Privacy Policy

1. Who we are and what this covers

eFile-CDM is a case and document management service for public agencies. It is provided by Pasadena Consulting Group LLC, doing business as Electronic Filing Systems ("eFile", "we", "us").

This policy covers:

• the eFile-CDM service, which runs at app.efilecdm.com, at subdomains of efilecdm.com, and at web addresses our customers set up for it (the "Service");
• this website, efilecdm.com.

Our other products and our company website have their own privacy policies. If your agency has a signed agreement with us that deals with privacy or data protection, that agreement takes priority over this policy where the two differ.

2. Your agency's role and ours

The agency that uses eFile-CDM (your "agency") decides what information goes into the Service, who can access it and how long it is kept. We process that information on the agency's behalf to provide the Service.

The records your agency keeps in eFile-CDM belong to your agency. They may be subject to public records laws, such as the California Public Records Act. Requests for those records should go to your agency.

3. Information we handle

Account information

Your agency's administrators create your account. It holds:

• your name, email address and time zone;
• your roles in the Service;
• your password, if you sign in with one. We store it only as a one-way hash (Argon2id), never in readable form.

Sign-in and security records

To protect accounts, we record sign-ins and security events, such as:

• successful and failed sign-ins, and account lockouts;
• password changes and ended sessions;
• changes administrators make to accounts, roles and settings.

These records include the time, your IP address and your browser's user-agent string. We also keep a record of each device you stay signed in on.

Case and document information

This is the information your agency puts into eFile-CDM. It can include:

• case details, and the names and contact details of the people and organizations involved in a case;
• documents and their earlier versions, and emails filed to cases;
• text extracted from documents, so they can be searched;
• each case's timeline, which records who changed what and when.

What goes into a case is up to your agency.

Microsoft 365 email

If your agency turns on the email features and you link a mailbox, see section 4.

This website

This website has no forms, analytics or cookies, and it loads nothing from other companies. Like any website, our hosting provider may record standard request information (IP address, page and time) for security and operations.

4. Microsoft 365 email

eFile-CDM can show your Microsoft 365 mail and let you file emails to cases. These features are optional. Your agency has to turn them on, and your organization's Microsoft administrator usually has to approve eFile-CDM first. You then link your mailbox by signing in with Microsoft. Work and school accounts only; personal Microsoft accounts are not supported.

Permissions we ask Microsoft for

When we access your mailbox

• Only when you use eFile-CDM's email features, or to finish a task you started, such as filing an email.
• A background task renews the link with Microsoft from time to time. It reads no mail.
• Search terms you enter in the mailbox view go to Microsoft, which runs the search.
• Opening an unread message marks it as read in Microsoft 365, as Outlook does.
• Deleting a message moves it to Deleted Items. eFile-CDM never permanently deletes mail.

What we store

• The link itself: the account's name, email address and Microsoft identifiers, the permissions granted, your list of linked mailboxes, and your email signature.
• The access tokens Microsoft issues. We encrypt them (AES-256-GCM) with a key used for nothing else, and the Service never shows them to anyone.
• Emails filed to a case. We store a copy of the whole message and its attachments as a document in that case. It then becomes part of your agency's case record:
  • people with access to the case can see it;
  • it is kept under your agency's retention rules, even if you unlink your mailbox later;
  • a copy of an email you sent is stored without its Bcc recipients.
• Which emails were filed to which cases, so the same email isn't stored twice.
• For drafts, only identifiers and status. The subject, recipients, text and files stay in your Microsoft mailbox.
• Files you upload from your computer to attach to an email. These are stored temporarily, removed from use within 24 hours, and then permanently deleted.

What we don't store

Apart from the emails you file, we don't keep a copy of your mailbox. To show you a message, the Service handles it in memory or in temporary files. A few short-lived items, such as your place in a list and your unread count, expire within an hour.

Who can see your mailbox

Only you. No one else can open your mailbox through eFile-CDM, including your agency's administrators and eFile staff. Email is displayed with scripts and remote images blocked, so tracking images in messages never load.

Unlinking

• You can unlink a mailbox at any time in eFile-CDM's settings. We immediately delete the stored tokens and your mailbox list.
• To also withdraw eFile-CDM's permissions at Microsoft, remove it at myapps.microsoft.com, or ask your Microsoft administrator.
• If your agency removes your access to eFile-CDM, we delete your mailbox links automatically, usually within an hour.

Our limits on Microsoft data

We use information from Microsoft only to provide the email features you use. We don't sell it, use it for advertising, or use it to train AI models. Our staff don't read it except when you or your agency ask us to (for example, for support), when it is needed to keep the Service secure, or when the law requires it.

5. How we use information

• To provide and operate the Service, including search and text extraction.
• To keep it secure: protecting accounts, preventing abuse and investigating incidents.
• To support your agency and its users when they ask for help.
• To comply with the law and our agreements.

We do not sell personal information. We don't use it for advertising or profiling, and we don't use it to train AI models.

6. Service providers

We rely on the following providers to run the Service. Each receives only what it needs for its task.

We may also share information if the law requires it, to protect the Service or its users, or as part of a merger or sale of our business. In a merger or sale, this policy would continue to protect the information.

7. Where information is stored

The Service and its data are hosted by Amazon Web Services in the United States, in the US West (Oregon) region. Mail that stays in Microsoft 365 is held by Microsoft under your agency's agreement with Microsoft.

8. How we protect information

• Separate agencies. Each agency's data is kept apart by row-level security in the database. Agencies that need it get a dedicated database and their own file storage.
• Encryption.
  • All connections to the Service use HTTPS.
  • Documents are encrypted at rest.
  • Microsoft access tokens and our signing keys are encrypted with separate keys.
• Access control.
  • Roles decide who can see each case and document, and recusals exclude staff from cases.
  • Downloads use links that expire within minutes.
• Accounts.
  • Passwords must be long and are checked against known breaches.
  • Repeated failed sign-ins lock the account.
  • Sessions end after a period of inactivity, and administrators can end them sooner.
• Audit trail. Case timelines and the audit log can't be changed or deleted through the Service.
• Staff access.
  • eFile staff have no access to case, document or email information through the Service.
  • A small number of engineers can reach the underlying systems to operate them. They access customer information only when needed to run, support or secure the Service, or when the law requires it.

No system is perfectly secure. If a security incident affects your agency's information, we will notify your agency as the law and our agreement require.

9. How long we keep information

• Case records, documents and filed emails are kept while your agency uses the Service, under your agency's retention schedules and instructions.
• Accounts. When your agency removes your access, your account is disabled. Your name stays on the records you worked on, because it is part of those records.
• Sign-in and security records are kept for at least one year.
• Microsoft access tokens are kept until you unlink the mailbox or your access is removed.
• Temporary data is deleted on a short schedule:
  • cached mailbox data within an hour;
  • draft records 30 days after the draft is sent or discarded, or after 90 days unused;
  • filing job records after 30 days.
• When your agency's agreement ends, we give your agency a complete copy of its information. We then delete it from our systems and backups, as that agreement provides.

10. Cookies and browser storage

eFile-CDM uses no advertising or analytics cookies and no tracking. It stores only the following:

This website (efilecdm.com) sets no cookies.

11. Your choices and requests

• Records and accounts. Your agency manages your account and the records in eFile-CDM. To see, correct or delete information there, contact your agency. We help agencies answer these requests.
• Mailbox. You can unlink your mailbox at any time (section 4).
• Other questions. If you contacted us directly, or have a question about this website, write to us at the address below.
• California residents. Where we process information on behalf of a public agency, requests under California privacy law should go to that agency.

12. Children

eFile-CDM is for agency staff and is not directed at children. Agency records may include information about people of any age. We handle that information as your agency's data under this policy.

13. Changes to this policy

If we change this policy, we will post the new version here with a new effective date. If a change is significant, we will also tell your agency's administrators before it takes effect.

14. Contact us

Pasadena Consulting Group LLC dba Electronic Filing Systems
1879 E Woodlyn Rd
Pasadena, California
info@efile.systems · 626-240-5169