TECHNICAL AND ORGANISATIONAL MEASURES
Confidentiality
Physical Access Control
- Data centers have restricted access to entry door, into server rooms, and at racks
- Data centers have manned monitoring 24×7 and camera monitoring
- Data centers are ISO certified and SOC2 attested
- Offices are access controlled and monitored by cameras
- Offices have manned reception desk during working hours
Electronic Access Control
- All users require unique user ID
- Centralized multi factor authentication (MFA)
- Strong password security (complexity) with two-factor authentication
- SAML compliant single sign-on
Internal Access Control (permissions for user rights of access to and amendment of data)
- Access to systems and data is granted on a “need to know” basis
- Management approval is required to access systems and data
- Background checks are performed on individuals
- Security, Privacy, and Data Handling trainings are mandatory
Isolation Control
- Data is required to be stored in a specific and controlled location per each client/project
- Management approval is required to access systems and data
- Access limited to only users with the “need to know”
Pseudonymization (Article 32 Paragraph 1 Point a GDPR; Article 25 Paragraph 1 GDPR)
- Only data that is required for obligations is collected
- Based on jurisdiction or client requirements, data may be pseudonymized
- Data is encrypted at rest using National Institute of Standards and Technology (NIST) Federal Information Processing Standards (FIPS) 140-2 approved encryption algorithms
Integrity
Data Transfer Control
- Data is only transferred when required by obligation
- Data transfer is protected in transit using NIST FIPS 140-2 approved encryption algorithms
Data Entry Control
- Only data that is required for obligations is collected
Availability and Resilience
Availability Control
- Information Technology stack and workforce is designed to allow work from any approved location
- Data centers have redundant power
- Data centers have redundant environment control systems
- Data centers have redundant points of presence (internet connections)
- Data center uptime requirement is 99.9%
Rapid Recovery (GDPR Article 32(1)(c))
- Data is replicated to secondary geographically dispersed data centers
- Incident Response (IR) plan to address security issues in a timely manner
- Information Technology (IT) ticketing and tracking systems to manage and escalate IT issues
- Business Continuity and Disaster Recovery policies and procedures
- Mobile workforce
Procedures for Regular Testing, Assessment and Evaluation
Data Protection Management
- Vendor Risk management in place
- Risk assessment performed
- Pertinent logs are stored locally and sent to a centralized tool for monitoring and alerting
- Logs are aggregated to create tech stack visibility and allowing for behavioral and threat risk analysis
- AV/Anti-Malware in place and update automatically
- Patches are applied to OS and SW automatically
Data Protection by Design and Default (Article 25 Paragraph 2 GDPR); Order or Contract
- Data is located in specifically assigned and controlled location
- Management must approve access to resources
- Access is limited to users with “need to know”