Introduction

The purpose of this document is to set out the organisation’s policy in the area of cloud computing.

Vertic Pty Ltd makes extensive use of cloud computing services in the delivery of its core business systems. The nature of these services is such that data is stored outside of the Vertic Pty Ltd internal network and is subject to access and management by a third party. Furthermore, many cloud services are offered on a multi-tenanted basis in which the infrastructure is shared across multiple customers of the Cloud Service Provider (CSP), making effective and secure segregation a key requirement.

It is therefore essential that rules are established for the selection and management of cloud computing services so that data is appropriately protected according to its business value and classification.

Cloud computing is generally accepted to consist of the following types of services:

• Software-as-a-Service (SaaS): The provision of a hosted application for use as part of a business process. Hosting usually includes all supporting components for the application such as hardware, operating software, databases etc.

• Platform-as-a-Service (PaaS): Hardware and supporting software such as operating system, database, development platform, web server etc. are provided but no business applications

• Infrastructure-as-a-Service (IaaS): Only physical or virtual hardware components are provided

This policy applies to the use of all types of cloud computing services and is particularly relevant where personal data is stored.

Policy

It is Vertic Pty Ltd policy in cloud computing that:

Data belonging to Vertic Pty Ltd will only be stored within cloud services with the prior permission of the Chief Executive Officer.

Appropriate risk assessment must be carried out regarding proposed or continued use of cloud services, including a full understanding of the information security controls implemented by the CSP.

Due diligence must be conducted prior to sign-up to a cloud service provider to ensure that appropriate controls will be in place to protect data. Preference will be given to suppliers who are certified to the ISO/IEC 27001 international standard.

Service level agreements and contracts with cloud service providers must be reviewed, understood, and accepted before sign-up to the service.

Contracts involving personal data must be checked to ensure that they comply with applicable data protection legislation. If not, a separate data processing agreement may be required.

Roles and responsibilities for activities such as backups, patching, log management, malware protection and incident management must be agreed and documented prior to the commencement of the cloud service.

Procedures must be established to ensure that activities that are irreversible in the cloud environment (e.g. deletion of virtual servers, terminating a cloud service or restoration from backups) are subject to appropriate controls to avoid error. Supervision by a second, suitably qualified person must be a stated part of such procedures.

The location of the data stored with the CSP must be understood e.g. UK, EU, USA and the applicable legal basis established, such as the country whose law applies to the contract.

Where available, multi factor authentication must be used to access all cloud services.

Sufficient audit logging must be available to allow Vertic Pty Ltd to understand the ways in which its data is being accessed and to identify whether any unauthorised access has occurred.

Confidential data stored in cloud services must be encrypted at rest and in transit using acceptable technologies and techniques. Where possible encryption keys will be held by Vertic Pty Ltd rather than the supplier.

All Vertic Pty Ltd data must be removed from cloud services in the event of a contract coming to an end for whatever reason. Data must not be stored in the cloud for longer than is necessary to deliver business processes.