Data Management Policy

2020.1

This policy outlines the requirements and controls/procedures Changineers has implemented to manage the end-to-end data lifecycle, from data creation/acquisition to retention and deletion.

Additionally, this policy outlines requirements and procedures to create and maintain retrievable exact copies of electronic protected health information (ePHI) and other critical customer/business data.

Data backup is an important part of the day-to-day operations of Changineers. To protect the confidentiality, integrity, and availability of ePHI, both for Changineers and Changineers Customers, complete backups are done daily to assure that data remains available when it needed and in case of a disaster.

Policy Statements

Changineers policy requires that

(a) Data should be classified at time of creation or acquisition according to the Changineers data classification model, by labeling or tagging the data.

(b) Maintain an up-to-date inventory and data flows mapping of all critical data.

(c) All business data should be stored or replicated to a company controlled repository, including data on end-user computing systems.

(d) Data must be backed up according to its level defined in Changineers data classification.

(e) Data backup must be validated for integrity.

(f) Data retention period must be defined and comply with any and all applicable regulatory and contractual requirements. More specifically,

• Data and records belonging to Changineers platform customer must be retained per Changineers product terms and conditions and/or specific contractual agreements.

(g) By default, all security documentation and audit trails are kept for a minimum of seven years, unless otherwise specified by Changineers data classification, specific regulations or contractual agreement.

(h) Data must remain in the environment it was created and not be copied or migrated to lower environments without explicit Customer permission.

Controls and Procedures

Data Classification Model

Changineers defines the following four classifications of data:

• Critical
• Confidential
• Internal
• Public

Definitions and Examples

Critical data includes data that must be protected due to regulatory requirements, privacy, and/or security sensitivities.

Unauthorized disclosure of critical data may result in major disruption to business operations, significant cost, irreparable reputation damage, and/or legal prosecution to the company.

External disclosure of critical data is strictly prohibited without an approved process and agreement in place.

Example Critical Data Types includes

• PHI/ePHI
• PII
• PCI
• Production Security data, such as
  • Production secrets, passwords, access keys, certificates, etc.
  • Production security audit logs, events, and incident data

Confidential and proprietary data represents company secrets and is of significant value to the company.

Unauthorized disclosure may result in disruption to business operations and loss in value.

Disclosure requires the signing of NDA and management approval.

Example Confidential Data Types includes

• Business plans
• Employee/HR data
• News and public announcements (pre-announcement)
• Patents (pre-filing)
• Specialized source codes
• Non-production Security data, including
  • Non-prod secrets, passwords, access keys, certificates, etc.
  • Non-prod security audit logs, events, reports, and incident data
  • Audit/compliance reports, security architecture docs, etc.

Internal data contains information used for internal operations.

Unauthorized disclosure may cause undesirable outcome to business operations.

Disclosure requires management approval. NDA is usually required but may be waived on a case-by-case basis.

Example Internal Data Types includes

• Internal documentation
• Policies and procedures
• Product roadmaps
• Most source codes

Public data is Information intended for public consumption. Although non-confidential, the integrity and availability of public data should be protected.

Example Internal Data Types includes

• News and public announcements (post-announcement)
• Marketing materials
• Product documentation
• Contents posted on company website(s) and social media channel(s)

Data Handling Requirements Matrix

Requirements for data handling, such as the need for encryption and the duration of retention, are defined according to the Changineers Data Classifications.

Data	Labeling or Tagging	Segregated Storage	Endpoint Storage	Encrypt At Rest	Encrypt In Transit	Encrypt In Use	Controlled Access	Monitoring	Destruction at Disposal	Retention Period	Backup Recovery
Critical	Required	Required	Prohibited	Required	Required	Required	Access is blocked to end users by default; Temporary access for privileged users only	Required	Required	7 years for audit trails; Varies for customer-owned data†	Required
Confidential	Required	N/R	Allowed	Required	Required	Required	All access is based on need-to-know	Required	Required	7 years for official documentation; Others vary based on business need	Required
Internal	Required	N/R	Allowed	N/R	N/R	N/R	All employees and contractors (read); Data owners and authorized individuals (write)	N/R	N/R	7 years for official documentation; Others vary based on business need	Optional
Public	N/R	N/R	Allowed	N/R	N/R	N/R	Everyone (read); Data owners and authorized individuals (write)	N/R	N/R	Varies based on business need	Optional

N/R = Not Required

† customer-owned data is stored for as long as they remain as a Changineers customer, or as required by regulations such as HIPAA and GDPR, whichever is longer. Customer may request their data to be deleted at any time; unless retention is required by law.

Sharing Data with Vendors

Where possible, data remains within Changineers’s AWS Cloud infrastructure, and for the purposes of this policy AWS is not considered a “Vendor”. All data may be handled by AWS in a manner compliant with Changineers’s data protection policies.

Critical and Confidential data is by default not shared with 3rd parties, unless it is necessary for the functioning of the Changineers Platform and only with prior agreement from the Customer.

Examples when Critical or Confidential data may be shared:

1. private conversations taking place in a video conference may transmit via an Australian TERN server for routing and media capture.

Ways that non-critical or non-confidential data may be shared:

1. Anonymised user behaviour analytics may be captured in an analytics tool such as Google Analytics or Mixpanel
2. User browser crash logs may be forwarded to a bug capture tool such as Sentry.io for detection.

Data Exfiltration

Whilst it is sometimes useful to be able to test upcoming feature changes with “real” user data, Changineers takes the security of Customer data seriously and does not use production data in any other environment for any purpose. We have developed reliable ways to test our systems without the need for using Customer data. The Changineers Platform has a dedicated “sandbox” tenant available in every environment that is used to run synthetic test transactions through which generate realistic behaviour and load.

Where there are isolated Customer-specific issues that cannot be resolved in any other way, Changineers may seek explicit permission from the Customer to temporarily load representative production data into an temporary isolated environment for testing. Once that testing is complete, the environment and all it’s data and backups will be destroyed.

If a Customer requests access to their own data, Changineers can provide a one-off snapshot in a medium suitable to the Customer.

Data Inventory and Lifecycle Management

Changineers Security team uses an automated system to query across our cloud-based infrastructure, including but is not limited to AWS, to obtain detailed records of all data repositories, including but not limited to:

• Amazon API Gateways
• Amazon S3 repositories
• Amazon DynamoDB tables
• AWS Lambdas
• Source code repositories

The records are stored in a database system maintained by Changineers security team. Records are tagged with owner/project and classification when applicable. All records are kept up to date via automation. The system is also designed to track movement of data and update/alert accordingly.

AWS S3 Object Lifecycle Management

The Changineers platform uses Intelligent Tiering to automatically adjust the storage class for certain types of data based on its usage pattern and age. This allows the Changineers platform to provide competitive pricing while still allowing the customer to store large amounts of data.

AWS provides the following storage classes:

• General Purpose
• Infrequent Access
• Archive (Amazon Glacier)

S3 lifecycle policies are used to manage the storage class for certain types of data. In most cases, the Changineers platform automatically adjusts the storage class but we may give customers the ability to adjust the storage class manually to meet their pricing or performance needs.

Changineers performs regular full backups of all production data. We leverage S3 lifecycle policies to automatically remove old backup data. This allows older data to “age out” instead of having to explicitly delete it. S3 lifecycle policies are also used to adjust the storage class of data backups based on the age of the backup.

Other Business Data

All internal and confidential business records and documents, such as product plans, business strategies, presentations and reports, are stored outside of an employee workstation or laptop.

• Official records are stored in record management systems such as

  • GitHub (tickets),
  • GitHub (source code),
  • Google Drive (HR),
  • Xero (expense reports), etc.

• Unstructured business documents such as Word documents, Excel spreadsheets and PowerPoint presentations are stored on Changineers intranet.

• Confidential business documents/records are be stored in encrypted form and with access control enabled on a need-to-know basis.

Backup and Recovery

Customer Data

Changineers stores data in a secure production account in AWS, using a combination of S3 and DynamoDB, all of which are HIPAA compliant. By default, Amazon S3 provides durable infrastructure to store important data and is designed for durability of 99.999999999% of objects.

Changineers performs automatic backup of all customer and system data to protect against catastrophic loss due to unforeseen events that impact the entire system. An automated process will back up databases continuously and provides a to-the-second restore point. Additionally, periodic full backups are taken daily and stored in S3. If a tenant’s data sovereignty requirements permit it, backups can additionally be replicated to a secondary AWS region for even higher resilience.

All backups are encrypted in the same way as live production data.

On-demand, Changineers can provide customers with a snapshot of their data in the event they would like to migrate away from our services.

Source code

Changineers stores its source in git repositories hosted by GitHub.

Source code repositories are backed up to Changineers’s AWS S3 infrastructure account on a weekly basis with a common set of configuration for each repository to enforce SDLC processes.

In the event that GitHub suffers a catastrophic loss of data, source code will be restored from the backups in AWS S3.

Because AWS and GitHub can both host git repositories, we are able to leverage git’s ability to maintain a full history of all changes to our git repos via the commit log.

Business records and documents

Backup copies of business records and documents are maintained on S3, replicated via a Google Drive connector, and stored with the appropriate level of encryption based on their classifications. Examples of business files include, but are not limited to:

• Documents (e.g. product specs, business plans)
• Presentations
• Reports and spreadsheets
• Design files/images/diagrams
• Meeting notes/recordings
• Important records (e.g. approval notes)

Unless the local workstation/device has access to Critical data, backups of user workstations/devices are self managed by the device owner. Backups may be stored on an external hard drive or using a cloud service such as iCloud if and only if the data is both encrypted and password protected (passwords must meet Changineers requirements).

Data Deletion Procedures

For Platform Customers

Despite not being a requirement within HIPAA, Changineers understands and appreciates the importance of health data retention. Acting as a subcontractor/service provider, and at times a business associate, Changineers is not directly responsible for health and medical records retention as set forth by each state. Despite this, Changineers has created and implemented the following procedures to make it easier for Changineers Customers to support data retention laws.

Some types of customer data may be automatically transitioned to a storage class that is appropriate for archival or infrequent usage. The guidelines for transitioning data to different storage classes is at the discretion of Changineers.

Customer data is retained for as long as the account is in active status. Data enters an expired state when the account is voluntarily closed. Expired account data will be retained for 90 days. After 90 days, the project/account and related data will be removed. Customers that wish to voluntarily close their account will be asked whether they want a copy of their data prior to it being purged.

For patient data as as a Covered Entity

Changineers is NOT a covered entity. Should we become a covered entity in the future, we would be required by law to retain healthcare records for up to 10 years beyond when service was last provided when providing healthcare services directly to patients. Any patient data that is marked for deletion will be archived for the time required by law. This archived data can be retrieved by the customer as long as it is retrieved within 10 years from date of last service.