CONFIDENTIAL — Shared under mutual NDA. These documents are proprietary to CloudFive and may not be reproduced, distributed, or disclosed outside your organization without prior written consent.
Contents
1
Information Security Policy
Core security controls, access management, and data classification
2
Data Handling & Privacy Policy
How CloudFive collects, processes, stores, and deletes client data
3
Incident Response Policy
Detection, containment, notification, and post-mortem procedures
4
Vulnerability Management Policy
Continuous scanning, patch cadence, and remediation SLAs
5
Business Continuity & Disaster Recovery
RPO/RTO targets, backup strategy, and continuity procedures
6
Subprocessor List
Third-party tools and cloud services used in client engagements
Policy 1 of 6
Information Security Policy
Effective: June 2026 · Owner: Todd Densmore · Review: Annual
1. Purpose
This policy establishes the security controls and practices CloudFive uses to protect the confidentiality, integrity, and availability of client data and systems. It applies to all services delivered by CloudFive and all systems, devices, and accounts used in the delivery of those services.
2. Scope
This policy applies to all CloudFive systems, cloud environments, client data, and third-party integrations used during an engagement. It covers all delivery personnel operating under the CloudFive umbrella.
3. Information Classification
Confidential: Client data, credentials, proprietary business logic, NDA-covered materials. Must be encrypted at rest and in transit. Access restricted to need-to-know.
Internal: Operating procedures, tooling configuration, internal communications. Not for public disclosure.
Public: Marketing materials, open-source repositories, published case studies (with client consent).
4. Access Control
All cloud console access uses MFA (TOTP or hardware key). Passwords not used without MFA.
IAM roles follow least-privilege; no standing admin access. Elevated roles are assumed temporarily via AWS IAM role assumption and logged.
SSH access to servers uses key-based authentication only. Root login is disabled.
Client credentials (API keys, secrets) are stored in AWS Secrets Manager or equivalent secret store — never in source control or plaintext files.
Access to client systems is revoked within 24 hours of engagement close.
5. Endpoint Security
Primary development machine runs macOS with FileVault full-disk encryption enabled.
OS and software patches are applied within 30 days of release; critical patches within 7 days.
Screen lock activates after 5 minutes of inactivity.
No client data is stored on local disk beyond the active engagement window. Data is purged or returned at engagement close.
6. Network Security
All client work is performed over a secured home office network with WPA3 or equivalent. Public Wi-Fi is avoided; VPN is required if used.
AWS VPCs are used to segment environments. Security groups follow deny-by-default.
All data in transit uses TLS 1.2 minimum. TLS 1.3 preferred for new deployments.
7. Data Handling
Client production data is not used in development or test environments without explicit written consent.
Backups of client data are encrypted using AES-256 and stored in isolated AWS S3 buckets with versioning enabled.
Data retention follows the terms of the engagement contract. Default: 90 days post-engagement, then permanent deletion.
8. Third-Party & Subprocessors
Third-party services used in client engagements are documented in the Subprocessor List (Policy 6). CloudFive does not share client data with third parties except as required to deliver the agreed scope of work. All third-party tools are reviewed for SOC 2 compliance or equivalent prior to use with client data.
9. Policy Review
This policy is reviewed annually and updated within 30 days of any material change in infrastructure, tooling, or regulatory requirements.
10. Contact
Security inquiries: todd@cloudfive.net
Policy 2 of 6
Data Handling & Privacy Policy
Effective: June 2026 · Owner: Todd Densmore · Review: Annual
1. Purpose
This document describes how CloudFive collects, uses, stores, protects, and deletes data belonging to clients, their customers, and other third parties. CloudFive's default position is data minimization: we access and retain only what is necessary to deliver the agreed scope of work.
2. Data Categories Processed
Category
Examples
Basis for processing
Client operational data
Databases, logs, files shared for analysis
Contractual necessity
Client contact data
Name, email, phone of client personnel
Contractual necessity
End-user PII (if applicable)
Names, emails in client systems
Client instruction only; DPA required
Financial data
Invoice data, payment records
Legal obligation
3. Data Collection
CloudFive collects only the minimum data required to complete the engagement.
Access to client production systems requires explicit written authorization per engagement.
Any access to end-user PII requires a signed Data Processing Agreement (DPA) prior to engagement start.
4. Data Storage
All client data in CloudFive's custody is stored in AWS (us-east-1 or us-east-2 by default, unless client specifies otherwise).
Data at rest is encrypted with AES-256 (AWS managed keys, or CMKs for sensitive engagements).
Data in transit uses TLS 1.2+.
No client data is stored in personal cloud storage or unencrypted local disk.
5. Data Access
Client data is accessed only by CloudFive personnel with a need-to-know for the engagement.
Access logs are retained for 90 days minimum in AWS CloudTrail.
Sub-contractors are not granted access to client data without prior written client consent.
6. Data Retention & Deletion
During engagement: Data is retained as required to deliver services.
Post-engagement default: 90 days, then permanent deletion.
On client request: Deletion within 10 business days. Certificate of deletion provided upon request.
Legal hold: Data may be retained longer if required by law or litigation.
7. Data Sharing
CloudFive does not sell, rent, or share client data. The only permitted disclosures are subprocessors necessary to deliver the service, legal requirements (client notified where legally permissible), and client-directed sharing.
8. Breach Notification
In the event of a confirmed data breach affecting client data, CloudFive will notify affected clients within 72 hours of confirmation. Notification will include the nature of the breach, data affected, mitigation steps taken, and recommended client actions.
9. Contact
Data handling inquiries: todd@cloudfive.net
Policy 3 of 6
Incident Response Policy
Effective: June 2026 · Owner: Todd Densmore · Review: Annual
1. Purpose
This policy defines how CloudFive detects, responds to, and recovers from security incidents affecting client data or CloudFive systems.
2. What Constitutes an Incident
Unauthorized access to CloudFive or client systems
Data breach or suspected exfiltration of client data
P4 — Low: Policy violation, failed intrusion attempt. Response: within 5 business days.
4. Response Phases
Phase 1 — Detection & TriageIdentify the incident through monitoring alerts (AWS GuardDuty, CloudTrail anomalies, endpoint alerts) or external report. Assess severity. Assign P-level. Begin incident log.
Phase 2 — ContainmentIsolate affected systems (revoke credentials, quarantine EC2 instances, disable compromised accounts). Preserve evidence before remediation.
Phase 3 — EradicationRemove threat, rotate all potentially exposed credentials, review access logs to identify full scope, patch exploited vulnerability.
Phase 4 — RecoveryRestore systems from clean backups. Verify integrity before returning to production. Monitor closely for 48 hours post-recovery.
Phase 5 — Post-MortemConduct blameless post-mortem within 5 business days. Document timeline, root cause, impact, response actions, and prevention measures.
5. Client Notification
P1/P2 incidents affecting client data: initial notification within 72 hours of confirmation.
Follow-up full incident report provided within 14 days.
CloudFive will cooperate fully with client forensic investigations.
6. Contact
To report a suspected incident: todd@cloudfive.net with subject line [SECURITY INCIDENT].
Policy 4 of 6
Vulnerability Management Policy
Effective: June 2026 · Owner: Todd Densmore · Review: Annual
1. Purpose
This policy defines how CloudFive identifies, prioritizes, remediates, and tracks security vulnerabilities in its systems and the client environments it manages.
2. Vulnerability Sources
AWS Inspector — continuous scanning of EC2, Lambda, and container images
AWS Security Hub — aggregated findings from GuardDuty, Config, Inspector, and Macie
To report a vulnerability: todd@cloudfive.net with subject [VULNERABILITY REPORT]. We acknowledge within 2 business days and request a 90-day coordinated disclosure window.
Policy 5 of 6
Business Continuity & Disaster Recovery Policy
Effective: June 2026 · Owner: Todd Densmore · Review: Annual
1. Purpose
This policy defines how CloudFive maintains service continuity and recovers from disruptive events including infrastructure failures, data loss, and personal incapacitation. Given CloudFive's structure as a single-operator consultancy, this policy prioritizes transparency with clients when disruptions occur.
S3 data: Versioning enabled on all client data buckets. Cross-region replication for critical buckets.
Infrastructure as code: All infrastructure defined in Terraform/CDK, committed to Git. Environment can be rebuilt from code.
Credentials: Stored in 1Password with emergency kit secured offline.
Development laptop: Time Machine to encrypted local drive + cloud backup. RPO: daily.
4. Scenario Responses
AWS region outage: Restore from snapshots in secondary region. Estimated RTO: 4 hours.
Data corruption: Restore from versioned S3 or RDS snapshot to the last known-good state.
Ransomware: Isolate affected systems. Restore from immutable backups (S3 Object Lock where applicable). Do not pay ransom.
Operator incapacitation (illness, emergency): Client is notified within 24 hours. A documented handoff procedure covers repository access, credential recovery, and in-flight work status so engagements can be transitioned or paused without data loss.
5. Client Notification
CloudFive will notify affected clients within 4 hours of any disruption expected to exceed 2 hours for P1 clients, or 24 hours for P2/P3 engagements. Status updates every 2 hours until resolved.
6. Contact
Todd Densmore — todd@cloudfive.net
Policy 6 of 6
Subprocessor List
Effective: June 2026 · Owner: Todd Densmore · Review: Quarterly
The following third-party services may be used in the delivery of CloudFive engagements. Client data is shared with a subprocessor only where required to deliver the agreed scope of work. CloudFive does not use subprocessors for advertising or data monetization.
Infrastructure & Compute
Vendor
Purpose
Data shared
HQ
Compliance
Amazon Web Services
Cloud infrastructure, compute, storage, databases
Client data per engagement scope
USA
SOC 2 Type II, ISO 27001, PCI DSS
GitHub (Microsoft)
Source code hosting, CI/CD
Source code only; no PII without consent
USA
SOC 2 Type II, ISO 27001
AI & LLM Services (when applicable)
Vendor
Purpose
Data shared
HQ
Compliance
Anthropic
Claude API — AI workflow automation
Prompt content per engagement; no training on API data
USA
SOC 2 Type II
OpenAI
GPT API — when specified by client or engagement
Prompt content per engagement; Business API no-training opt-out
USA
SOC 2 Type II
Communication & Productivity
Vendor
Purpose
Data shared
HQ
Compliance
Google Workspace
Email, calendar, documents
Email communications; no client data stored in Docs without consent
USA
SOC 2 Type II, ISO 27001
Resend
Transactional email delivery
Email address, message content
USA
SOC 2 Type II
Security & Operations
Vendor
Purpose
Data shared
HQ
Compliance
1Password (AgileBits)
Credential and secret management
Encrypted credential vaults only
Canada
SOC 2 Type II, ISO 27001
Change Notification
CloudFive will provide 30 days advance notice before adding a new subprocessor that will process client personal data. Contact: todd@cloudfive.net