Data Security Policy

Technical and organisational measures for protecting data processed through the Adoptic platform.

Version 1.0 [DATE] [Adoptic Pty Ltd]
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1. Purpose

This Data Security Policy describes the technical and organisational measures Adoptic employs to protect the confidentiality, integrity, and availability of data processed through the platform. It supplements our Privacy Policy and applies to all staff, contractors, and service providers.

2. Scope

3. Data Classification

ClassificationDescriptionHandling
ConfidentialClient data, Personal Information, Derived Data, uploaded documents, credentialsEncrypted at rest & in transit; access restricted; logged
InternalSystem configurations, internal notes, analytics, error logsAdoptic personnel only; not shared externally
PublicAnonymised reports, marketing materials, this policyNo restrictions

All data is Internal by default. Client Data and uploads are always Confidential.

4. Infrastructure Security

4.1 Hosting Environment

ComponentProviderLocation
Application serversAWS / Railway (transitioning to AWS)[REGION] / US
DatabasePostgreSQL on [AWS RDS / Railway][REGION]
File storage[AWS S3][REGION]

4.2 Network Security

4.3 Server Hardening

4.4 Environment Separation

EnvironmentPurposeData
ProductionLive platformReal client data (Confidential)
StagingPre-release testingSynthetic / anonymised only
DevelopmentLocal developmentSynthetic / anonymised only

Real Client Data is never used in non-production environments without explicit authorisation.

5. Application Security

5.1 Authentication

5.2 Authorisation

5.3 Input Validation

5.4 Secure Development

6. Data Protection

6.1 Encryption

StateMethod
In transitTLS 1.2+ (HTTPS)
At restAES-256 for database and storage volumes
PasswordsPBKDF2-SHA256 one-way hashing
BackupsEncrypted by hosting provider

6.2 Backups

6.3 Data Isolation

6.4 Document & File Security

7. Data Science and Analytical Processing Security

7.1 Processing Controls

7.2 Model & Algorithm Security

7.3 De-identification Standards

7.4 Training Data Governance

7.5 AI/LLM Processing Security

Adoptic's analytical pipeline includes AI processing via Amazon Bedrock, a managed AI service by AWS.

Provider security:

Authentication & access:

Data residency:

Data handling:

Operational controls:

8. Access Control

9. Logging and Monitoring

Event TypeDetails Logged
AuthenticationLogin attempts (success/failure), logouts, password changes, invitation redemptions
AccessPages accessed, reports generated/downloaded, data exports
Admin actionsRole changes, invitation creation, configuration changes
Data modificationRecord creation, updates, deletions (audit trail)
SystemServer errors, exceptions, deployment events
ConsentGrants and revocations with timestamps and IPs

Logs stored separately, do not contain passwords or Client Data content, retained for [PERIOD].

10. Incident Response

StepActionTimeframe
1. IdentifyDetect and confirm; assign incident leadImmediately
2. ContainIsolate systems, revoke credentialsWithin hours
3. AssessDetermine scope, cause, affected data/clientsWithin 24h
4. NotifyClients, OAIC/ICO if required, affected individualsWithin 72h
5. RemediateFix root cause, restore systems, prevent recurrenceASAP
6. ReviewPost-incident review, update policiesWithin 30 days

Affected clients notified within 24 hours where practicable, including: nature of incident, data affected, measures taken, and recommended actions.

11. Data Retention and Disposal

Client data deleted or returned on contract termination. Deletion confirmed in writing on request.

12. Business Continuity and Disaster Recovery

13. Third-Party Risk Management

14. Acceptable Use

All users agree to:

Violations may result in immediate suspension or termination of access.

15. Compliance

StandardRelevance
Australian Privacy Act 1988Legal obligation for Personal Information in Australia
Notifiable Data Breaches schemeMandatory breach notification
UK GDPR / EU GDPRApplicable for UK/EEA residents
ISO/IEC 27001:2022Information security best practices (aspirational)
OWASP Top 10Application security baseline
CIS ControlsInfrastructure security (aspirational)

[PLANNED] Formal ISO 27001 certification and SOC 2 Type II report.

16. Policy Review

Reviewed at least annually, or in response to:

17. Responsibilities

RoleResponsibility
[Security Officer]Owns this policy; oversees security, incident response, compliance
Development teamTechnical security controls, application & infrastructure security, code review
Data science teamAnalytical compliance, de-identification standards, model documentation
All staffPolicy compliance, security training, incident reporting

18. Contact

[Adoptic Pty Ltd]
ABN: [XX XXX XXX XXX]
Email: [SECURITY CONTACT EMAIL]
Website: adoptic.online

To report a vulnerability, email [SECURITY CONTACT EMAIL] with "Security Vulnerability" in the subject. Acknowledged within 1 business day.

Also see Privacy Policy →