Data Management Policy¶
Last Reviewed: 2025-02-17:19:44:43-UTC
This policy outlines the requirements and controls/procedures APS has implemented to manage the end-to-end data lifecycle, from data creation/acquisition to retention and deletion.
Additionally, this policy outlines requirements and procedures to create and maintain retrievable exact copies of
PII and other critical customer/business data.
Data backup is an important part of the day-to-day operations of APS. To protect the confidentiality, integrity, and availability of sensitive and critical data, both for APS and APS Customers, complete backups are done daily to assure that data remains available when it needed and in case of a disaster.
Policy Statements¶
APS policy requires that
(a) Data should be classified at time of creation or acquisition according to the APS data classification model, by labeling or tagging the data.
(b) Maintain an up-to-date inventory and data flows mapping of all critical data.
(c) All business data should be stored or replicated to a company controlled repository, including data on end-user computing systems.
(d) Data must be backed up according to its level defined in APS data classification.
(e) Data backup must be validated for integrity.
(f) Data retention period must be defined and comply with any and all applicable regulatory and contractual requirements. More specifically,
- Data and records belonging to APS platform customer must be retained per APS product terms and conditions and/or specific contractual agreements.
(g) By default, all security documentation and audit trails are kept for a minimum of seven years, unless otherwise specified by APS data classification, specific regulations or contractual agreement.
Controls and Procedures¶
Data Classification Model¶
APS defines the following four classifications of data:
- Critical
- Confidential
- Internal
- Public
Definitions and Examples¶
Critical data includes data that must be protected due to regulatory requirements, privacy, and/or security sensitivities.
Unauthorized disclosure of critical data may result in major disruption to business operations, significant cost, irreparable reputation damage, and/or legal prosecution to the company.
External disclosure of critical data is strictly prohibited without an approved process and agreement in place.
Example Critical Data Types includes
- PII
- PCI or CHD (cardholder data)
- Production Security data, such as
- Production secrets, passwords, access keys, certificates, etc.
- Production security audit logs, events, and incident data
Confidential and proprietary data represents company secrets and is of significant value to the company.
Unauthorized disclosure may result in disruption to business operations and loss in value.
Disclosure requires the signing of NDA and management approval.
Example Confidential Data Types includes
- Business plans
- Employee/HR data
- News and public announcements (pre-announcement)
- Patents (pre-filing)
- Specialized source codes
- Non-production Security data, including
- Non-prod secrets, passwords, access keys, certificates, etc.
- Non-prod security audit logs, events, reports, and incident data
- Audit/compliance reports, security architecture docs, etc.
Internal data contains information used for internal operations.
Unauthorized disclosure may cause undesirable outcome to business operations.
Disclosure requires management approval. NDA is usually required but may be waived on a case-by-case basis.
Example Internal Data Types includes
- Internal documentation
- Policies and procedures
- Product roadmaps
- Most source codes
Public data is Information intended for public consumption. Although non-confidential, the integrity and availability of public data should be protected.
Example Internal Data Types includes
- News and public announcements (post-announcement)
- Marketing materials
- Product documentation
- Contents posted on company website(s) and social media channel(s)
Data Handling Requirements Matrix¶
Requirements for data handling, such as the need for encryption and the duration of retention, are defined according to the APS Data Classifications.
| Data | Labeling or Tagging | Segregated Storage | Endpoint Storage | Encrypt At Rest | Encrypt In Transit | Encrypt In Use | Controlled Access | Monitoring | Destruction at Disposal | Retention Period | Backup Recovery |
|---|---|---|---|---|---|---|---|---|---|---|---|
| Critical | Required | Required | Prohibited | Required | Required | Required | Access is blocked to end users by default; Temporary access for privileged users only | Required | Required | 7 years for audit trails; Varies for customer-owned data† | Required |
| Confidential | Required | N/R | Allowed | Required | Required | Required | All access is based on need-to-know | Required | Required | 7 years for official documentation; Others vary based on business need | Required |
| Internal | Required | N/R | Allowed | N/R | N/R | N/R | All employees and contractors (read); Data owners and authorized individuals (write) | N/R | N/R | 7 years for official documentation; Others vary based on business need | Optional |
| Public | N/R | N/R | Allowed | N/R | N/R | N/R | Everyone (read); Data owners and authorized individuals (write) | N/R | N/R | Varies based on business need | Optional |
N/R = Not Required
† customer-owned data is stored for as long as they remain as a APS customer, or as required by regulations, whichever is longer. Customer may request that their data be deleted at any time unless retention is required by law or regulation.
Backup and Recovery¶
Customer Data¶
APS stores data in a secure production account in AWS, using a combination of S3 and EBS By default, Amazon S3 provides durable infrastructure to store important data and is designed for durability of 99.999999999% of objects.
APS performs automatic backup of all customer and system data to protect against catastrophic loss due to unforeseen events that impact the entire system. An automated process will back up all data to a separate AWS region in the same country (e.g. US East to US West). By default, data will be backed up daily. The backups are encrypted in the same way as live production data.
Customers can also utilize the APS Application Programming Interface (API) to extract and store their data elsewhere. Standard API usage fees will apply.
Source code¶
APS stores its source in git repositories hosted by GitHub.
Source code repositories are backed up to APS’s AWS S3 infrastructure account on a weekly basis with a common set of configuration for each repository to enforce SDLC processes.
In the event that GitHub suffers a catastrophic loss of data, source code will be restored from the backups in AWS S3.
Because AWS and GitHub can both host git repositories, we are able to leverage git’s ability to maintain a full history of all changes to our git repos via the commit log.
Business records and documents¶
Each data owner/creator is responsible for maintaining a backup copy of their business files local on their laptop/workstation to the appropriate location on APS Google Workspace site. Examples of business files include, but are not limited to:
- Documents (e.g. product specs, business plans)
- Presentations
- Reports and spreadsheets
- Design files/images/diagrams
- Meeting notes/recordings
- Important records (e.g. approval notes)
Unless the local workstation/device has access to Critical data, backups of user workstations/devices are self managed by the device owner. Backups may be stored on an external hard drive or using a cloud service such as iCloud if and only if the data is both encrypted and password protected (passwords must meet APS requirements).