In regard to data protection, not just for Layer 6 but for any technology system within TD Bank, we go through a very robust accreditation process that we call our “secure SDLC” program. That really starts in understanding basic requirements, risk assessments and privacy impact assessments, and then providing prescriptive measures on how that data is supposed to be protected. We have a very robust data classification standard. Then we leverage various schemes to protect that data.
The first strategy, of course, is if you don't actually have an explicit need, you don't get the data. Then there are various techniques, from tokenization obfuscation to encryption, to protect that data.