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Back in the early days of the Internet, you could physically see the hardware where your data was stored. You knew where your data was and what kind of locks and security protections you had in place. Fast-forward a few decades, and data is all “in the cloud”. Now, you have to trust that your cloud services provider is putting security precautions in place just as you would have if your data was still sitting on your hardware. The good news is, you don’t have to merely trust your provider anymore. There are a number of ways a cloud services provider can prove it has robust privacy and security protections in place.
Today, we are excited to announce that Cloudflare has taken three major steps forward in proving the security and privacy protections we provide to customers of our cloud services: we achieved a key cloud services certification, ISO/IEC 27018:2019; we completed our independent audit and received our Cloud Computing Compliance Criteria Catalog (“C5”) attestation; and we have joined the EU Cloud Code of Conduct General Assembly to help increase the impact of the trusted cloud ecosystem and encourage more organizations to adopt GDPR-compliant cloud services.
Cloudflare has been committed to data privacy and security since our founding, and it is important to us that we can demonstrate these commitments. Certification provides assurance to our customers that a third party has independently verified that Cloudflare meets the requirements set out in the standard.
ISO/IEC 27018:2019 - Cloud Services Certification
2022 has been a big year for people who like the number ‘two’. February marked the second when the 22nd Feb 2022 20:22:02 passed: the second second of the twenty-second minute of the twentieth hour of the twenty-second day of the second month, of the year twenty-twenty-two! As well as the date being a palindrome — something that reads the same forwards and backwards — on an vintage ‘80s LCD clock, the date and time could be written as an ambigram too — something that can be read upside down as well as the right way up:
When we hit 2022 02 22, our team was busy completing our second annual audit to certify to ISO/IEC 27701:2019, having been one of the first organizations in our industry to have achieved this new ISO privacy certification in 2021, and the first Internet performance & security company to be certified to it. And now Cloudflare has now been certified to a second international privacy standard related to the processing of personal data — ISO/IEC 27018:2019.1
ISO 27018 is a privacy extension to the widespread industry standards ISO/IEC 27001 and ISO/IEC 27002, which describe how to establish and run an Information Security Management System. ISO 27018 extends the standards into a code of practice for how any personal information should be protected when processed in a public cloud, such as Cloudflare’s.
What does ISO 27018 mean for Cloudflare customers?
Put simply, with Cloudflare’s certifications to both ISO 27701 and ISO 27018, customers can be assured that Cloudflare both has a privacy program that meets GDPR-aligned industry standards and also that Cloudflare protects the personal data processed in our network as part of that privacy program.
These certifications, in addition to the Data Processing Addendum (“DPA”) we make available to our customers, offer our customers multiple layers of assurance that any personal data that Cloudflare processes on their behalf will be handled in a way that meets the GDPR’s requirements.
The ISO 27018 standard contains enhancements to existing ISO 27002 controls and an additional set of 25 controls identified for organizations that are personal data processors. Controls are essentially a set of best practices that processors must meet in terms of data handling practices and transparency about those practices, protecting and encrypting the personal data processed, and handling data subject rights, among others. As an example, one of the ISO 27018 requirements is:
Where the organization is contracted to process personal data, that personal data may not be used for the purpose of marketing and advertising without establishing that prior consent was obtained from the appropriate data subject. Such consent shall not be a condition for receiving the service.
When Cloudflare acts as a data processor for our customers’ data, that data (and any personal data it may contain) belongs to our customers, not to us. Cloudflare does not track our customers’ end users for marketing or advertising purposes, and we never will. We even went beyond what the ISO control required and added this commitment to our customer DPA:
“... Cloudflare shall not use the Personal Data for the purposes of marketing or advertising…”
- 3.1(b), Cloudflare Data Processing Addendum
Cloudflare achieves ISO 27018:2019 Certification
For ISO 27018, Cloudflare was assessed by a third-party auditor, Schellman, between December 2021 and February 2022. Certifying to an ISO privacy standard is a multi-step process that includes an internal and an external audit, before finally being certified against the standard by the independent auditor. Cloudflare’s new single joint certificate, covering ISO 27001:2013, ISO 27018:2019, and ISO 27701:2019 is now available to download from the Cloudflare Dashboard.
C5:2020 – Cloud Computing Compliance Criteria Catalog
ISO 27018 isn’t all we’re announcing: as we blogged in February, Cloudflare has also been undergoing a separate independent audit for the Cloud Computing Compliance Criteria Catalog certification — also known as C5 — which was introduced by the German government’s Federal Office for Information Security (“BSI”) in 2016 and updated in 2020. C5 evaluates an organization’s security program against a standard of robust cloud security controls. Both German government agencies and private companies place a high level of importance on aligning their cloud computing requirements with these standards. Learn more about C5 here.
Today, we’re excited to announce that we have completed our independent audit and received our C5 attestation from our third-party auditors. The C5 attestation report is now available to download from the Cloudflare Dashboard.
And we’re not done yet…
When the European Union’s benchmark-setting General Data Protection Regulation (“GDPR”) was adopted four years ago this week, Article 40 encouraged:
“...the drawing up of codes of conduct intended to contribute to the proper application of this Regulation, taking account of the specific features of the various processing sectors and the specific needs of micro, small and medium-sized enterprises.”
The first code officially approved as GDPR-compliant by the EU one year ago this past weekend is ‘The EU Cloud Code of Conduct’. This code is designed to help cloud service providers demonstrate the protections they provide for the personal data they process on behalf of their customers. It covers all cloud service layers, and its compliance is overseen by accredited monitoring body SCOPE Europe. Initially, cloud service providers join as members of the code’s General Assembly, and then the second step is to undergo an audit to validate their adherence to the code.
Today, we are pleased to announce today that Cloudflare has joined the General Assembly of the EU Cloud Code of Conduct. We look forward to the second stage in this process, undertaking our audit and publicly affirming our compliance to the GDPR as a processor of personal data.
Customers may now download a copy of Cloudflare’s certifications and reports from the Cloudflare Dashboard; new customers may request these from your sales representative. For the latest information about our certifications and reports, please visit our Trust Hub.
1The International Organization for Standardization (“ISO”) is an international, nongovernmental organization made up of national standards bodies that develops and publishes a wide range of proprietary, industrial, and commercial standards.