Integration · security

Security and compliance

Written for the person who has to sign the third-party risk assessment. It includes what we have not certified yet, in the same typeface as everything else, because you will find that out in due diligence anyway and finding it here costs you less time.

Current posture

The honest version, ahead of the questionnaire.

ControlStatusDetail
Australian data residencyBy designap-southeast-2 only; no cross-border transfer or support access
Encryption in transit and at restIn placeTLS 1.3, AES-256, customer-managed keys available
Data minimisationBy designEnforced by the data model, not by configuration
Automated decision transparencyBuiltAPP 1 disclosure generated per claim ahead of 10 Dec 2026
Protected-attribute firewallBuilt, testedRuntime error, not a filter
Audit loggingBuiltAppend-only; reports replayable to a rule-set fingerprint
Penetration testNot yet performedScheduled before first production tenant
ISO 27001 / SOC 2 Type IINot certifiedControls designed against both; no audit engaged yet
Production operating historyNoneNo production tenant to date

Data residency

Australian claim data stays in Australia. Not "primarily", not "unless support requires otherwise" - the architecture has no path out of the region.

  • All storage and compute in ap-southeast-2 (Sydney).
  • Backups replicate to a second availability zone within the same region, never to another region.
  • Support access is from Australia, through the same region, logged against a named individual.
  • No sub-processor outside Australia has access to claim content. The sub-processor list is provided in the due diligence pack and changes are notified in advance.

What we hold

The strongest privacy control available is not holding the data. The data model is built to need very little.

Held

Necessary to answer the question

Claim identifier, product class, jurisdiction, scheme. Claim events with dates. Documents you send us, their classification and extracted facts. Findings and their anchors.

Not held

Stays in your system of record

Customer names and contact details unless they appear in a document you send. Reserves, payments and financials. Claim notes. Any copy of your policy administration data.

Never used

Firewalled in code

Postcode, ethnicity, language, interpreter need, disability, mental health, Centrelink receipt, credit score, prior AFCA complaint, legal representation - excluded from integrity assessment by a runtime error, not a filter.

Encryption and key management

LayerControl
In transitTLS 1.3, HSTS with preload. mTLS available. AWS PrivateLink where public internet transit is unacceptable.
At restAES-256. Documents encrypted per tenant with a distinct data key.
Key managementAWS KMS in ap-southeast-2. Customer-managed keys supported - you hold revocation, and revoking the key makes your data unreadable to us.
SecretsNo credential in source or configuration files. Rotation without downtime; client secrets rotate independently of tokens.
In useDocuments are processed in memory and not written to local disk on processing nodes.

Access control

  • Tenant isolation at the storage layer, not by a WHERE tenant_id clause that one missing filter can defeat.
  • Scoped API credentials - an ingestion service holding events:write cannot read a document back out. See scopes.
  • SSO and SCIM for the console: SAML 2.0 or OIDC, with group-driven provisioning and de-provisioning.
  • Role separation - handler, team leader, governance and rule administrator are distinct. Drafting a rule and activating it are separate permissions held by different people.
  • Break-glass access is time-boxed, requires a second approver, and writes an audit record that cannot be deleted by the person who used it.

APRA CPS 234

You remain accountable for information security regardless of who operates the control. What follows is what we do and what we can evidence, mapped to the paragraphs your assessment will reference.

RequirementHow it is met
Clear roles and responsibilities (para 13)Named security owner. RACI provided in the due diligence pack.
Capability commensurate with threat (paras 15-17)Controls designed to ISO 27001 Annex A. No external certification yet - see posture.
Classification by criticality (paras 18-20)Claim documents classified as sensitive by default; no lower tier exists for claim content.
Third-party assurance (paras 21-22)Sub-processor list, zero-retention model terms, and this page. Right to audit offered contractually.
Testing (paras 27-32)Automated control tests in CI. Independent penetration test not yet performed - scheduled before first production tenant.
Internal audit (paras 33-34)Your internal audit may review our control design. We have no internal audit function of our own at this stage.
Notification (paras 35-36)Material incident notified within 12 hours, so you can meet your 72-hour obligation with time to assess. See incident response.

APRA CPS 230

In force since 1 July 2025. If any part of your claims handling depends on us, we are a material service provider and you need the following on file.

ObligationPosition
Tolerance levels for disruptionAgreed per tenant. Because obligation positions are computed rather than stored, a period of unavailability does not corrupt state - positions recompute correctly on recovery.
Critical operations mappingWe support claims handling and regulatory reporting. We are not in the payment path and cannot stop a payment.
Service provider registerRegister entry drafted for you, including sub-processors, in the due diligence pack.
Exit planFull export of events, documents, findings and reports in the documented JSON schema, on demand and at exit. No proprietary format and no export fee.
Business continuityMulti-AZ within ap-southeast-2. Not yet exercised under production load, because there is no production load yet.
Concentration riskWe run on AWS. If that is a concentration your board has already flagged, it applies here too.

Privacy Act and APP 1

PrinciplePosition
APP 1 - open and transparent managementThe automated decision-making disclosure is generated per claim: what is decided automatically, what is not, what information is used, how a person is involved. Built ahead of the 10 December 2026 commencement rather than after it.
APP 3 - collectionWe collect only what you send. The data model has no field for information we do not need.
APP 6 - use and disclosureClaim content is used to answer your questions about your claims. It is not used for training, benchmarking, or any cross-tenant analysis.
APP 8 - cross-border disclosureNot engaged. There is no cross-border disclosure of claim content.
APP 11 - securitySee encryption and access control.
APP 12 - accessWhere a customer requests their information, every finding about their claim is already anchored to the pages it came from, so an access request is answerable rather than archaeological.

You remain the APP entity for claim personal information; we are your service provider and act on your instructions. The data processing agreement reflects that.

AI governance

APRA's April 2026 letter to boards flagged third-party AI risk specifically. Three distinctions matter for your model risk register.

1

Most of the system is not a model

The obligation engine, the five integrity detectors and the seven coverage checks are deterministic code with no model call. Same inputs, same output, every time. This is the part that produces positions and findings.

2

Models are used for reading and drafting, not deciding

Document classification and extraction, and drafting a candidate rule from a prompt. A drafted rule cannot activate itself - it enters review carrying verified: false and a person activates it.

3

Nothing decides a claim

There is no endpoint that declines, reduces or recovers. recommendation is hardcoded to "review". This is an architectural property you can verify in the source rather than a commitment you have to trust.

Retention and deletion

DataDefault retentionNotes
Claim events7 yearsConfigurable to your record-keeping policy; append-only within the period
DocumentsYour settingOr hold none - submit by pre-signed URL and we retain extracted facts and anchors only
Findings and reports7 yearsRetained as compliance evidence; deleting a report deletes evidence you may need
Audit logs7 yearsNot deletable by tenant administrators, by design

Deletion is verified, not merely marked. On exit you get a full export first, then deletion, then written confirmation identifying what was deleted and when.

Incident response

1

Detect and contain

24/7 alerting on authentication anomalies, egress volume and access-pattern deviation.

2

Notify you within 12 hours

Of a material incident affecting your data - deliberately inside your CPS 234 72-hour window so you have time to assess rather than react.

3

Assess against the NDB scheme

Jointly. You are the APP entity; we provide the forensic detail you need to make the assessment.

4

Post-incident review

Written, shared with you, including what we got wrong. Provided whether or not you ask for it.

Due diligence pack

Provided on request, under NDA, before any commercial discussion:

  • Completed third-party risk questionnaire in your format, or CAIQ if you have none
  • Sub-processor list with locations and data categories
  • Data processing agreement and draft service provider register entry (CPS 230)
  • Architecture and data flow diagrams
  • Business continuity and exit plan
  • Source access for the engine, so your model risk function can read the code that produces positions and findings rather than accept a description of it

Request the pack