# Information Security & SOC 2 Audit Readiness Policy Blueprint ==================================================================== MODULE 1: INFORMATION SECURITY GOVERNANCE & ORGANIZATIONAL OVERSIGHT ==================================================================== - Information Security Program Scope & Purpose: * Organization: CloudMetrics Technologies Inc. * System Description: Multi-tenant cloud analytics and telemetry data platform hosted natively on Amazon Web Services (AWS us-east-1 and us-west-2). * Scope: All production cloud environments, corporate workstations, repository instances (GitHub), continuous integration pipelines, and identity providers (Auth0/Google Workspace). * Management Commitment: CloudMetrics executive management is formally committed to maintaining the confidentiality, integrity, and availability of customer data in accordance with the AICPA Trust Services Criteria for Security and Confidentiality. * Policy Review & Acknowledgment: This policy shall be reviewed, updated, and approved by the designated Security Officer at least annually. All newly onboarded employees and contractors must review and electronically acknowledge compliance with this policy within five (5) business days of their start date. - Security Roles & Governance RACI Matrix: | Security Role | Assigned Owner | Core Compliance Responsibilities | Segregation of Duties Controls | | :--- | :--- | :--- | :--- | | Security Officer | VP of Engineering (Interim CISO) | Annual policy approval, security risk register maintenance, external audit coordination. | Cannot approve their own infrastructure pull requests in production. | | Cloud Infrastructure Lead | Lead DevOps Engineer | AWS KMS key management, VPC security group configuration, bastion access administration. | Prohibited from directly modifying production financial billing accounts. | | Application Security Lead | Senior Staff Engineer | Static application security testing (SAST) triage, dependency vulnerability patching. | Requires independent peer review for code deployments to main branch. | | Compliance Coordinator | People Operations Lead | Background check verification, onboarding security training, offboarding checklist audit. | No direct administrative access to AWS production VPCs or database consoles. | ==================================================================== MODULE 2: ACCESS CONTROL, IDENTITY & CREDENTIAL MANAGEMENT POLICY ==================================================================== - Identity & Access Governance Principles: * Principle of Least Privilege: Access to production systems, databases, and infrastructure consoles shall be granted solely on a business-need-to-know basis. Default user access across all systems is "Deny All". * Mandatory MFA: Multi-Factor Authentication (MFA) using hardware security keys (WebAuthn/FIDO2) or Time-based One-Time Password (TOTP) applications is mandatory across Google Workspace, GitHub, AWS IAM Identity Center, and Auth0. SMS-based verification is explicitly banned. * Password Rigor: All corporate accounts must enforce a minimum length of 16 characters, complex alphanumeric requirements, and mandatory integration with the corporate password manager (1Password). Master passwords must never be written down or transmitted via unencrypted channels. - User Provisioning, Access Review & Offboarding Protocol: * Provisioning: Access requests require written ticket approval from the employee's direct manager and the Security Officer prior to provisioning via Okta/Auth0 role mapping. * Quarterly User Access Reviews (UAR): On the last business day of each calendar quarter, the Security Officer must extract active user lists across AWS, GitHub, Supabase, and Datadog, verify active employment status, and revoke any redundant or elevated privileges within 48 hours. * 24-Hour Offboarding SLA: Upon notification of employee termination, People Operations must notify IT immediately. IT must revoke all Single Sign-On (SSO) credentials, terminate active sessions, rotate shared API tokens, and initiate remote workstation wipes within exactly twenty-four (24) hours of departure. - Production Environment Access Controls: * Direct SSH access to production EC2 or container instances from public IP addresses is strictly prohibited. * All administrative access must route through AWS Systems Manager (SSM) Session Manager or an encrypted Zero-Trust Network Access (ZTNA) tunnel with mandatory session recording and ephemeral credential issuance (<8 hour duration). * Shared or generic administrative accounts (e.g., "admin", "root") are strictly prohibited. The AWS root account must remain locked behind hardware MFA stored in a secure physical safe. ==================================================================== MODULE 3: DATA CLASSIFICATION, HANDLING & CRYPTOGRAPHY POLICY ==================================================================== - 4-Tier Data Classification Taxonomy Table: | Level | Classification | Description & Examples | Storage & Cryptographic Standards | Access & Transmission Rules | | :--- | :--- | :--- | :--- | :--- | | Tier 1 | Public | Public marketing collateral, published API documentation, open-source repos. | Standard cloud storage; no specialized encryption mandate. | Unrestricted public distribution permitted. | | Tier 2 | Internal | Employee handbooks, internal meeting notes, operational runbooks. | Stored in authenticated Google Workspace drives; encrypted at rest. | CloudMetrics employees only; NDA required for third parties. | | Tier 3 | Confidential | Customer telemetry data, signed customer MSAs, production audit logs. | AES-256 encrypted at rest; customer tenant segregation enforced in PostgreSQL. | Role-based access; TLS 1.3 encryption mandatory in transit. | | Tier 4 | Restricted | Production DB master credentials, customer encryption keys, payment tokens. | Dedicated AWS Secrets Manager / KMS envelope encryption; encrypted at rest. | CISO and Infrastructure Lead only; zero plain-text display permitted. | - Cryptographic Architecture & Key Management: * Transmission Encryption: All public-facing HTTP web traffic must enforce HTTPS using TLS 1.3 (minimum TLS 1.2). Insecure legacy cipher suites (SSL v3, TLS 1.0, TLS 1.1) must be disabled at the AWS Application Load Balancer (ALB). * Storage Encryption: All PostgreSQL RDS databases, Aurora clusters, S3 buckets, and EBS snapshot volumes must be encrypted at rest using AES-256 via AWS KMS Customer Managed Keys (CMKs). * Key Rotation: KMS master keys must be configured with automated annual rotation enabled. Deletion of KMS keys requires a mandatory 30-day waiting window and dual-administrator sign-off. - Data Retention & Sanitization Standards: * Upon customer contract termination, all associated customer data stored across active databases and S3 buckets must be purged within thirty (30) calendar days. * Ephemeral backups and snapshots older than ninety (90) days must be automatically pruned via AWS Backup lifecycle policies. * Hardware decommissioning must adhere to NIST SP 800-88 Rev. 1 cryptographic erasure standards. ==================================================================== MODULE 4: INCIDENT RESPONSE, BREACH NOTIFICATION & BC/DR PLAN ==================================================================== - Incident Response Team (IRT) & Severity Matrix: | Severity Level | Definition & Business Impact | Max Response SLA | Incident Lead | | :--- | :--- | :--- | :--- | | Sev-1: Critical | Confirmed production data breach, active exfiltration, or complete service outage. | < 30 Minutes | Security Officer & Lead Architect | | Sev-2: Major | High-severity vulnerability in production, localized data corruption, failed cluster node. | < 2 Hours | Senior DevOps Engineer | | Sev-3: Minor | Blocked network intrusion attempt, isolated malware alert on employee laptop. | < 8 Hours | IT Systems Administrator | - 6-Phase Incident Handling Workflow: 1. Preparation: Maintain updated runbooks, emergency Slack war-rooms, and active incident response retainers. 2. Detection & Analysis: Continuous log ingestion via Datadog and AWS CloudTrail; alert triggers notify on-call engineers via PagerDuty. 3. Containment: Isolate compromised AWS VPC subnets, rotate affected IAM credentials, and freeze affected customer workspaces. 4. Eradication: Remove unauthorized artifacts, patch exploited vulnerabilities, and deploy verified clean code containers. 5. Recovery: Restore operations from clean database snapshots and monitor traffic for anomalous activity for 48 hours. 6. Post-Mortem: Conduct a blameless post-mortem within five (5) business days; document root cause and file corrective actions. - Regulatory & Contractual Breach Notification Protocols: * In the event of confirmed unauthorized access to customer confidential data, CloudMetrics shall notify affected customer legal contacts in writing without unreasonable delay, and in no event later than seventy-two (72) hours after becoming aware of the incident. * Notifications must include: nature of the incident, categories of data accessed, immediate mitigation steps taken, and designated company contact. - Business Continuity & Disaster Recovery (BC/DR) Framework: * Target Metrics: Recovery Time Objective (RTO) <= 4 Hours | Recovery Point Objective (RPO) <= 1 Hour. * Automated Redundancy: PostgreSQL multi-AZ deployment with continuous automated WAL streaming to secondary AWS region (us-west-2). * DR Simulation: CloudMetrics must conduct an annual live disaster recovery failover drill simulating total region loss, documenting RTO/RPO metrics for auditor review. ==================================================================== MODULE 5: VENDOR RISK MANAGEMENT & AICPA TSC AUDITOR EVIDENCE CHECKLIST ==================================================================== - Third-Party Vendor Risk Assessment SOP: * Critical Vendors (e.g., AWS, Auth0, GitHub, Supabase, Stripe) that store or process customer data must be evaluated prior to onboarding. * Evaluation Criteria: Verification of current SOC 2 Type II or ISO 27001 certification, execution of a Data Processing Agreement (DPA) with standard contractual clauses, and completion of a SIG Lite questionnaire. * Re-Certification: Vendor compliance certifications must be re-collected and audited every twelve (12) months. - AICPA Trust Services Criteria (TSC) Auditor Evidence Checklist: | TSC Criteria | Policy Mandate | Specific Evidence Artifact Required | Audit Source Tool | | :--- | :--- | :--- | :--- | | CC6.1 / CC6.2 | Logical Access Controls | Screenshot of MFA enforcement policy; export of quarterly user access review sign-off ticket. | AWS IAM Console / Auth0 / Jira | | CC6.3 | Offboarding Timeliness | Timestamped HR termination ticket matched against timestamped AWS/Google SSO account deactivation log (<24h). | BambooHR & Google Admin Audit | | CC6.6 | Boundary Protection | VPC architecture diagram; export of security group ingress rules showing 0.0.0.0/0 port restrictions. | AWS VPC Console / Terraform | | CC7.1 / CC7.2 | Vulnerability Management | Monthly automated container scanning reports showing zero open Sev-1/Sev-2 vulnerabilities older than 30 days. | AWS Inspector / Snyk / GitHub Dependabot | | CC8.1 | Change Management | GitHub pull request logs showing branch protection rules, two peer code approvals, and automated CI test passes prior to merge. | GitHub Repository Settings & Commit History | | CC9.1 | Risk Mitigation | Signed annual executive risk assessment register and documented tabletop exercise summary notes. | Confluence Security Space / Vanta |