Hetzner

1 Vendor Overview

Service: Cloud infrastructure and S3-compatible object storage Primary Use: Google Meet recording storage, database backups, file archival Data Classification: Sensitive customer information (client meeting recordings) Contract Status: Enterprise cloud hosting with GDPR DPA Risk Level: High (stores client meeting recordings and sensitive data)

2 Services Utilized

S3-Compatible Storage: Client meeting recordings and transcripts
Cloud Servers: Database hosting and backup infrastructure
Network Infrastructure: European data center presence
Backup Services: Automated client data archival

3 Data Protection Compliance

3.1 Regulation S-P Compliance

Status: ⚠️ REQUIRES VERIFICATION

Required Documentation: - [ ] Data Processing Agreement: Enterprise DPA with incident notification requirements - [ ] Security Certifications: ISO 27001 or equivalent verification - [ ] Breach Notification: 72-hour notification guarantee to ECIC - [ ] Audit Rights: Annual security assessment access

3.2 Green Energy & Sustainability

Status: ✅ GREEN ENERGY POWERED - Renewable Energy: 100% green energy for all data centers - Environmental Commitment: Carbon-neutral operations and cooling systems - Sustainability Focus: European data centers powered by renewable sources - Green Certifications: Verified sustainable energy sourcing

Current Gaps: - Incident response integration not yet documented - Client meeting recording retention policies need formalization - Breach notification procedures require testing

3.3 Utah Consumer Privacy Act (UCPA)

Status: ⚠️ REQUIRES VERIFICATION

Required Capabilities: - [ ] Data Access: Client ability to access stored recordings - [ ] Data Deletion: Secure deletion of client meeting data - [ ] Data Portability: Export capabilities for client recordings - [ ] Processing Limitation: Ability to restrict data processing

4 Critical Data Flows

4.1 Client Meeting Recordings

High-Risk Data Processing:

Google Meet Recording → Hetzner S3 Storage → Transcription Processing
                                          → Long-term Archive

Data Sensitivity: - Personal Information: Client names, voices, financial discussions - Investment Details: Portfolio strategies, account information - Confidential Communications: Advisory conversations protected by privilege

4.2 Retention and Access

Storage Duration: 7 years minimum per SEC Rule 204-2
Access Controls: Encrypted storage with access logging
Deletion Procedures: Secure deletion after retention period
Client Rights: Access and deletion requests per privacy regulations

5 Incident Response Integration

5.1 Breach Notification Requirements

Hetzner → ECIC: 72 hours maximum (REQUIRED - not yet verified) ECIC → Clients: 30 days per Regulation S-P requirements

High-Priority Implementation Needed: 1. Security Incident Contacts: Establish direct communication channels 2. Automated Monitoring: Configure alerts for unauthorized access 3. Client Impact Assessment: Procedures for evaluating recording breaches 4. Notification Templates: Pre-approved client communication materials

5.2 Required Contact Information

Security Incidents: [Needs verification - likely security@hetzner.com]
DPA Compliance: [Needs verification - likely privacy@hetzner.com]
Account Management: [Establish dedicated enterprise contact]
24/7 Support: [Verify availability for incident response]

6 Compliance Action Items

6.1 Immediate Actions Required (Week 1)

Security Assessment: Conduct vendor security questionnaire
DPA Negotiation: Establish data processing agreement with incident notification
Access Audit: Review current permissions and access controls
Backup Verification: Test client recording retrieval and integrity

6.2 Week 2-4 Implementation

Incident Response Testing: Simulate breach notification procedures
Client Notification Procedures: Draft and approve breach communication templates
Monitoring Setup: Configure security alerts and access logging
Documentation: Complete vendor risk assessment and mitigation plan

7 Risk Assessment

7.1 High-Risk Factors

Sensitive Data Storage: Client meeting recordings contain privileged information
European Infrastructure: GDPR compliance required alongside US regulations
Long-term Retention: 7-year storage requirements increase exposure window
Access Management: Multiple users require recordings for transcription/analysis

7.2 Critical Mitigation Strategies

Encryption at Rest: All client recordings encrypted with ECIC-controlled keys
Access Logging: Complete audit trail of who accesses client recordings
Geographic Controls: Ensure data remains within approved jurisdictions
Secure Deletion: Verified destruction after retention period expires

8 Vendor Due Diligence Requirements

8.1 Security Verification Needed

ISO 27001 Certification: Verify current certification status
Penetration Testing: Review recent security assessments
Compliance Reports: SOC 2 or equivalent audit results
Insurance Coverage: Cyber liability and data breach insurance verification

8.2 Contract Requirements

Liability Limits: Adequate coverage for client data breaches
Indemnification: Protection for regulatory violations
Termination Rights: Ability to terminate for security failures
Data Return: Secure data return/destruction upon contract termination

9 Regulatory Compliance Status

9.1 Regulation S-P Requirements

❌ INCOMPLETE - Requires immediate attention

Missing Elements: - Incident response program integration - 30-day client notification procedures - Vendor oversight documentation - Security control verification

9.2 Utah Consumer Privacy Act

❌ INCOMPLETE - Requires verification

Missing Elements: - Consumer rights facilitation - Data processing limitation capabilities - Opt-out mechanisms - Privacy policy disclosure accuracy

10 Recommended Actions

10.1 Priority 1: Immediate Compliance

Vendor Security Questionnaire: Complete within 48 hours
DPA Negotiation: Establish incident notification requirements
Access Review: Audit all users with recording access
Risk Assessment: Complete formal vendor risk evaluation

10.2 Priority 2: Ongoing Monitoring

Quarterly Security Reviews: Regular vendor performance assessment
Annual Certification Verification: Maintain current security certifications
Incident Response Testing: Annual breach notification drills
Client Rights Facilitation: Establish procedures for privacy requests

CRITICAL NOTE: This vendor relationship requires immediate compliance attention due to high-risk data processing and current gaps in Regulation S-P requirements.