Data Protection¶

2020.1

Changineers takes the confidentiality and integrity of its customer data very seriously. As stewards and partners of Changineers Customers, we strive to assure data is protected from unauthorized access and that it is available when needed. The following policies drive many of our procedures and technical controls in support of the Changineers mission of data protection.

Production systems that create, receive, store, or transmit Customer data (hereafter “Production Systems”) must follow the requirements and guidelines described in this section.

Policy Statements¶

Changineers policy requires that:

(a) Data must be handled and protected according to its classification requirements and following approved encryption standards, if applicable.

(b) Whenever possible, store data of the same classification in a given data repository and avoid mixing sensitive and non-sensitive data in the same repository. Security controls, including authentication, authorization, data encryption, and auditing, should be applied according to the highest classification of data in a given repository.

(c) Workforce members shall not have direct administrative access to production data during normal business operations. Exceptions include emergency operations such as forensic analysis and manual disaster recovery.

(d) All Production Systems must disable services that are not required to achieve the business purpose or function of the system.

(e) All access to Production Systems must be logged, following the Changineers Auditing Policy.

(f) All Production Systems must have security monitoring enabled, including activity and file integrity monitoring, vulnerability scanning, and/or malware detection, as applicable.

Controls and Procedures¶

Data Protection Implementation and Processes¶

Data is classified and handled according to the Changineers Data Handling Specifications and Data Classification document.

Critical, confidential and internal data will be tagged upon creation, if tagging is supported. Each tag maps to a data type defined in the data classification scheme, which then maps to a protection level for encryption, access control, backup, and retention. Data classification may alternatively be identified by its location/repository. For example, source code in Changineers’s GitHub repository are considered “Internal” by default, even though a tag is not directly applied to each source file.

Critical and confidential data is always stored and transmitted securely, using approved encryption standards. More details are specified in Changineers’s Data Classification and Handling document.

All IT systems that process and store sensitive data follow the provisioning process, configuration, change management, patching and anti-malware standards as defined in Configuration and Change Management document.

Customer/Production Data Protection¶

Changineers hosts on Amazon Web Services in the ap-southeast-2 (Sydney) region by default. Data is replicated across multiple regions for redundancy and disaster recovery where Customer data sovereignty restrictions permit.

All Changineers employees, systems, and resources adhere to the following standards and processes to reduce the risk of compromise of Production Data:

Implement and/or review controls designed to protect Production Data from improper alteration or destruction.
Ensure that confidential data is stored in a manner that supports user access logs and automated monitoring for potential security incidents.
Ensure Changineers Customer Production Data is segmented and only accessible to Customer authorized to access data.
All Production Data at rest is stored on encrypted volumes using encryption keys managed by Changineers. Encryption at rest is ensured through the use of automated deployment scripts referenced in Configuration and Change Management.
Volume encryption keys and machines that generate volume encryption keys are protected from unauthorized access. Volume encryption key material is protected with access controls such that the key material is only accessible by privileged accounts.
Encrypted volumes use approved cipher algorithms, key strength, and key management process as defined above.

Access¶

Changineers employee access to production is guarded by an approval process and by default is disabled. When access is approved, temporary access is granted that allows access to production. Production access is reviewed by the security team on a case by case basis.

Separation¶

Customer data is logically separated at the database/datastore level using a unique identifier for the institution. The separation is enforced at the API layer where the client must authenticate with a chosen institution and then the customer unique identifier is included in the access token and used by the API to restrict access to data to the institution. All database/datastore queries then include the institution identifier.

Implementation of multi-tenanted storage follows Amazon’s SaaS Storage Strategies for Multi-tenant Storage principles.

Backup and Recovery¶

For details on the backup and recovery process, see controls and procedures defined in Data Management.

Monitoring¶

Changineers uses AWS CloudWatch and CloudTrail to monitor the entire cloud service operation. If a system failure and alarm is triggered, key personnel are notified by text, chat, and/or email message in order to take appropriate corrective action. Escalation may be required and there is an on-call rotation for major services when further support is necessary.

For details on the monitoring and alerting process, see controls and procedures defined in Application Observability.

Data Sovereignty¶

Data resides only in AWS Regions approved by the Customer of whose data it is. Based on the Customer’s requirements, data may be stored in a single AWS Region or across multiple. Similarly, if the Customer’s data sovereignty policies permit it, backups may be replicated to a secondary region for additional redundancy.

Data whilst in transit within Changineers’s systems will remain within the Customer’s elected AWS Region.

Once data reaches the public internet, Changineers does not currently limit access based on geographic location.

Changineers respects the laws and legislation of the region that a Customer’s data resides. For example, in Australia Changineers honours the Australian Privacy Principles and the Information Privacy Principles by performing (but not limited) to the following:

Maintaining full and accurate records of data access and modification
By not collecting personal information unless it is neccessary for the functions of the application
By receiving concent from users about the collection and storage of data
Maintaining proper and correct security practices outlined in this policy

Protecting Data At Rest¶

Encryption of Data at Rest¶

All databases, data stores, secrets, and file systems are encrypted with AES-256 using Amazon’s centrally managed Key Management Service. Separate keys for each storage type. The keys are rotated periodically.

Local Disk/Volume Encryption¶

Encryption and key management for local disk encryption of devices follow the defined best practices for Windows, macOS, and Linux/Unix operating systems, such as Bitlocker and FileVault.

Protecting Data In Transit¶

All external data transmission is encrypted end-to-end using encryption keys managed by Changineers. This includes, but is not limited to, cloud infrastructure and third party vendors and applications.
Transmission encryption keys and systems that generate keys are protected from unauthorized access. Transmission encryption key materials are protected with access controls, and may only be accessed by privileged accounts.
Transmission encryption keys use a minimum of 4096-bit RSA keys, or keys and ciphers of equivalent or higher cryptographic strength (e.g., 256-bit AES session keys in the case of IPSec encryption).
Transmission encryption keys are limited to use for one year and then must be regenerated.
For all Changineers APIs, enforcement of authentication, authorization, and auditing is used for all remote systems sending, receiving, or storing data.
System logs of all transmissions of Production Data access are kept. These logs are available for audit.

Encryption of Data in Transit¶

Data in transit from Changineers servers and users will be encrypted using TLSv1.2_2018 and a best negotiated cypher such as ECDHE-RSA-AES128-GCM-SHA256. Refer to CloudFront’s supported viewer protocols for information on what TLSv1.2 cyphers are currently in use.

For data in transit internally within Changineers systems, all traffic is managed by AWS and is encrypted appropriately.

The Amazon Data in Transit material can be referred to for individual products:

Data protection via end-user messaging channels¶

Restricted and sensitive data is not allowed to be sent over electronic end-user messaging channels such as email or chat.

Protecting Data In Use¶

Data in Use, sometimes known as Data in Process, refers to active data being processed by systems and applications which is typically stored in a non-persistent digital state such as in computer random-access memory (RAM), CPU caches, or CPU registers.

Protection of data in use relies on application layer controls and system access controls. See the Production Security / SDLC.

Changineers applications implement logical account-level data segregation to protect data in a multi-tenancy deployment. In addition, Changineers applications may incorporate advanced security features such as Runtime Application Self Protection (RASP) modules and Attribute Based Access Control (ABAC) for protection of data in use through Amazon DynamoDB’s fine grained access controls.

Encryption Key Management¶

Changineers uses AWS Key Management Service (KMS) for encryption key management.

KMS keys are unique to Changineers environments and services.
KMS keys are automatically rotated yearly or more frequently.
KMS keys are inaccesible to all Changineers workers, and are only usable by the application systems themselves limited by IAM policies.

Certificate Management¶

Changineers uses AWS Certificate Manager for certificate management.

Certificates are renewed automatically.
Security team monitors the certificates for expiration, potential compromise and use/validity. Certificate revocation process is invoked if the certificate is no longer needed or upon discovery of potential compromise.

Data Integrity Protection¶

When appropriate, Changineers engineering implements “Versioning” and “Lifecycle”, or equivalent data management mechanism, such that direct edit and delete actions are not allowed on the data to prevent accidental or malicious overwrite. This protects against human errors and cyberattacks such as ransomware.

In AWS, the IAM and S3 bucket policy in production is implemented accordingly when the environments are configured. When changes are made, a new version is created instead of editing and overwriting existing data.

All edits create a new version and old versions are preserved for a period of time defined in the lifecycle policy.
Data objects are “marked for deletion” or “soft deleted” when deleted so that they are recoverable if needed within a period of time defined according to the data retention policy.
Actual deletes of data is prevented wherever possible using IAM policies or additional protections such as multi-factor authentication.
Data is archived in long term storage by AWS and only destroyed when legally required to or at the request of a Customer.

Additionally, all access to data (including ePHI) is authenticated, and audited via logging in the infrastructure, systems and/or application. Amazon CloudTrail is used to log all activity within AWS accounts including security configuration changes, and Amazon CloudWatch is configured to Alarm when misconfigurations occur.

Observability Data Integrity¶

All log, metric, or trace data, that is captured throughout the system lifecycle is stored in Amazon CloudWatch and access controled through IAM policies. Changineers workers have read-only access to all observability data, with no mechanisms to alter data. Data is retained for 90 days by default unless a Customer specifies otherwise.