C5 Field Guideunofficial

PSS · Product Safety and Security

PSS-12 Region of Data Processing and Storage

8 sub-criteria: 4 basic, 4 additional, with customer criteria

Changed since C5:2020

Basic criterion

Specified which data types the criterion applies to.

Specified that data being only stored and processed in the region chosen by the cloud service customer is supported not just by the cloud service architecture, but in particular the technical design of the infrastructure.

Added requirement for service organisations to adhere to the choice of region as well.

Added requiremnt regarding contractual agreements about the use of regions.

Added requirement for the cloud service provider to inform cloud service customers about changes to their region.

Additional criterion

Additional criterion newly included.

Wording in C5:2020

Basic criterion

The cloud customer is able to specify the locations (location/country) of the data processing and storage including data backups according to the contractually available options.

This must be ensured by the cloud architecture.

All changes since C5:2020

Basic criterion

PSS-12.01B

The architecture of the cloud service, including the technical design of its infrastructure, ensures that cloud service customer data and eventual data backups thereof are processed and stored only in the region specified in the contractual agreements with the cloud service provider. If the cloud service customer is able to select from multiple regions, processing and storage of the aforementioned data is limited to the selected regions.

Supplementary information

Also applies to 02B, 03B, 04B, 01AS, 01AC, 02AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

PSS-12.02B

Processing and storage of cloud service customer data within the service organisations of the cloud service provider also adheres to the regions selected by the cloud service customer.

Supplementary information

Also applies to 01B, 03B, 04B, 01AS, 01AC, 02AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

PSS-12.03B

The contractual agreements specify the regions in which processing and storage of cloud service customer data, cloud service derived data and account data occurs and the circumstances under which changes may be applied.

Supplementary information

This criterion refers to the architecture of the cloud service and does not put any constraints on the architecture the cloud service customer designs.

If a cloud service provider has several regions that provide the same service, the cloud service customer is free to use the service in different regions (e.g. for more resilience).

This subcriterion refers to contractual agreements which include the pledge for cloud service customer data, cloud service derived data, cloud service provider data and account data to reside in the chosen region. It also covers how contractual agreements are updated, ensuring transparent communication and continued residency for all four types of data in the agreed region(s).

Supplementary information

Also applies to 01B, 02B, 04B, 01AS, 01AC, 02AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

PSS-12.04B

Customers are notified beforehand in case of any changes to the regions in which the aforementioned data is processed or stored. If the cloud service provider has not been granted prior general authorisation by the cloud service customer to do so, such authorisations are obtained in accordance with the requirements specified in the contractual agreements or let the cloud service customer exercise termination rights.

Supplementary information

Also applies to 01B, 02B, 03B, 01AS, 01AC, 02AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

Additional criterion

PSS-12.01AS

Additional, sharpens01B

The architecture of the cloud service, including the technical design of its infrastructure, ensures that the cloud service customer data, cloud service derived data and eventual data backups thereof are processed and stored only in the region specified in the contractual agreements with the cloud service provider. If the cloud service customer is able to select from multiple regions, processing and storage of the aforementioned data is limited to the selected regions.

Supplementary information

Also applies to 01B, 02B, 03B, 04B, 01AC, 02AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

PSS-12.02AS

Additional, sharpens02B

Processing and storage of cloud service customer data and cloud service derived data within the service organisations of the cloud service provider also adheres to the regions selected by the cloud service customer.

PSS-12.01AC

Additional, complementing

The cloud service provider offers partitions selectable by the cloud service customer where partition-specific identity management is enforced for both cloud service customers and all cloud service provider personnel. Identity verification and identity storage are confined to the geographical boundaries of the selected partition.

Supplementary information

Also applies to 01B, 02B, 03B, 04B, 01AS, 02AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

PSS-12.02AC

Additional, complementing

Within these partitions, the following operations by the cloud service provider are restricted to occur only within the geographical boundaries of the customer-selected partitions:

  1. Privileged access to the production environment by the cloud service provider, including potential access to cloud service customer data and cloud service derived data;
  2. System logging and event monitoring by the cloud service provider, except for processing event logs specifically for threat intelligence and handling IP addresses for routing purposes; and
  3. Cryptographic key management and storage practices to ensure keys are handled and stored within limits of the partition.

These restrictions considering partitions also apply to any service organisations involved in the operation of the cloud service.

Supplementary information

Also applies to 01B, 02B, 03B, 04B, 01AS, 01AC

This criterion supplements the General Condition GC-01. It does not require the cloud service provider to offer multiple regions or partitions. If the cloud service provider offers only one partition for the cloud service(s) in scope, this does not comprise a deviation from the criterion.

If the additional complemental criterion is only applicable for selected partitions in scope of an assurance engagement in accordance with this catalogue, this should be presented in the cloud service provider's description of its system of internal control for the cloud service.

This criterion is a prerequisite for technical service sovereignty.

Monitoring of threat intelligence data, which excludes any cloud service customer data and account data, and logging of required routing information such as IP addresses are not required to be geographically limited to a single partition.

Complementary customer criteria

What cloud service customers implement on their side.

Cloud service customers ensure with suitable controls that, when selecting service providers and configuring the cloud service, they are informed about the available data processing and storage partitions and, if there is a choice between different partitions, that they select those that meet their own requirements.

Depending on the use case and especially when using services of a cloud service provider which is based in another country, cloud service customers take the laws of their own jurisdiction applicable to them into account when making their selection (e.g. when processing personal data; compliance with legal retention obligations for business documents, etc.).

All customer criteria in one place

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