Last modified: September 27, 2021 | Previous Versions
The customer agreeing to these terms (“Customer”), 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 Customer (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 as 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 “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 the Customer 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 that is the subject of an adequacy decision by the Commission under Article 45(1) of the EU GDPR;
(b) for data processed subject to the UK GDPR: the UK or a country or territory that is the subject of the adequacy regulations under Article 45(1) of the UK GDPR and Section 17A of the Data Protection Act 2018; and/or
(c) for data processed subject to the Swiss FDPA: Switzerland, or a country or territory that (i) is included in the list of the states whose legislation ensures an adequate level of protection as published by the Swiss Federal Data Protection and Information Commissioner, or (ii) is the subject of an adequacy decision by the Swiss Federal Council under the Swiss FDPA.
● Alternative Transfer Solution means a solution, other than the SCCs, that enables the lawful transfer of personal data to a third country in accordance with European Data Protection Law.
● Chronicle’s Third Party Auditor means a Chronicle-appointed, qualified and independent third party auditor, whose then-current identity Chronicle will disclose to Customer.
● Customer Personal Data means the personal data contained within the Customer Data, including any special categories of personal data defined under European Data Protection Law.
● Customer SCCs means the SCCs (EU Controller-to-Processor), SCCs (EU Processor-to-Processor), the SCCs (EU Processor-to-Controller), and/or the SCCs (UK Controller-to-Processor), as applicable.
● Data Incident means a breach of Chronicle’s security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer 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 Customer Personal Data); and (b) the law of the UK or a part of the UK (if the UK GDPR applies to the processing of Customer 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 (Customer’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 Customer in the Order Form to receive certain notifications from Chronicle. Customer is responsible for ensuring that its Notification Email Address remains current and valid.
● SCCs means the Customer SCCs and/or SCCs (EU Processor-to-Processor, Chronicle Exporter), as applicable.
● SCCs (EU Controller-to-Processor) means the terms at: https://chronicle.security/legal/sccs/eu-c2p.
● SCCs (EU Processor-to-Controller) means the terms at: https://chronicle.security/legal/sccs/eu-p2c.
● SCCs (EU Processor-to-Processor) means the terms at: https://chronicle.security/legal/sccs/eu-p2p.
● SCCs (EU Processor-to-Processor, Chronicle Exporter) means the terms at: https://chronicle.security/legal/sccs/eu-p2p-chronicle-exporter.
● SCCs (UK Controller-to-Processor) means the terms at: https://chronicle.security/legal/sccs/uk-c2p.
● 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 Customer 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 Customer 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 Customer 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 Customer 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 Customer 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 Customer 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 Customer Personal Data:
4.1.2 Processor Customers. If European Data Protection Law applies to the processing of Customer Personal Data and Customer is a processor:
a. Customer warrants on an ongoing basis that the relevant controller has authorized: (i) the Instructions, (ii) Customer’s appointment of Chronicle as another processor, and (iii) Chronicle’s engagement of Subprocessors as described in Section 10 (Subprocessors);
b. Customer will immediately forward to the relevant 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. Customer may:
i. request access for the relevant controller to the SOC Reports in accordance with Section 6.5.3(a); and
ii. make available to the relevant 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 Customer Personal Data, the relevant party will comply with any obligations applicable to it under that law with respect to the processing of that Customer Personal Data.
4.2 Scope of Processing.
4.2.1 Customer’s Instructions. Customer instructs Chronicle to process Customer Personal Data in accordance with applicable law only: (a) to provide, secure, and monitor the Services and Chronicle TSS; (b) as further specified via Customer’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 Customer 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 Instructions unless prohibited by European Law.
4.2.3 Instruction Notifications. Chronicle will immediately notify Customer 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 Customer. During the Term, Chronicle will enable Customer to delete Customer Data upon request in a manner consistent with the functionality of the Services. If Customer requests deletion of any Customer Data during the Term and that Customer Data cannot be recovered by Customer, this request will constitute an Instruction to Chronicle to delete the relevant Customer 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, Customer instructs Chronicle to delete all remaining Customer 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. Customer is responsible for notifying Chronicle before the Term expires of any Customer Data that Customer wishes to export and, if Customer does so, Chronicle will assist Customer in exporting such Customer 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 Customer 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 personal data; to help ensure ongoing confidentiality, integrity, availability and resilience of Chronicle’s systems and services; to help restore timely access to personal 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 Customer Personal 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 Customer Personal Data are under an obligation of confidentiality.
6.1.3 Additional Security Controls. Chronicle may make Additional Security Controls available to: (a) allow Customer to take steps to secure Customer Data; and (b) provide Customer with information about securing, accessing and using Customer Data.
6.1.4 Chronicle Security Assistance. Chronicle will (taking into account the nature of the processing of Customer Personal Data and the information available to Chronicle) assist Customer in ensuring compliance with its (or, where Customer 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 Customer promptly and without undue delay after becoming aware of a Data Incident, and promptly take reasonable steps to minimize harm and secure Customer 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 Customer 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 Customer 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 Customer Data by Chronicle. Chronicle has no obligation to assess Customer 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 Customer’s Security Responsibilities and Assessment.
6.3.1 Customer’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, Customer is responsible for its use of the Services and its storage of any copies of Customer Data outside Chronicle or Chronicle’s Subprocessors’ systems, including:
6.3.2 Customer’s Security Assessment. Customer 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 Customer Data (taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing of Customer 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: 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 Customer to demonstrate compliance by Chronicle with its obligations under these Terms.
6.5.2 Customer’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 Customer in ensuring compliance with its (or, where Customer 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 Customer, in a manner consistent with the functionality of the Services, to access, rectify and restrict processing of Customer Data, including via the deletion functionality provided by Chronicle as described in Section 5.1 (Deletion by Customer). If Customer becomes aware that any Customer Personal Data is inaccurate or outdated, Customer will be responsible for notifying Chronicle and Chronicle will assist Customer 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 Customer Personal Data, and identifies Customer, Chronicle will: (a) advise the data subject to submit their request to Customer; (b) promptly notify Customer; and (c) not otherwise respond to that data subject’s request without authorization from Customer. Customer 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 Customer Personal Data) assist Customer in fulfilling its (or, where Customer 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), Customer Data may be processed in any country in which Chronicle or its Subprocessors maintain facilities.
9.2 Permitted Transfers. The parties acknowledge that European Data Protection Law does not require SCCs or an Alternative Transfer Solution in order for Customer Personal Data to be processed in or transferred to an Adequate Country (“Permitted Transfers”).
9.3 Restricted Transfers. If the processing of Customer Personal Data involves any transfers that are not Permitted Transfers, and European Data Protection Law applies to those transfers if Customer’s address is outside EMEA (“Restricted Transfers”), then:
A. the SCCs (EU Processor-to-Processor, Chronicle Exporter) will apply with respect to all Restricted Transfers from Chronicle to Subprocessors; and
B. in addition, if Customer’s address is not in an Adequate Country, the SCCs (EU Processor-to-Controller) will apply (regardless of whether Customer is a controller and/or processor) with respect to Restricted Transfers between Chronicle and Customer; or
A. the SCCs (EU Controller-to-Processor) and/or SCCs (EU Processor-to-Processor) will apply (according to whether Customer is a controller and/or processor) with respect to Restricted Transfers between Customer and Chronicle that are subject to the EU GDPR and/or the Swiss FDPA; and
B. the SCCs (UK Controller-to-Processor) will apply (regardless of whether Customer is a controller and/or processor) with respect to Restricted Transfers between Customer and Chronicle that are subject to the UK GDPR.
9.4 Supplementary Measures and Information. Chronicle may provide Customer with information relevant to Restricted Transfers, including information about Additional Security Controls and other supplementary measures to protect Customer Personal Data as described in Section 6.5.1 (Reviews of Security Documentation).
9.5 Termination. If Customer 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 Customer Personal Data, then Customer 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. Customer specifically authorizes the engagement as Subprocessors of those entities listed in Section 10.2 (Information about Subprocessors). In addition, without prejudice to Section 10.4 (Opportunity to Object to Subprocessor Changes), Customer 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 such URLs 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 Customer queries related to processing of Customer Personal Data under the Agreement and can be contacted at https://support.google.com/cloud/contact/dpo (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 Customer, Customer 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 Customer Personal Data, Chronicle will advise the third party to contact Customer.
12.1 Precedence. To the extent of any conflict or inconsistency between:
12.2 Legacy MCCs. The SCCs will, as of the Transition Date, supersede and terminate any Model Contract Clauses approved under Directive 95/46/EC and previously entered into by Customer and Chronicle LLC. The “Transition Date” means: (a) if Customer’s billing address is outside EMEA, and the processing of Customer Personal Data is subject to European Data Protection Law, then 27 October 2021; or (b) otherwise, 27 September 2021. Where Chronicle LLC is not a party to the Agreement, Chronicle LLC will be a third party beneficiary of this Section 12.2.
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.
Chronicle’s provision of the Services and Chronicle TSS to Customer.
Duration of the Processing
The Term plus the period from the end of the Term until deletion of all Customer Data by Chronicle in accordance with the Terms.
Nature and Purpose of the Processing
Chronicle will process Customer Personal Data for the purposes of providing the Services and Chronicle TSS to Customer in accordance with the Terms.
Categories of Data
Data relating to individuals provided to Chronicle via the Services, by (or at the direction of) Customer or by Customer End Users.
Data subjects include the individuals about whom data is provided to Chronicle via the Services by (or at the direction of) Customer or by Customer 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 an electronic card key and biometric 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. Customer’s administrators and Customer 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 personal data. Google designs its systems to (i) only allow authorized persons to access data they are authorized to access; and (ii) ensure that personal 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 Chronicle’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.
(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 (for example, in the form of a data location selection), Google replicates Customer Data between multiple geographically dispersed data centers. Google also logically isolates Customer Data. Customer will be given control over specific data sharing policies. Those policies, in accordance with the functionality of the Services, will enable Customer to determine the product sharing settings applicable to Customer 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 Customer Data are required to complete additional requirements appropriate to their role (e.g., certifications). Google’s personnel will not process Customer Data without authorization.