Data Security & Privacy
How sensitive compliance data is protected, accessed, and audited. Defense-in-depth security architecture designed for regulated financial services.
Security Architecture Overview
The system handles highly sensitive compliance data. Security is implemented at multiple layers:
Security Layers
- Network Layer: TLS 1.3 for all communication, private VPC, DDoS mitigation
- Application Layer: Input validation, rate limiting, API authentication
- Data Layer: Encryption at rest, row-level security, audit logging
- Access Control: Role-based access control, multi-factor authentication
- Key Management: HSM-backed encryption keys, automated rotation
- Audit & Detection: Logging, intrusion detection, anomaly detection
Data Classification
Compliance data is classified by sensitivity, with corresponding protection levels:
| Classification | Examples | Protection Level |
|---|---|---|
| CONFIDENTIAL | Audit findings, project test results, risk assessments, internal test data | Highest — encryption, role-based access, detailed audit logging |
| INTERNAL | Audit metadata, compliance metrics, approved reports, aggregate statistics | High — encryption, access logging, department-level access control |
| PUBLIC | Compliance frameworks, standards references, aggregate compliance metrics (for regulators) | Standard — encryption in transit, public availability |
Data Access Rules
- Findings: Only accessible to audit sponsor, compliance officers, and assigned approvers
- Audit Trail: Restricted access to authorized individuals; external auditors can request verification proofs
- Remediation Status: Visible to assigned party and compliance officer; restricted view for project team
- Aggregate Reports: Broader distribution (board, management) but individual findings not visible outside governance chain
Encryption Strategy
Encryption protects data in transit and at rest:
Data in Transit
- Protocol: TLS 1.3 for all HTTPS connections
- Certificate Management: Auto-renewing, issued by trusted CA, pinning for mobile clients
- APIs: OAuth 2.0 with PKCE for mobile apps
- Enforcement: HSTS enabled; HTTP redirected to HTTPS
- Monitoring: Alert on certificate expiry, unexpected certificate changes
Data at Rest
- Database Encryption: AES-256 transparent data encryption (TDE) at database level
- Blob Storage: Server-side encryption for all document storage (S3, Azure Blob)
- Backup Encryption: All backups encrypted with same key as source
- Key Management: AWS KMS / Azure Key Vault for master key management
- Key Rotation: Automatic rotation every 90 days; re-encryption of all data on rotation
Encryption Key Management
- HSM-Backed Keys: Master encryption keys stored in hardware security module (HSM), never in software
- Key Separation: Different keys for database, blob storage, audit trail
- Access Audit: All key accesses logged; alerts on unusual patterns
- Disaster Recovery: Encrypted key backups stored in secure vault with multi-person access control
- Key Compromise Procedure: If key compromise suspected, documented process for key rotation and data re-encryption
Document Encryption Detail
- At Upload: Document encrypted client-side before transmission (defense in depth)
- In Transit: TLS 1.3 protects already-encrypted document
- At Rest: Server-side encryption applied as well (double encryption)
- Key per Audit: Can optionally use separate key per audit for additional isolation
- Access: Only decrypted in memory when user views; never stored decrypted
Access Control & Authentication
Role-based access control restricts data visibility to authorized personnel:
Authentication
- MFA Required: Multi-factor authentication for all users
- Corporate SSO (Okta, Azure AD) for main authentication
- TOTP or hardware security key for second factor
- Session Management: Sessions expire after 30 minutes of inactivity; longer for batch operations
- Password Policy: N/A (SSO-based); but if local auth, enforces strong passwords + periodic change
- Account Lockout: After 5 failed login attempts, account locked for 30 minutes
- Audit Logging: All login attempts logged (success and failure)
Authorization & RBAC
Role Hierarchy:
| Role | Can Access | Can Perform |
|---|---|---|
| System Admin | All data, all audits | User management, system configuration, audit trail verification |
| Compliance Director | All audits, all findings | Rule management, audit approval, reporting |
| Compliance Manager | Audits in assigned department(s) | Approve findings, manage remediation, create reports |
| Compliance Officer | Assigned audits only | Validate findings, escalate exceptions, view remediation status |
| Analyst | Assigned audits only (view/comment) | Monitor analysis, prepare findings summaries |
| Project Team | Own project findings only | View assigned remediation tasks, provide status updates |
| Auditor (External) | Audit trail metadata only (no findings) | Verify audit trail integrity, request crypto proofs |
Row-Level Security (RLS)
- Database Enforcement: RLS policies in database ensure queries automatically filtered by user's accessible projects/audits
- No Privilege Escalation: Cannot query findings for project you don't have access to (enforced at DB level, not app level)
- Audit Department Separation: Compliance Officer can only see audits in their assigned department
- Project Manager Isolation: Project managers see only remediation tasks for their projects, not raw findings
Data Access Logging
- What's Logged: User ID, timestamp, action (view, download, export), data accessed (audit ID, finding count), result
- Retention: Access logs retained for 5 years minimum
- Alerts: Real-time alerts for suspicious patterns (bulk download, after-hours access, etc.)
- Query Audit: All database queries logged; suspicious patterns escalated
Network Security
Network-level controls protect data in transit and limit attack surface:
Network Architecture
- Private VPC: All system components in private virtual cloud (no direct internet access)
- Web Tier (Public): Web servers behind load balancer with DDoS mitigation (Cloudflare, AWS Shield)
- Application Tier (Private): API servers in private subnet, accessed only from load balancer
- Database Tier (Highly Restricted): Database servers accessible only from application servers via private connection
- Encryption Tier (HSM): HSM in physically secure data center, accessed only by key management service
DDoS & Attack Mitigation
- DDoS Protection: AWS Shield Standard + Premium with automatic attack detection
- Rate Limiting: API rate limits per user/API key to prevent brute force attacks
- WAF (Web Application Firewall): Rules to block common attacks (SQL injection, XSS, etc.)
- IP Whitelisting: For admin access, IP whitelisting to known corporate networks
- API Key Rotation: Service-to-service API keys rotated every 90 days
Intrusion Detection
- Network IDS: Real-time intrusion detection scanning all ingress/egress traffic
- Endpoint Monitoring: EDR (endpoint detection & response) on all servers
- SIEM Integration: All logs forwarded to SIEM for centralized analysis and correlation
- Alerting: Real-time alerts on suspicious activity with automated response triggers
Data Retention & Deletion
Compliance data is retained according to regulatory requirements and securely deleted when no longer needed:
Retention Policy
| Data Type | Retention Period | Justification |
|---|---|---|
| Audit Records & Findings | 7 years minimum | Regulatory hold for financial services (SOX, GLBA) |
| Audit Trail / Blockchain | Indefinite | Immutable archive for regulatory inspection |
| Supporting Documents | 3 years after closure | Full audit reconstruction capability |
| Access Logs | 5 years | Compliance investigation and incident response |
| System Logs | 1 year (cold storage 5 years) | Incident investigation and diagnostics |
| Personal Data (if any) | Per GDPR/PIPEDA: Deleted on request | Privacy regulation compliance |
Secure Deletion
- Method: Cryptographic overwrite (delete encryption keys, render data unrecoverable)
- Verification: Automated verification that deletion completed successfully
- Audit Trail: Deletion events logged and cannot be reversed
- Disaster Recovery: Deleted data confirmed absent from all backups before closure
- Certificate of Destruction: On request, provide proof of secure deletion
Data Export & Portability
- Subject Access Requests: On request, user can export all personal data held by system (GDPR, PIPEDA compliance)
- Format: JSON or CSV, encrypted, delivered via secure channel
- Timeline: Fulfilled within 30 days (regulatory requirement)
- Right to be Forgotten: Personal data deleted on request (except where regulatory hold applies)
Backup & Disaster Recovery
Data is backed up securely and can be recovered in case of system failure:
Backup Strategy
- Frequency: Full backup daily, incremental backups every 6 hours
- Encryption: All backups encrypted with same keys as source (can decrypt backup with production keys)
- Storage: Backups stored in separate AWS region (geographic redundancy)
- Retention: 30-day rolling window of backups; indefinite retention for year-end backups
- Testing: Monthly restore tests to verify backup integrity and recovery time
Disaster Recovery Plan
- RTO (Recovery Time Objective): 4 hours maximum (target: 2 hours)
- RPO (Recovery Point Objective): 6 hours maximum (minimal data loss)
- Failover Automation: Automated failover to secondary data center if primary fails
- Testing: Quarterly DR drills; unannounced tests to verify readiness
- Communication: Defined communication plan if system unavailable > 1 hour
Business Continuity
- System Redundancy: All components deployed across multiple availability zones
- Database Replication: Real-time replication to secondary database in different region
- Audit Trail Resilience: Blockchain audit trail replicated across 3+ independent nodes
- Manual Operations: If system down, compliance team can operate audits manually using exported data
Vulnerability Management
Proactive approach to identifying and remediating security vulnerabilities:
Scanning & Assessment
- SAST (Static Application Security Testing): Automated code analysis pre-deployment; blocks deployment if critical vuln found
- DAST (Dynamic Application Security Testing): Automated penetration testing in staging environment weekly
- Dependency Scanning: Continuous scanning of third-party libraries for known vulnerabilities
- Infrastructure Scanning: Cloud security posture assessment; alerts on misconfigured security groups, unencrypted buckets, etc.
Penetration Testing
- Frequency: External penetration test semi-annually by independent firm
- Scope: All attack surfaces (web, API, mobile, infrastructure)
- Results: Findings documented, prioritized, remediation tracked
- Retesting: After critical/high vulnerabilities fixed, retesting confirms remediation
Vulnerability Remediation SLA
- Critical: Fixed within 24 hours (or system taken offline)
- High: Fixed within 7 days
- Medium: Fixed within 30 days
- Low: Fixed within 90 days (or with next major release)
Zero-Day Management
- Monitoring: Real-time alerts for newly disclosed vulnerabilities in used libraries
- Temporary Mitigation: If patch not available, implement WAF rules to block exploitation
- Patching: Emergency patching procedure for critical zero-days (within hours)
Compliance & Certifications
System security verified and certified by independent auditors:
Compliance Standards
- SOC 2 Type II: Annual audit covering security, availability, and confidentiality
- ISO 27001: Information security management system certification
- NIST Cybersecurity Framework: Alignment with federal security standards
- OWASP Top 10: Regular assessment against web application security standards
Audit Reports
- Available: SOC 2 report available to customers under NDA
- Frequency: Updated annually with new audit results
- Third-Party Verification: Reports signed by independent auditors