and adhere to an industry standard confidentiality agreement prior to their first day of work.

Background Checks

We perform background checks on all new team members in accordance with local laws.

Cloud Security

Cloud Infrastructure Security

All of our services are hosted with Heroku. They employ a robust security program.

Data Hosting Security

All of our data is hosted on Heroku and AWS databases. These databases are located in the United States.

Encryption at Rest

All databases are encrypted at rest.

Encryption in Transit

Our applications encrypt in transit with TLS/SSL only.

Vulnerability Scanning

We perform vulnerability scanning and actively monitor for threats.

Logging and Monitoring

We actively monitor and log various cloud services.

Business Continuity and Disaster Recovery

We use our data hosting provider’s backup services to reduce any risk of data loss in the event of a hardware failure. We utilize monitoring services to alert the team in the event of any failures affecting users.

Incident Response

We have a process for handling information security events which includes escalation procedures, rapid mitigation and communication.

Access Security

Permissions and Authentication

Access to cloud infrastructure and other sensitive tools are limited to authorized employees who require it for their role. Where available we have Single Sign-on (SSO), 2-factor authentication (2FA) and strong password policies to ensure access to cloud services are protected.

Least Privilege Access Control

We follow the principle of least privilege with respect to identity and access management.

Quarterly Access Reviews

We perform quarterly access reviews of all team members with access to sensitive systems.

Password Requirements

All team members are required to adhere to a minimum set of password requirements and complexity for access.

Password Managers

All company issued laptops utilize a password manager for team members to manage passwords and maintain password complexity.

Vendor and Risk Management

Annual Risk Assessments

We undergo at least annual risk assessments to identify any potential threats, including considerations for fraud.

Vendor Risk Management

Vendor risk is determined and the appropriate vendor reviews are performed prior to authorizing a new vendor.

Contact Us

If you have any questions, comments or concerns or if you wish to report a potential security issue, please contact


Is Sparrow HIPAA compliant?

HIPAA applies specifically to health plans, health care clearinghouses, and health care providers. Sparrow is authorized to collect information for leave management in accordance with employment law, the Department of Labor (DOL), and the Equal Employment Opportunity Commission (EEOC). While HIPAA does not apply to Sparrow’s activities, we take security very seriously and strive to align with the security elements of HIPAA, also known as the Federal Privacy Act, that require reasonable administrative, technical, and physical safeguards in order to protect your employees’ data.

Is Sparrow CCPA compliant & compliant with other state data privacy laws?

The California Consumer Privacy Act (CCPA) is a data privacy law that regulates businesses that collect California consumer data and satisfy one of the following thresholds: (1) generate more than $25 million in annual revenue; or (2) buy, sell, or share personal data of more than 100,000 “consumers or households”; or (3) earn more than half of their annual revenue selling consumers’ personal data. While Sparrow does not meet any of these thresholds, we consider your employees’ privacy rights to be fundamental to our relationship. In that respect, we do not sell information to third parties, we explain what information is collected, we give the employee access to their information, and we do not discriminate against them when they choose to exercise their privacy rights. Moreover, we act as a “service provider” for employee personal data that you provide to us, and offer a Data Processing Addendum (DPA) to assist you in complying with your CCPA obligations.

Other states, including Virginia, Colorado, and Connecticut, also have passed data privacy legislation. Like the CCPA, these laws include specific thresholds that Sparrow currently does not meet and therefore Sparrow is not subject to their respective statutory requirements. However, Sparrow offers its DPA to all customers to assist them in complying with their obligations under applicable U.S. data privacy laws.

Is Sparrow GDPR compliant?

All of Sparrow’s operations are located within the United States. Sparrow does not target or profile data subjects within the European Union. Therefore, Sparrow’s activities fall outside the scope of European Union law, and Sparrow is not required to comply with GDPR. That said, GDPR has some of the most stringent privacy standards worldwide, and to demonstrate Sparrow’s commitment to protecting customers’ data, Sparrow has achieved GDPR compliance in accordance with AT-C 315, with criteria established by the AICPA.

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