Chronicle Data Processing and Security Terms (Partners)
Last modified: September 21, 2022 | Previous Versions
The partner agreeing to these terms (“Partner”),
and Chronicle LLC, Chronicle Security Ireland Limited, or any other entity that
directly or indirectly controls, is controlled by, or is under common control
with Chronicle LLC (as applicable, “Chronicle”), have entered into an
agreement under which Chronicle has agreed to provide the Services and related
technical support to Partner as a reseller or as a supplier of the Services (as
amended from time to time, the “Agreement”).
These Data
Processing and Security Terms, including their appendices (the “Terms”)
are incorporated into the Agreement. These Terms will be effective and replace
any previously applicable data processing and security terms from the Terms
Effective Date (as defined below). Where the Agreement was entered into offline
with Chronicle, these Terms supersede the “Data Privacy and Security” Clause,
the “Subprocessor Addendum”, “SPA”, “DPA”, and “Security Terms” in that
agreement (if applicable).
1.1 Capitalized terms defined in the
Agreement apply to these Terms. In addition, in these Terms:
●
Additional
Security Controls means security
resources, features, functionality and/or controls that Partner may use at its
option and/or as it determines, including encryption, logging, monitoring, and
security scanning.
● Adequate Country means:
(a) for data processed subject to the EU GDPR: the EEA, or a country
or territory recognized as ensuring adequate protection under the EU GDPR;
(b) for data processed subject to the UK GDPR: the UK, or a country or
territory recognized as ensuring adequate protection under the UK GDPR the Data
Protection Act 2018; and/or
(c) for data processed subject to the Swiss FDPA: Switzerland, or a
country or territory that is (i) included in the list of the states whose
legislation ensures adequate protection as published by the Swiss Federal Data
Protection and Information Commissioner, or (ii) recognized as ensuring adequate
protection by the Swiss Federal Council under the Swiss FDPA;
in
each case, other than on the basis of an optional data protection framework.
●
Alternative Transfer Solution means a solution, other than SCCs, that
enables the lawful transfer of personal data to a third country in accordance
with European Data Protection Law, for example a data protection framework recognized
as ensuring that participating entities provide adequate protection.
●
Chronicle’s Third Party Auditor means a Chronicle-appointed, qualified
and independent third party auditor, whose then-current identity Chronicle will
disclose to Partner.
●
Data Incident means a breach of Chronicle’s security leading to the accidental
or unlawful destruction, loss, alteration, unauthorized disclosure of, or
access to, Partner Data on systems managed by or otherwise controlled by Chronicle.
●
EEA
means the European Economic Area.
●
EMEA
means Europe, the Middle East and Africa.
●
EU GDPR means 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.
●
European Data Protection Law means, as applicable: (a) the GDPR;
and/or (b) the Swiss FDPA.
●
European Law means, as applicable: (a) EU or EU Member State law (if the EU
GDPR applies to the processing of Partner Personal Data); and (b) the law of
the UK or a part of the UK (if the UK GDPR applies to the processing of Partner
Personal Data).
●
GDPR
means, as applicable: (a) the EU GDPR; and/or (b) the UK GDPR.
●
Instructions has the meaning given in Section 4.2.1 (Partner’s
Instructions).
●
Non-European Data Protection Law means data protection or privacy laws
in force outside the EEA, the UK and Switzerland.
●
Notification Email Address means the email address(es) designated by
Partner in the Order Form (as applicable), to receive certain notifications
from Chronicle. Partner is responsible for ensuring that its Notification Email
Address remains current and valid.
●
Partner
End Users has the meaning
given in the Agreement or, if no such meaning is given, has the meaning given
to “End Users” in the Agreement.
●
Partner
Personal Data means the
personal data contained within the Partner Data.
●
Partner SCCs means the SCCs (Controller-to-Processor), the SCCs (Processor-to-Processor)
and/or the SCCs (Processor-to-Controller), as applicable.
●
SCCs
means the Partner SCCs and/or SCCs (Processor-to-Processor, Chronicle Exporter),
as applicable.
●
SCCs (Controller-to-Processor) means the terms at: https://chronicle.security/legal/sccs/eu-c2p.
●
SCCs (Processor-to-Controller) means the terms at: https://chronicle.security/legal/sccs/eu-p2c.
●
SCCs (Processor-to-Processor) means the terms at: https://chronicle.security/legal/sccs/eu-p2p.
●
SCCs (Processor-to-Processor, Chronicle Exporter) means the terms at: https://chronicle.security/legal/sccs/eu-p2p-chronicle-exporter.
●
Security Documentation means all documents and information made available by
Chronicle under Section 6.5.1 (Reviews of Security Documentation).
●
Security Measures has the meaning given in Section 6.1.1 (Chronicle’s Security
Measures).
●
Subprocessor means a third party authorized as another processor under these
Terms to have logical access to and process Partner Data in order to provide
parts of the Services and Chronicle TSS.
●
Supervisory Authority means, as applicable: (a) a “supervisory authority” as
defined in the EU GDPR; and/or (b) the “Commissioner” as defined in the UK
GDPR; and/or the Swiss FDPA.
●
Swiss FDPA means the Federal Data Protection Act of 19 June 1992
(Switzerland).
●
Term
means the period from the Terms Effective Date until the end of Chronicle’s
provision of the Services, including, if applicable, any period during which
provision of the Services may be suspended and any post-termination period
during which Chronicle may continue providing the Services for transitional
purposes.
●
Terms Effective Date means the date on which Partner accepted, or the parties
otherwise agreed to, these Terms.
●
UK GDPR means the EU GDPR as amended and incorporated into UK law under
the UK European Union (Withdrawal) Act 2018 and applicable secondary
legislation made under that Act.
1.2 The terms “personal data”, “data subject”,
“processing”, “controller” and “processor” as used in these Terms have the
meanings given in the GDPR irrespective of whether European Data Protection Law
or Non-European Data Protection Law applies.
Regardless of whether the Agreement has
terminated or expired, these Terms will remain in effect until, and
automatically expire when, Chronicle deletes all Partner Data as described in
these Terms.
3.1 Application of European Law.
The parties acknowledge that European Data Protection Law will apply to the
processing of Partner Personal Data if, for example:
3.2 Application of Non-European Law.
The parties acknowledge that Non-European Data Protection Law may also apply to
the processing of Partner Personal Data.
3.3 Application of Terms. Except
to the extent these Terms state otherwise, these Terms will apply irrespective
of whether European Data Protection Law or Non-European Data Protection Law
applies to the processing of Partner Personal Data.
4.1 Roles and Regulatory Compliance;
Authorization.
4.1.1 Processor and Controller
Responsibilities. If European Data Protection Law applies to the processing
of Partner Personal Data:
4.1.2 Processor Partners. If
European Data Protection Law applies to the processing of Partner Personal Data
and Partner is a processor:
a. Partner warrants on an ongoing basis that
the relevant Customer and controller has authorized: (i) the Instructions, (ii)
Partner’s appointment of Chronicle as another processor, and (iii) Chronicle’s
engagement of Subprocessors as described in Section 10 (Subprocessors);
b. Partner will immediately forward to the
relevant Customer and controller any notice provided by Chronicle under
Sections 4.2.3 (Instruction Notifications), 6.2.1 (Incident Notification),
8.2.1 (Responsibility for Requests), 10.4 (Opportunity to Object to
Subprocessor Changes) or that refers to any SCCs; and
c. Partner may:
i.
request access for the relevant
Customer and controller to the SOC Reports in accordance with Section 6.5.3(a);
and
ii. make available to the relevant Customer and
controller any other information made available by Chronicle under Sections 9.4
(Supplementary Measures and Information), 9.6 (Data Center Information) and
10.2 (Information about Subprocessors).
4.1.3 Responsibilities under
Non-European Law. If Non-European Data Protection Law applies to either
party’s processing of Partner Personal Data, the relevant party will comply
with any obligations applicable to it under that law with respect to the
processing of that Partner Personal Data.
4.2 Scope of Processing.
4.2.1 Partner’s Instructions.
Partner instructs Chronicle to process Partner Data only in accordance with
applicable law: (a) to provide, secure, and monitor the Services and Chronicle
TSS; (b) as further specified via Partner’s use of any of the functionality of
the Services and Chronicle TSS; (c) as documented in the form of the Agreement,
including these Terms; and (d) as further documented in any other written
instructions given by Partner and acknowledged by Chronicle as constituting
instructions for purposes of these Terms (collectively, the “Instructions”).
4.2.2 Chronicle’s Compliance with
Instructions. Chronicle will comply with the Instructions unless prohibited
by European Law.
4.2.3 Instruction Notifications.
Chronicle will immediately notify Partner if, in Chronicle’s opinion: (a)
European Law prohibits Chronicle from complying with an Instruction; (b) an
Instruction does not comply with European Data Protection Law; or (c) Chronicle
is otherwise unable to comply with an Instruction, in each case unless such
notice is prohibited by European Law. This Section does not reduce either
party’s rights and obligations elsewhere in the Agreement.
5.1 Deletion by Partner. Chronicle
will enable Partner to delete Partner Data upon request during the Term in a
manner consistent with the functionality of the Services. If Partner requests
deletion of any Partner Data during the Term and that Partner Data cannot be
recovered by Partner, this request will constitute an Instruction to Chronicle to
delete the relevant Partner Data from Chronicle’s systems in accordance with
applicable law. Chronicle will comply with this Instruction as soon as
reasonably practicable and within a maximum period of 180 days, unless European
Law requires storage.
5.2 Return or Deletion on Termination
at the end of the Term; Data Export. On expiry of the Term, Partner
instructs Chronicle to delete all remaining Partner Data (including existing
copies) from Chronicle’s systems at the end of the Term in accordance with applicable
law. After a recovery period of up to 30 days from that date, Chronicle will
comply with this Instruction as soon as reasonably practicable and within a
maximum period of 180 days, unless European Law requires storage. Partner is
responsible for notifying Chronicle before the Term expires of any Partner Data
that Partner wishes to export and, if Partner does so, Chronicle will assist
Partner in exporting such Partner Data.
6.1 Chronicle Security Measures,
Controls and Assistance.
6.1.1 Chronicle Security Measures.
Chronicle will implement and maintain technical and organizational measures to
protect Partner Data against accidental or unlawful destruction, loss, alteration,
unauthorized disclosure or access as described in Appendix 2 (the “Security
Measures”). The Security Measures include measures to encrypt Partner Data; to
help ensure ongoing confidentiality, integrity, availability and resilience of
Chronicle’s systems and services; to help restore timely access to Partner Data
following an incident; and for regular testing of effectiveness. Chronicle may
update the Security Measures from time to time provided that such updates do
not result in a material reduction of the security of the Services.
6.1.2 Access and Compliance.
Chronicle will: (a) authorize its employees, contractors and Subprocessors to
access Partner Data only as strictly necessary to comply with Instructions; (b)
take appropriate steps to ensure compliance with the Security Measures by its
employees, contractors and Subprocessors to the extent applicable to their
scope of performance, and (c) ensure that all persons authorized to process
Partner Data are under an obligation of confidentiality.
6.1.3 Additional Security Controls.
Chronicle may make Additional Security Controls available to: (a) allow Partner
to take steps to secure Partner Data; and (b) provide Partner with information
about securing, accessing and using Partner Data.
6.1.4 Chronicle Security Assistance.
Chronicle will (taking into account the nature of the processing of Partner
Personal Data and the information available to Chronicle) assist Partner in
ensuring compliance with its (or, where Partner is a processor, the relevant
controller’s) obligations under Articles 32 to 34 of the GDPR, by:
6.2 Data Incidents.
6.2.1 Incident Notification. Chronicle
will notify Partner promptly and without undue delay after becoming aware of a
Data Incident, and promptly take reasonable steps to minimize harm and secure
Partner Data.
6.2.2 Details of Data Incident.
Chronicle’s notification of a Data Incident will describe: the nature of the
Data Incident, including the Partner resources impacted; the measures Chronicle
has taken, or plans to take, to address the Data Incident and mitigate its
potential risk; the measures, if any, Chronicle recommends that Partner take to
address the Data Incident; and details of a contact point where more information
can be obtained. If it is not possible to provide all such information at the
same time, Chronicle’s initial notification will contain the information then
available and further information will be provided without undue delay as it
becomes available.
6.2.3 Delivery of Notification.
Notification(s) of any Data Incident(s) will be delivered to the Notification
Email Address.
6.2.4 No Assessment of Partner Data
by Chronicle. Chronicle has no obligation to assess Partner Data in order
to identify information subject to any specific legal requirements.
6.2.5 No Acknowledgement of Fault by
Chronicle. Chronicle’s notification of or response to a Data Incident under
this Section 6.2 (Data Incidents) will not be construed as an acknowledgement
by Chronicle of any fault or liability with respect to the Data Incident.
6.3 Partner’s Security
Responsibilities and Assessment.
6.3.1 Partner’s Security
Responsibilities. Without prejudice to Chronicle’s obligations under Sections
6.1 (Chronicle Security Measures, Controls and Assistance) and 6.2 (Data
Incidents), and elsewhere in the Agreement, as between Chronicle and Partner,
Partner is responsible for its and its Customers’ use of the Services and its
and their storage of any copies of Partner Data outside Chronicle or
Chronicle’s Subprocessors’ systems, including:
6.3.2 Partner’s Security Assessment.
Partner agrees that the Services, Security Measures implemented and maintained
by Chronicle,, Additional Security Controls and Chronicle’s commitments under
this Section 6 (Data Security) provide a level of security appropriate to the
risk to Partner Data (taking into account the state of the art, the costs of
implementation and the nature, scope, context and purposes of the processing of
Partner Personal Data as well as the risks to individuals).
6.4 Compliance Certification and SOC
Report. Chronicle will maintain at least the following for the
Services in order to evaluate the continued effectiveness of the Security
Measures: ISO 27001 certification (the “Compliance Certification”) and
SOC 2 Type 2 accreditation (the “SOC Report”). Chronicle may add
standards at any time. Chronicle may replace a Compliance Certification or SOC Report
with an equivalent or enhanced alternative.
6.5 Reviews and Audits of Compliance.
6.5.1 Reviews of Security Documentation.
Chronicle will make the Compliance Certification and the SOC Report available
for review by Partner to demonstrate compliance by Chronicle with its
obligations under these Terms.
6.5.2 Partner’s Audit Rights.
6.5.3 Additional Business Terms for
Reviews and Audits.
Chronicle will (taking into account the nature of the processing and
the information available to Chronicle) assist Partner
in ensuring compliance with its (or, where Partner is a processor, the relevant
controller’s) obligations under Articles 35 and 36 of the GDPR, by:
8.1 Access; Rectification; Restricted
Processing. During the Term, Chronicle will enable Partner, in a manner
consistent with the functionality of the Services, to access, rectify and
restrict processing of Partner Data, including via the deletion functionality
provided by Chronicle as described in Section 5.1 (Deletion by Partner). If Partner becomes aware that
any Partner Personal Data is inaccurate or outdated, Partner will be
responsible for notifying Chronicle and Chronicle will
assist Partner in rectifying or deleting that data if required by applicable European Data
Protection Law.
8.2 Data Subject Requests.
8.2.1 Responsibility for Requests.
During the Term, if Chronicle receives a request from a data subject that
relates to Partner Personal Data and identifies Partner, Chronicle will: (a)
advise the data subject to submit their request to Partner; (b) promptly notify
Partner; and (c) not otherwise respond to that data subject’s request without
authorization from Partner. Partner will be responsible for responding to any such
request including, where necessary, by using the functionality of the Services.
8.2.2 Chronicle’s Data Subject Request Assistance. Chronicle
will (taking into account the nature of the processing of Partner Personal Data) assist Partner in fulfilling its (or, where Partner is a
processor, the relevant controller’s) obligations under Chapter III of the GDPR
to respond to requests for exercising the data subject’s rights by:
9.1 Data Storage and Processing
Facilities. Subject to Chronicle’s data location commitments under the
Chronicle Service Specific Terms and to the remainder of this Section 9 (Data
Transfers), Partner Data may be processed in any country in which Chronicle or
its Subprocessors maintain facilities.
9.2 Restricted European Transfers.
The parties acknowledge that European Data Protection Law does not require SCCs
or an Alternative Transfer Solution in order for Partner Personal Data to be
processed in or transferred to an Adequate Country. If Partner Personal Data is
transferred to any other country and European Data Protection Law applies to the
transfers if Partner’s address is outside EMEA (“Restricted European Transfers”),
then:
A.
the SCCs (Processor-to-Processor, Chronicle Exporter) will apply
with respect to such Restricted European Transfers from Chronicle to
Subprocessors; and
B.
in addition, if Partner’s address is not in an Adequate Country,
the SCCs (Processor-to-Controller) will apply (regardless of whether Partner is
a controller and/or processor) with respect to such Restricted European Transfers
between Chronicle and Partner; or
9.4 Supplementary Measures and
Information. Chronicle will provide Partner with information relevant to
Restricted European Transfers, including information about Additional Security
Controls and other supplementary measures to protect Partner Personal Data as
described in Section 6.5.1 (Reviews of Security Documentation).
9.5 Termination. If Partner concludes,
based on its current or intended use of the Services, that the Alternative
Transfer Solution and/or SCCs, as applicable, do not provide appropriate
safeguards for Partner Personal Data, then Partner may immediately terminate
the Agreement for convenience by notifying Chronicle.
9.6 Data Center Information.
Information about the locations of Chronicle’s and its Affiliate Subprocessors’
facilities is available at: https://cloud.google.com/about/locations/ (as may be updated from time to
time).
10.1 Consent to Subprocessor Engagement. Partner specifically authorizes the engagement as Subprocessors
of those entities listed as of the Terms Effective Date at the URLs specified in
Section 10.2 (Information about Subprocessors). In addition, without prejudice
to Section 10.4 (Opportunity to Object to Subprocessor Changes), Partner generally authorizes the engagement as
Subprocessors of any other third parties (“New Subprocessors”).
10.2 Information about Subprocessors.
Information
about Subprocessors, including their functions and locations, is available at https://cloud.google.com/terms/subprocessors
and https://chronicle.security/legal/subprocessors,
as may be updated from time to time in accordance with these Terms.
10.3 Requirements for
Subprocessor Engagement. When
engaging any Subprocessor, Chronicle will:
10.4 Opportunity to Object to Subprocessor Changes.
11.1 Chronicle’s
Cloud Data Protection Team. Chronicle’s Cloud Data Protection Team will provide prompt and
reasonable assistance with any Partner queries related to processing of Partner
Data under the Agreement and can be contacted by raising a ticket with
the Chronicle Support Team via the support portal at support.chronicle.security
(and/or via such other means as Chronicle may provide from time to time).
11.2 Chronicle’s Processing
Records. Chronicle will keep appropriate documentation of its processing activities
as required by the GDPR. To the extent the GDPR requires Chronicle to collect
and maintain records of certain information relating to Partner or its
Customers, Partner will supply such information and keep it accurate and
up-to-date. Chronicle may make any such information available to the
Supervisory Authorities if required by the GDPR.
11.3 Controller Requests.
During the Term, if Chronicle’s Cloud Data Protection Team receives a request
or instruction from a third party purporting to be a controller of Partner Personal
Data, Chronicle will advise the third party to contact Partner.
12.1 Precedence.
To the extent of any conflict or inconsistency between:
12.2 Legacy UK
SCCs. The supplementary terms for UK GDPR transfers in the SCCs will, as of
21 September 2022, supersede and terminate any standard contractual clauses
approved under the UK GDPR or Data Protection Act 2018 and previously entered
into by Partner and Chronicle.
12.3 No
Modification of SCCs. Nothing in the Agreement (including these Terms) is
intended to modify or contradict any SCCs or prejudice the fundamental rights
or freedoms of data subjects under European Data Protection Law.
Subject Matter
Chronicle’s provision of the Services and
Chronicle TSS to Partner.
Duration of the Processing
The Term plus the period from the end of the
Term until deletion of all Partner Data by Chronicle
in accordance with the Terms.
Nature and Purpose of the Processing
Chronicle will process Partner
Personal Data for the purposes of providing the Services and Chronicle TSS to Partner in accordance with the Terms.
Categories of Data
Data relating to individuals provided to Chronicle via the Services, by
(or at the direction of) Partners or its Customers
or by Partner End Users.
Data Subjects
Data subjects include the individuals about whom data is provided to
Chronicle via the Services by (or at the direction of) Partner or its Customers
or by Partner End Users.
As from the Terms Effective Date,
Chronicle will implement and maintain the Security Measures described in this
Appendix 2.
1. Subprocessor Security
Before onboarding Subprocessors,
Chronicle conducts an audit of the security and privacy practices of
Subprocessors to ensure they provide a level of security and privacy
appropriate to their access to data and the scope of the services they are
engaged to provide. Once Chronicle has assessed the risks presented by the
Subprocessor, then subject to the requirements described in Section 10.3
(Requirements for Subprocessor Engagement) of these Terms, the Subprocessor is
required to enter into appropriate security, confidentiality and privacy
contract terms.
2. Infrastructure Security
Chronicle is built on core
infrastructure provided by Google LLC and other Chronicle Affiliate
Suprocessors (hereinafter, “Google”). Chronicle will ensure that, as
from the Terms Effective Date, Google will implement and maintain the
additional Security Measures described in this Appendix 2.
(a) Data Center and Network Security
(i) Data Centers.
Infrastructure. Google maintains geographically
distributed data centers. Google stores all production data in Google’s
physically secure data centers.
Redundancy. Infrastructure systems have
been designed to eliminate single points of failure and minimize the impact of
anticipated environmental risks. Dual circuits, switches, networks or other
necessary devices help provide this redundancy. The Services are designed to
allow Google to perform certain types of preventative and corrective
maintenance without interruption. All environmental equipment and facilities
have documented preventative maintenance procedures that detail the process for
and frequency of performance in accordance with the manufacturer’s or internal
specifications. Preventative and corrective maintenance of the data center
equipment is scheduled through a standard change process according to
documented procedures.
Power. The data center electrical power
systems are designed to be redundant and maintainable without impact to
continuous operations, 24 hours a day, 7 days a week. In most cases, a primary
as well as an alternate power source, each with equal capacity, is provided for
critical infrastructure components in the data center. Backup power is provided
by various mechanisms such as uninterruptible power supplies (UPS) batteries,
which supply consistently reliable power protection during utility brownouts,
blackouts, over voltage, under voltage, and out-of-tolerance frequency
conditions. If utility power is interrupted, backup power is designed to
provide transitory power to the data center, at full capacity, for up to 10
minutes until the backup generator systems take over. The backup generators are
capable of automatically starting up within seconds to provide enough emergency
electrical power to run the data center at full capacity typically for a period
of days.
Server Operating Systems. Google servers use a Linux
based implementation customized for the application environment. Data is stored
using proprietary algorithms to augment data security and redundancy. Google
employs a code review process to increase the security of the code used to
provide the Services and enhance the security products in production
environments.
Businesses Continuity. Google has designed and
regularly plans and tests its business continuity planning/disaster recovery
programs.
(ii) Networks and Transmission.
Data Transmission. Data centers are typically connected
via high-speed private links to provide secure and fast data transfer between
data centers. This is designed to prevent data from being read, copied, altered
or removed without authorization during electronic transfer or transport or
while being recorded onto data storage media. Google transfers data via
Internet standard protocols.
External Attack Surface. Google employs multiple layers
of network devices and intrusion detection to protect its external attack
surface. Google considers potential attack vectors and incorporates appropriate
purpose built technologies into external facing systems.
Intrusion Detection. Intrusion detection is
intended to provide insight into ongoing attack activities and provide adequate
information to respond to incidents. Google’s intrusion detection involves:
Incident Response. Google monitors a variety of communication
channels for security incidents, and Google’s security personnel will react
promptly to known incidents.
Encryption Technologies. Google makes HTTPS encryption
(also referred to as SSL or TLS connection) available. Google servers support
ephemeral elliptic curve Diffie-Hellman cryptographic key exchange signed with
RSA and ECDSA. These perfect forward secrecy (PFS) methods help protect traffic
and minimize the impact of a compromised key, or a cryptographic breakthrough.
(b) Access and Site Controls
(i) Site Controls.
On-site Data Center Security
Operation.
Google’s data centers maintain an on-site security operation responsible for
all physical data center security functions 24 hours a day, 7 days a week. The
on-site security operation personnel monitor closed circuit TV (CCTV) cameras
and all alarm systems. On-site security operation personnel perform internal
and external patrols of the data center regularly.
Data Center Access Procedures. Google maintains formal access
procedures for allowing physical access to the data centers. The data centers
are housed in facilities that require electronic card key access, with alarms
that are linked to the on-site security operation. All entrants to the data
center are required to identify themselves as well as show proof of identity to
on-site security operations. Only authorized employees, contractors and
visitors are allowed entry to the data centers. Only authorized employees and
contractors are permitted to request electronic card key access to these
facilities. Data center electronic card key access requests must be made
through e-mail, and require the approval of the requestor’s manager and the
data center director. All other entrants requiring temporary data center access
must: (i) obtain approval in advance from the data center managers for the
specific data center and internal areas they wish to visit; (ii) sign in at
on-site security operations; and (iii) reference an approved data center access
record identifying the individual as approved.
On-site Data Center Security
Devices.
Google’s data centers employ a dual authentication access control system that
is linked to a system alarm. The access control system monitors and records
each individual’s electronic card key and when they access perimeter doors,
shipping and receiving, and other critical areas. Unauthorized activity and
failed access attempts are logged by the access control system and
investigated, as appropriate. Authorized access throughout the business
operations and data centers is restricted based on zones and the individual’s
job responsibilities. The fire doors at the data centers are alarmed. CCTV
cameras are in operation both inside and outside the data centers. The
positioning of the cameras has been designed to cover strategic areas
including, among others, the perimeter, doors to the data center building, and
shipping/receiving. On-site security operations personnel manage the CCTV
monitoring, recording and control equipment. Secure cables throughout the data
centers connect the CCTV equipment. Cameras record on site via digital video
recorders 24 hours a day, 7 days a week. The surveillance records are retained
for up to 30 days based on activity.
(ii) Access Control.
Infrastructure Security
Personnel. Google
has, and maintains, a security policy for its personnel, and requires security
training as part of the training package for its personnel. Google’s
infrastructure security personnel are responsible for the ongoing monitoring of
Google’s security infrastructure, the review of the Services, and responding to
security incidents.
Access Control and Privilege
Management.
Partner’s administrators and Partner End Users must authenticate themselves via
a central authentication system or via a single sign on system in order to use
the Services.
Internal Data Access Processes
and Policies – Access Policy. Google’s internal data access processes and policies are
designed to prevent unauthorized persons and/or systems from gaining access to
systems used to process Partner Data. Google designs its systems to (i) only
allow authorized persons to access data they are authorized to access; and (ii)
ensure that Partner Data cannot be read, copied, altered or removed without
authorization during processing, use and after recording. The systems are
designed to detect any inappropriate access. Google employs a centralized
access management system to control personnel access to production servers, and
only provides access to a limited number of authorized personnel. Google’s authentication
and authorization systems utilize SSH certificates and security keys, and are
designed to provide Google with secure and flexible access mechanisms. These
mechanisms are designed to grant only approved access rights to site hosts,
logs, data and configuration information. Google requires the use of unique
user IDs, strong passwords, two factor authentication and carefully monitored
access lists to minimize the potential for unauthorized account use. The
granting or modification of access rights is based on: the authorized
personnel’s job responsibilities; job duty requirements necessary to perform
authorized tasks; and a need to know basis. The granting or modification of
access rights must also be in accordance with Google’s internal data access
policies and training. Approvals are managed by workflow tools that maintain
audit records of all changes. Access to systems is logged to create an audit trail
for accountability. Where passwords are employed for authentication (e.g.,
login to workstations), password policies that follow at least industry
standard practices are implemented. These standards include restrictions on
password reuse and sufficient password strength. For access to extremely
sensitive information (e.g., credit card data), Google uses hardware tokens.
(c) Data
(i) Data Storage, Isolation and
Logging. Google
stores data in a multi-tenant environment on Google-owned servers. Subject to
any Instructions to the contrary (e.g., in the form of a data location
selection), Google replicates Partner Data between multiple geographically
dispersed data centers. Google also logically isolates Partner Data. Partner
will be given control over specific data sharing policies. Those policies, in
accordance with the functionality of the Services, will enable Partner to
determine the product sharing settings applicable to Partner End Users for
specific purposes.
(ii) Decommissioned Disks and
Disk Erase Policy.
Disks containing data may experience performance issues, errors or hardware failure
that lead them to be decommissioned (“Decommissioned Disk”). Every
Decommissioned Disk is subject to a series of data destruction processes (the
“Disk Erase Policy”) before leaving Google’s premises either for reuse or
destruction. Decommissioned Disks are erased in a multi-step process and
verified complete by at least two independent validators. The erase results are
logged by the Decommissioned Disk’s serial number for tracking. Finally, the
erased Decommissioned Disk is released to inventory for reuse and redeployment.
If, due to hardware failure, the Decommissioned Disk cannot be erased, it is
securely stored until it can be destroyed. Each facility is audited regularly to
monitor compliance with the Disk Erase Policy.
(d) Personnel Security
Google personnel are required to conduct
themselves in a manner consistent with the company’s guidelines regarding
confidentiality, business ethics, appropriate usage, and professional
standards. Google conducts reasonably appropriate backgrounds checks to the
extent legally permissible and in accordance with applicable local labor law
and statutory regulations.
Personnel are required to execute a
confidentiality agreement and must acknowledge receipt of, and compliance with,
Google’s confidentiality and privacy policies. Personnel are provided with
security training. Personnel handling Partner Data are required to complete
additional requirements appropriate to their role (e.g., certifications).
Google’s personnel will not process Partner Data without authorization.
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