This Data Protection Addendum (“DPA”) is entered into between Customer (defined below) and Avora Ltd of 38 Chancery Lane, London WC2A 1EN (hereafter referred to as “Avora”). These Terms were last updated on 2 July 2019.

1. DEFINITIONS

“Agreement” means any agreement or “terms of service” between Avora and the Customer under which Services are provided by Avora to that customer.

Customer” means the customer that is identified in, and is a party to, the Agreement.

Data Protection Legislation” means all laws and regulations, including laws and regulations of the European Union, the European Economic Area, and their member states, applicable to the processing of Personal Data under the Agreement, including from 25 May 2018 the GDPR.

“GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Personal Data” means all data which is defined as ‘Personal Data’ in the Data Protection Legislation and that is provided directly or indirectly by Customer to Avora, or accessed, stored or otherwise processed by Avora or its subprocessors (as applicable) for the purposes of delivering the Services to Customer.

“Processing”, “Data Controller”, Data Processor “, “Data Subject” and “Supervisory Authority” shall have the meanings ascribed to them in the Data Protection Legislation.

Services” means the services provided by Avora to the Customer according to the Agreement.

Standard Contractual Clauses” means the Standard Contractual Clauses document attached as Appendix 2.

2. DATA PROCESSING

2.1 Scope. The parties acknowledge and agree that with regard to the Processing of Personal Data, Customer is the Data Controller, Avora is the Data Processor.

2.2 Compliance with Laws. Each party will comply with all laws, rules and regulations applicable to it and binding on it in the performance of this DPA, including all Data Protection Legislation.

2.3 Processing Instructions. Avora will process Customer Data in accordance with the Agreement; and with the Customer’s reasonable written instructions, where such instructions are consistent with the terms of the Agreement.

2.4 Details of the Processing. The subject-matter of Processing of Personal Data by Avora is the performance of the Services pursuant to the Agreement. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified in Schedule 1 (Details of Processing) to this DPA.

3. DATA TRANSFER REQUIREMENTS

The Standard Contractual Clauses will apply to all processing of Personal Data by Avora where the Personal Data is transferred from the European Economic Area (EEA) to outside the EEA, either directly or via onward transfer, to any country or recipient not recognized by the European Commission as providing an adequate level of protection for personal data (as described in the Data Protection Legislation), and not covered by a suitable framework recognized by the relevant authorities or courts as providing an adequate level of protection for personal data. If there is a conflict or inconsistency between the DPA and the Standard Contractual Clauses, the Standard Contractual Clauses will prevail to the extent of any inconsistency or conflict.

4. SECURITY & AUDIT OF TECHNICAL AND ORGANISATIONAL MEASURES

4.1 Security.  Avora will maintain appropriate technical and organizational measures for protection of the security, confidentiality and integrity of Customer Data (including protection against unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Customer Data), according to the measures set forth on Appendix 2 of Schedule 2. Avora shall provide reasonable assistance to the Customer in relation to (i) the Customer’s obligations under Data Protection Legislation with respect to data protection impact assessments (as such term is defined in the GDPR); (ii) notifications to the Supervisory Authority and/or communications to Data Subjects by the Customer in response to any Security Incident; and (iii) the Customer’s compliance with its obligations under the GDPR with respect to the security of processing.

4.2 Audit Procedure. On request, Avora will provide Customer with all documentation reasonably required to satisfy Customer of Avora’s compliance with this DPA.

4.3 Records.  Avora shall, in accordance with Data Protection Legislation, make available to the Customer such information in Avora’s possession or control as the Customer may reasonably request with a view to demonstrating Avora’s compliance with the obligations of data processors under Data Protection Legislation in relation to its processing of Personal Data.

4.4 Return and Deletion. As soon as reasonably practicable following, and in any event within ninety (90) days of, termination or expiry of the Agreement or completion of the Services, Avora will delete or return to the Customer (at the Customer’s direction) all Personal Data (including copies thereof) processed pursuant to this DPA.

5. SECURITY BREACH NOTIFICATION

Avora maintains security incident response policies and procedures and shall, to the extent permitted by law, (a) promptly notify the Customer of any actual or reasonably suspected unauthorized disclosure of Personal Data by Avora, or its sub-processors of which Avora becomes aware (a “Security Incident”); (b) take reasonable steps to mitigate the effects and to minimize any damage resulting from the Security Incident; and (c) provide commercially reasonable cooperation and assistance during such investigation to remediate such occurrence.

6. SUB-PROCESSORS

6.1 Subcontracting. Customer agrees that Avora hosts the Service on Amazon Web Services and its affiliates as subcontractors to fulfill its contractual obligations under this DPA. Subject to the remainder of this clause 6, Customer permits Avora to appoint subcontractors to the extent required to fulfil its obligations under the Agreement.

6.2 Subcontractor Obligations. In the event that Avora authorizes any subcontractor to process the Customer Data, (i) Avora shall restrict the subcontractor’s access to Customer Data only to the extent necessary to provide the Service and not for any other purpose; (ii) Avora shall impose appropriate contractual obligations upon the subcontractor, including relevant contractual obligations regarding confidentiality, data protection, data security, and audit rights; and (iii) Avora remains responsible for its compliance with the DPA and for any acts or omissions of the subcontractor that cause Avora to breach any of Avora’s obligations under this DPA.

6.3 Objection Right to New Sub-Processors.  Avora will maintain a list of sub-processors and will add the names of new and replacement sub-processors to the list prior to them starting sub-processing of Personal Data. If the Customer has a reasonable objection to any new or replacement sub-processor, it shall notify Avora of such objections in writing within ten (10) days of the notification and the parties will seek to resolve the matter in good faith. If Avora is able to provide the Services to the Customer in accordance with the Agreement without using the sub-processor and decides in its discretion to do so, then the Customer will have no further rights under this Section in respect of the proposed use of the sub-processor.  If Avora requires to use the sub-processor and is unable to satisfy the Customer (acting reasonably) as to the suitability of the sub-processor or the documentation and protections in place between Avora and the sub-processor within sixty (60) days from the Customer’s notification of objections, the Customer may within thirty (30) days of the end of the sixty-day period referred to above terminate the Agreement only in relation to the Services to which the proposed new sub-processor’s processing of Personal Data relates or would relate by providing written notice to Avora having effect thirty (30) days after receipt by Avora. Avora will refund to the Customer any prepaid fees covering the remainder of the term of the Agreement following the date of termination.

7. DATA SUBJECT REQUESTS

Where the Customer, based on applicable Data Protection Legislation, receives a request from a Data Subject to access, rectify or erase that person’s Personal Data or if a Data Subject objects to the processing of, or makes a data portability request in respect of, such Personal Data (“together Data Subject Request”), Avora shall provide commercially reasonable assistance to the Customer, provided that Customer has instructed Avora to do so and Customer reimburses Avora for the costs arising from such assistance. Avora will not independently respond to requests from Customer’s end users without Customer’s prior written consent, except to confirm that the request relates to the Customer.

8. GENERAL

8.1 Entire Agreement. Except as amended by this DPA, the Agreement will remain in full force and effect. If there is a conflict between the Agreement and this DPA, this DPA shall apply.

8.2 Counterparts. This DPA may be executed in two or more counterparts, each of which will be deemed an original and which taken together will be deemed to constitute the same document. The parties may sign this DPA by email or facsimile.

8.3 Severability. If any provision of this DPA is determined to be unenforceable by a court of competent jurisdiction, that provision will be severed and the remainder of terms will remain in full effect.

Schedule 1 – Details of Processing

Nature and Purpose of Processing

Avora will Process Personal Data as necessary to perform the Services pursuant to the Agreement and as further instructed by Customer in its use of the Services.

Duration of Processing

Unless otherwise agreed upon in writing, Avora will Process Personal Data for the duration of the Agreement.

Categories of Data Subject

Customer may submit Personal Data, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Data Subjects:

  • Prospects, customers, business partners and vendors of Customer
  • Employees or contact persons of Customer’s prospects, customers, business partners and vendors
  • Employees, agents, advisors, freelancers of Customer

Type of Personal Data

Customer may submit Personal Data, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Personal Data:

  • Name
  • Contact information (company email address, phone number, business address)
  • Job titles
  • Professional data

Schedule 2

Standard Contractual Clauses (processors)

For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection

The entity identified as “Customer” in the DPA

(the “data exporter”)

and

Avora
(the “data importer”)

each a “party”; together “the parties”,

HAVE AGREED on the following Contractual Clauses (the Clauses) in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals for the transfer by the data exporter to the data importer of the personal data specified in Appendix 1.

Clause 1

Definitions

For the purposes of the Clauses:

(a) ‘personal  data’,  ‘special  categories  of  data’,  ‘process/processing’,  ‘controller’,  ‘processor’,  ‘data subject’  and ‘supervisory authority’ shall have the same meaning as in Directive 95/46/EC of the  European Parliament and of the Council of 24 October 1995 on the protection of individuals with  regard to the processing of personal data and on the free movement of such data;

(b) ‘the data exporter’ means the controller who transfers the personal data;

(c) ‘the data importer’ means the processor who agrees to receive from the data exporter personal data  intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who is not subject to a third country’s system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC;

(d) ‘the subprocessor’ means any processor engaged by the data importer or by any other subprocessor of the data importer who agrees to receive from the data importer or from any other subprocessor of the data importer personal data exclusively intended for processing activities to be carried out on behalf of the data exporter after the transfer in accordance with his instructions, the terms of the Clauses and the terms of the written subcontract;

(e) ‘the  applicable  data  protection  law‘  means  the  legislation  protecting  the  fundamental  rights  and   freedoms  of individuals and, in particular, their right to privacy with respect to the processing of  personal data applicable to a data controller in the Member State in which the data exporter is  established;

(f) ‘technical and organisational security measures’ means those measures aimed at protecting  personal data against accidental or  unlawful destruction or  accidental loss,  alteration, unauthorised  disclosure  or  access,  in  particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.

Clause 2

Details of the transfer

The details of the transfer and in particular the special categories of personal data where applicable are specified in Appendix 1 which forms an integral part of the Clauses.

Clause 3

Third-party beneficiary clause

1. The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as third-party beneficiary.

2. The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity.

3. The data subject can enforce against the subprocessor this Clause, Clause 5(a) to  (e)  and  (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, unless  any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law as a result of which it takes on the rights and obligations of the data exporter, in  which case the data subject can enforce them against such entity. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.

4. The parties do not object to a data subject being represented by an association or other body if the data subject so expressly wishes and if permitted by national law.

Clause 4

Obligations of the data exporter

(a) that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;

(b) that it  has  instructed and throughout the  duration of the  personal data processing services will  instruct the data importer to  process the personal data transferred only on the data exporter’s behalf  and in accordance with the applicable data protection law and the Clauses;

(c) that  the  data  importer  will  provide  sufficient  guarantees  in  respect  of  the  technical  and  organisational security measures specified in Appendix 2 to this contract;

(d) that after assessment of the requirements of the applicable data protection law, the security  measures are appropriate to  protect  personal  data  against  accidental  or  unlawful  destruction  or  accidental  loss,  alteration,  unauthorised disclosure  or  access,  in  particular  where  the  processing  involves the  transmission of  data over  a  network, and against all other unlawful forms of  processing, and that these measures ensure a level of security appropriate to the risks presented by  the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;

(e) that it will ensure compliance with the security measures;

(f) that, if the transfer involves special categories of data, the data subject has been informed or will be  informed before, or as soon as possible after, the transfer that its data could be transmitted to a third  country not providing adequate protection within the meaning of Directive 95/46/EC;

(g) to forward any notification received from the data importer or  any  subprocessor  pursuant  to  Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter decides to continue the transfer or to lift the suspension;

(h) to make available to the data subjects upon request a copy of the Clauses, with the exception of Appendix 2, and a summary description of the security measures, as well as a copy of any contract for subprocessing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information;

(i) that, in the event of subprocessing, the processing activity is   carried   out   in   accordance   with  Clause 11 by a subprocessor providing at least the same level of protection for the personal data  and the rights of data subject as the data importer under the Clauses; and

(j) that it will ensure compliance with Clause 4(a) to (i).

Clause 5

Obligations of the data importer

The data importer agrees and warrants:

(a) to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;

(b) that  it  has  no  reason  to  believe  that  the  legislation  applicable  to  it  prevents  it  from  fulfilling  the  instructions received from the data exporter and its obligations under the contract and that in the  event of  a  change in this legislation which is likely to have a substantial adverse effect on the  warranties and obligations provided by the Clauses, it will promptly notify the change to  the data  exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;

(c) that it has implemented the technical and organisational security measures specified in Appendix 2  before processing the personal data transferred;

(d) that it will promptly notify the data exporter about:

(i) any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,

(ii) any accidental or unauthorised access, and

(iii) any request received directly from the data subjects without responding to that request, unless it has been otherwise authorised to do so;

(e) to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with  regard to the processing of the data transferred;

(f) at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;

(g) to make available to the data subject upon request a copy of the Clauses, or any existing contract for subprocessing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;

(h) that,  in  the  event  of  subprocessing, it  has  previously informed  the  data  exporter  and  obtained  its  prior written consent;

(i)  that the processing services by the subprocessor will be carried out in accordance with Clause 11;

(j) to send promptly a copy of any subprocessor agreement it concludes under the Clauses to the data  exporter.

Clause 6

Liability

1. The parties agree that any data  subject, who  has  suffered damage as  a  result of  any breach of  the  obligations referred  to  in  Clause 3  or  in  Clause 11  by any  party or  subprocessor is  entitled  to  receive compensation from the data exporter for the damage suffered.

2. If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against the data exporter, arising out of a breach by the data importer or his subprocessor of any of  their obligations referred to in Clause 3  or  in  Clause 11,  because  the  data  exporter  has factually  disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by  operation of law, in which case the data subject can enforce its rights against such entity.

The data importer may not rely on a breach by a subprocessor of its obligations in order to avoid its own liabilities.

3. If a data subject is not able to bring a claim against the data exporter or the data importer referred to in paragraphs 1 and  2,  arising  out  of  a  breach  by  the  subprocessor  of  any  of their obligations  referred to  in Clause 3  or  in Clause 11 because both the data exporter and the data importer have factually disappeared or ceased to exist in law or  have  become  insolvent,  the subprocessor  agrees  that  the  data  subject  may  issue  a  claim  against  the  data subprocessor with  regard  to  its  own  processing operations under the Clauses as if it were the data exporter or the data importer, unless  any successor entity has assumed the  entire legal obligations of the data  exporter or  data importer  by contract or by operation of law, in which case the data subject can enforce its rights against such  entity. The liability of the subprocessor shall be limited to its own processing operations under the Clauses.

Clause 7

Mediation and jurisdiction

1. The  data  importer  agrees that  if  the  data  subject  invokes against  it  third-party beneficiary rights  and/or  claims compensation for  damages under  the  Clauses, the  data  importer will  accept the  decision of the data subject:

(a) to refer the dispute to mediation, by an independent person or, where applicable, by the  supervisory authority;

(b) to refer the dispute to the courts in the Member State in which the data exporter is established.

The parties agree that the choice made by the data subject will not prejudice its substantive or procedural rights to seek remedies in accordance with other provisions of national or international law.

Clause 8

Cooperation with supervisory authorities

1. The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so requests or if such deposit is required under the applicable data protection law.

2. The  parties  agree  that  the  supervisory authority has  the  right  to  conduct  an  audit  of  the  data  importer, and of any subprocessor, which has the same scope and is subject to the same conditions  as would apply to an audit of the data exporter under the applicable data protection law.

3. The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any subprocessor preventing the conduct of an audit of the data importer, or any subprocessor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5 (b).

Clause 9

Governing Law

The Clauses shall be governed by the law of the Member State in which the data exporter is established.

Clause 10

Variation of the contract

The parties undertake not to vary or modify the Clauses. This does not preclude the parties from adding clauses on business related issues where required as long as they do not contradict the Clause.

Clause 11

Subprocessing

1. The data importer shall not subcontract any of its processing operations performed on behalf of the data exporter under the Clauses without the prior written consent of the data exporter. Where the data importer subcontracts its obligations under the Clauses, with the consent of the data exporter, it   shall  do  so  only  by  way  of  a  written agreement with the subprocessor which imposes the same obligations on the subprocessor as are imposed on the data importer under the Clauses. Where the subprocessor fails to fulfil its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the subprocessor’s obligations under such agreement.

2. The  prior  written  contract  between  the  data  importer  and  the  subprocessor  shall  also  provide  for  a  third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data exporter  or the data importer because they have factually disappeared or have ceased to exist in law or have become insolvent and no successor entity has assumed the  entire  legal  obligations  of  the  data  exporter  or  data  importer  by  contract  or  by  operation  of  law.  Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.

3. The provisions relating to data protection aspects for subprocessing of the contract referred to in  paragraph 1  shall be  governed by the  law of  the  Member State in  which  the  data  exporter is established.

4. The data exporter shall keep a list of subprocessing agreements concluded under the Clauses and notified by the data importer pursuant to Clause 5(j), which shall be updated at least once a year.  The list shall be available to the data exporter’s data protection supervisory authority.

Clause 12

Obligation after the termination of personal data processing services

1. The parties agree that on the termination of the provision of data processing services, the data importer and the subprocessor shall, at the choice of the data exporter, return all the personal data  transferred and the copies thereof to  the  data  exporter  or  shall  destroy all  the  personal data  and  certify to  the data exporter that it has done so, unless legislation imposed upon the data importer  prevents it from returning or destroying all or part of the personal data transferred. In that case, the data importer warrants that it will guarantee the confidentiality of the personal data transferred and will not actively process the personal data transferred anymore.

2. The data importer and the subprocessor warrant that upon request of the data exporter and/or of the supervisory    authority, it will submit its data processing facilities for an audit of the measures referred to in paragraph 1.

APPENDIX 1 TO THE STANDARD CONTRACTUAL CLAUSES

Data Exporter

The data exporter is the entity identified as the “Customer” in the DPA.

Data Importer

The data importer is Avora.

Data Subjects

Customer may submit Personal Data, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Data Subjects:

Categories of data

Customer may submit Personal Data, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Personal Data:

Processing operations

The personal data transferred will be subject to the following basic processing activities (please specify):

The objective of Processing of Personal Data by data importer is the performance of the Services pursuant to the Agreement.

APPENDIX 2 TO THE STANDARD CONTRACTUAL CLAUSES

This Appendix forms part of the Clauses and must be completed and signed by the parties.

Description of the technical and organisational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):

Data importer shall undertake appropriate technical and organisational security measures (“TOMs”) to protect personal data against the unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data. These measures should take into account available encryption technology and the costs of implementing the specific measures and must ensure a level of security appropriate to the harm that might result from a breach of security and the nature of the data to be protected.

The IT control environment of the data importer is based upon industry-accepted concepts, providing for multiple layers of preventive and detective controls, working in concert to provide for the overall protection of data importer’s computing environment and data assets. Data importer has the following measures in place:

1. Access control to premises and facilities

Technical and organizational measures to control access to premises and facilities, particularly to check authorization:

Utilizing various physical security controls such as ID cards, keys, alarm systems, and door locking to restrict physical access to office facilities. This program is audited annually.

2. Access control to systems and data

Technical (ID/password security) and organizational (user master data) measures for user identification and authentication:

Utilizing password complexity requirements for access to all on-premises and cloud-based platforms.  In addition, all user access is established on a role basis and requires user management, system or H/R approval, depending on use.  User access and supporting processes for sensitive platforms is subject to periodic review basis. For access to production systems authorized, user accounts require 2 step authentication, or to use an auth provider that has two step access enabled.

3. Disclosure control

Measures to transport, transmit and communicate or store data on data media (manual or electronic) and for subsequent checking:

Requirements on employees and other relevant staff to utilize industry-standard authentication and secure communication mechanisms with production and other cloud services.

4. Input control

Measures for subsequent checking whether data have been entered, changed or removed (deleted), and by whom:

Logging is activated in production and all data actions in the application are logged.

5. Job control

Measures for subsequent checking whether data have been entered, changed or removed (deleted), and by whom:

Logging is activated in production and all data actions in the application are logged.

6. Separation control

Measures to provide for separate processing (storage, amendment, deletion, transmission) of data for different purposes:

Utilization of segregation requirements between production, testing and development environments of sensitive platforms, including restrictions on the level of data available to each environment.  In multi-tenant environment, each customer’s data are logically segregated/separated.

7. Availability control

Measures to assure data security (physical/logical):

Regular backups are conducted in a periodic manner to safeguard data. Utilization of local and/or cloud-based mechanisms to ensure data availability.  Additionally, hosting provider is subject to periodic 3rd party evaluation of operating effectiveness for significant controls ensuring data availability.

8. Further technical measures

Further measures include:

Regular IT control evaluation by audit (internal and/or external), on an as-needed basis.

The information contained in this web site is subject to change without notice.