Statement of Applicability

Every control, accounted for.

entityOS management attests to the applicability and implementation of every Annex A control of ISO/IEC 27001:2022, and the cloud-specific controls of ISO/IEC 27017:2026, for the confidentiality, integrity and availability of customer data on the entityOS cloud service.

ISO 27001:2022ISO 27002:2022ISO 27017:2026Version 3.0
About this SOA

The standards, and the attestation.

This Statement of Applicability records, for each control, whether it applies to entityOS and how it is implemented — as required by ISO/IEC 27001:2022, clause 6.1.3(d).

ISO/IEC 27001

Third edition · 2022-10

The ISMS requirements standard. Annex A lists the reference controls this SOA responds to.

ISO/IEC 27002

2022

The control set behind Annex A — 93 controls across four themes: organisational, people, physical and technological.

ISO/IEC 27017

Second edition · 2026-07

Cloud services controls, rebased on ISO/IEC 27002:2022, adding four standalone cloud-specific controls.

entityOS management attests that the following controls are in place in regard to the risks relating to the confidentiality, integrity and availability of customer data stored on the entityOS cloud service using isolated / dedicated services.

Two measures are central to how we control risk: the automation of the platform using machines and the minimal use of humans in delivering the service; and, after 25+ years of development, making no functional changes to the platform — so no new internally-created risks are introduced. The only changes are security-maintenance measures against externally-created risks, shared with Amazon Web Services.

Mark ByersChief Risk Officer · ibCom Pty Ltd (entityOS)
97
Controls assessed
96
Applicable
1
Excluded
4
Cloud controls (27017)
Shared responsibility. Under ISO/IEC 27017:2026, controls are shared between entityOS as a cloud service provider (CSP), its customers as cloud service customers (CSCs), and AWS as entityOS’s upstream provider. entityOS operates the fixed platform kernel; customers govern their own user-mode applications and data configuration.
97 shown
Theme A · organisational

organisational controls

37 controls — governance, policy, people-facing process, supplier and cloud, incident and compliance.

#ControlApplicabilityHow entityOS applies it
5.1Policies for information securityApplicableInformation security and topic-specific policies are defined by the CRO, form part of the employment contract, and are reviewed and re-distributed on a regular cycle.
5.2Information security roles and responsibilitiesApplicableThe Chief Risk Officer (CRO) owns and allocates all information-security roles, and communicates them to customers, service providers and suppliers as required.
5.3Segregation of dutiesApplicableOnly operational personnel can access data; conflicting duties are segregated by role under the CRO.
5.4Management responsibilitiesApplicableManagement requires all personnel to apply information security in line with policy — it is a core value and a condition of employment.
5.5Contact with authoritiesApplicableThe CRO maintains contact with relevant authorities and informs customers of the geographic location of their data.
5.6Contact with special interest groupsApplicableThe CRO maintains contact with specialist security forums and subscribes to daily threat-intelligence feeds.
5.7Threat intelligenceApplicableThreat intelligence is drawn from daily security feeds, AWS advisories and the real-time testing service, and feeds patching and WAF control-set updates.
5.8Information security in project managementApplicableAny project that could change the platform treats information security as a first-class concern from design onward.
5.9Inventory of information and other associated assetsApplicableCore customer-data assets (including derived data) are managed contractually within AWS; assets used to access operations are registered and owned.
5.10Acceptable use of information and other associated assetsApplicableAcceptable-use rules link each asset to the employee's role and are documented.
5.11Return of assetsApplicableOn role change or termination, assets revert immediately to the direct responsibility of the CRO.
5.12Classification of informationApplicableCustomer data is classified and handled on a strict need-to-know basis; the model delivers only encoded data to the UI layer.
5.13Labelling of informationApplicableInformation is labelled per handling procedures; tenancy context is enforced by the data-store.
5.14Information transferApplicableAll transfer is over HTTPS (2048/256 SSL with perfect forward secrecy); no customer data is stored at remote-working sites.
5.15Access controlApplicableAccess is least-privilege and role-based; each of the 700+ platform methods can be functionally controlled, with optional IP allowlisting and MFA.
5.16Identity managementApplicableThe identity life cycle is managed; being employed by ibCom does not by itself grant access to customer data.
5.17Authentication informationApplicableAuthentication information is managed by process; TOTP/MFA is available on all user access.
5.18Access rightsApplicableAccess rights are provisioned, reviewed and removed under the CRO, with periodic access reviews.
5.19Information security in supplier relationshipsApplicableSupplier risk is managed; the principal supplier is AWS, whose certifications are relied upon and monitored.
5.20Addressing information security within supplier agreementsApplicableSecurity requirements are established in agreements; AWS obligations are covered contractually.
5.21Managing information security in the ICT supply chainApplicableICT supply-chain risk is minimised by a fixed, in-house kernel on AWS with few third-party components.
5.22Monitoring, review and change management of supplier servicesApplicableAWS service changes and security practices are monitored and reviewed.
5.23Information security for use of cloud servicesApplicableAs both a CSP and a CSC of AWS, entityOS has defined processes for acquisition, use, management and exit of the cloud services it consumes and provides.
5.24Information security incident management planning and preparationApplicableAn incident-management process is defined, including roles, responsibilities and customer-notification obligations.
5.25Assessment and decision on information security eventsApplicableEvents from the real-time testing service and monitoring are assessed and categorised.
5.26Response to information security incidentsApplicableIncidents are handled per documented procedures; reported issues are fixed within 24 hours (maximum).
5.27Learning from information security incidentsApplicableLessons feed the plan-do-check-act cycle and the automated testing service.
5.28Collection of evidenceApplicableLogging and the testing service preserve evidence; procedures cover its identification and preservation.
5.29Information security during disruptionApplicableA real-time duplicate runs in warm mode so security is maintained during disruption.
5.30ICT readiness for business continuityApplicableICT continuity is planned, maintained and tested: real-time data-store duplication, warm standby, and daily test-restores via AWS RDS against defined RTO/RPO.
5.31Legal, statutory, regulatory and contractual requirementsApplicableLegal, regulatory and contractual requirements (incl. the Australian Privacy Act and data location) are identified and kept current by the CRO.
5.32Intellectual property rightsApplicableIP rights are respected; customer data and derived data remain the customer's property and are never shared.
5.33Protection of recordsApplicableRecords are protected from loss, falsification and unauthorised access or release.
5.34Privacy and protection of PIIApplicablePrivacy and PII obligations are identified and met per applicable law; data is encrypted at rest and isolated per tenant.
5.35Independent review of information securityApplicableInformation security is reviewed independently through external ISO 27001/17 audit and surveillance.
5.36Compliance with policies, rules and standards for information securityApplicableCompliance is reviewed regularly under the plan-do-check-act ISMS.
5.37Documented operating proceduresApplicableProcedures for critical operations (virtual-resource changes, key management, backup/restore, service termination) are documented.
Theme B · People

People controls

8 controls — the human layer, where entityOS applies its “least number of humans” principle.

#ControlApplicabilityHow entityOS applies it
6.1ScreeningApplicablePersonnel with data access must have at least one year with ibCom or an equivalent proven provider; the first control is using very few such people.
6.2Terms and conditions of employmentApplicableInformation security is at the heart of the employment contract, including post-employment obligations.
6.3Information security awareness, education and trainingApplicableAll personnel are tertiary-qualified with extensive experience and are continually trained in protecting customer data, including derived data.
6.4Disciplinary processApplicableAny information-security breach by an employee results in immediate termination.
6.5Responsibilities after termination or change of employmentApplicableAccess is revoked immediately and post-employment obligations are re-communicated.
6.6Confidentiality or non-disclosure agreementsApplicableAll personnel are bound by confidentiality / non-disclosure agreements.
6.7Remote workingApplicableWork is remote by design; no customer data is stored at remote sites, and AWS access requires MFA and/or IP restriction.
6.8Information security event reportingApplicablePersonnel and the public can report events (including via the reward program); the testing service raises real-time alerts.
Theme C · Physical

Physical controls

14 controls — largely inherited from AWS data centres under the shared-responsibility model.

#ControlApplicabilityHow entityOS applies it
7.1Physical security perimetersApplicableDelivered by AWS data centres (Sydney by default) under their certified physical-security programme.
7.2Physical entryApplicableAWS data-centre entry controls apply; ibCom personnel do not physically access infrastructure.
7.3Securing offices, rooms and facilitiesApplicableNo customer data is held in ibCom offices; facilities used to access operations are controlled.
7.4Physical security monitoringApplicableContinuous physical monitoring is provided by AWS data centres.
7.5Protecting against physical and environmental threatsApplicableAWS environmental protections (power, fire, flood and similar) apply.
7.6Working in secure areasApplicableAWS-controlled; the least-humans model means no ibCom physical presence in the infrastructure.
7.7Clear desk and clear screenApplicableEnforced for operations personnel; no local storage of customer data.
7.8Equipment siting and protectionApplicableInfrastructure is sited and protected by AWS; operations endpoints are hardened.
7.9Security of assets off-premisesApplicableOperations endpoints are hardened and MFA/IP-restricted; no customer data is stored off-premises.
7.10Storage mediaApplicableMedia life cycle is handled by AWS; no removable media holds customer data.
7.11Supporting utilitiesApplicablePower and utility resilience are provided by AWS.
7.12Cabling securityApplicableProvided within AWS data centres.
7.13Equipment maintenanceApplicableInfrastructure maintenance is performed by AWS; operations endpoints are maintained and patched.
7.14Secure disposal or re-use of equipmentApplicableSecure disposal is handled by AWS; customer data can be cryptographically cleansed by the owner via the API.
Theme D · Technological

Technological controls

34 controls — the technical core: access, cryptography, logging, testing and network security.

#ControlApplicabilityHow entityOS applies it
8.1User endpoint devicesApplicableOperations endpoints are hardened and monitored, MFA/IP-restricted, and run only approved software.
8.2Privileged access rightsApplicablePrivileged access is restricted to a few long-tenured, qualified operations personnel and managed by the CRO with MFA.
8.3Information access restrictionApplicableAccess to services, service functions and customer data is restricted by policy and enforced by the model.
8.4Access to source codeApplicableRead/write access to the platform source is tightly managed; the kernel is fixed and rarely changes.
8.5Secure authenticationApplicableSecure authentication (TOTP/MFA, perfect forward secrecy) is implemented.
8.6Capacity managementApplicableResource usage is monitored and scaled on AWS; the testing service checks availability.
8.7Protection against malwareApplicableEndpoints run hardened, ad-blocking browsers with restricted execution and no Office/macros; AWS WAF sits at the edge.
8.8Management of technical vulnerabilitiesApplicableVulnerability scanning is continuous, patches are applied within 24 hours, and the WAF uses the latest control sets.
8.9Configuration managementApplicableSecure configuration of virtual resources is defined and continuously monitored; the fixed kernel keeps drift minimal.
8.10Information deletionApplicableCustomer data can be deleted by the owner at any time via the standard API; deletion on termination is documented.
8.11Data maskingApplicableMasking / encryption of sensitive fields is available to applications via the cryptography helper methods.
8.12Data leakage preventionApplicableLayering, tenant isolation and encoded model output limit leakage; monitoring detects abnormal transfer.
8.13Information backupApplicableReal-time data-store duplication plus daily full backups and test-restores via AWS RDS.
8.14Redundancy of information processing facilitiesApplicableA warm-mode duplicate service is maintained and continuously tested for ready-to-run status.
8.15LoggingApplicableActivities, exceptions and faults are logged; the testing service verifies that logging is occurring.
8.16Monitoring activitiesApplicableNetworks, systems and applications are monitored for anomalies; the real-time testing service alerts on any exception.
8.17Clock synchronizationApplicableSystem clocks are synchronised to approved time sources.
8.18Use of privileged utility programsApplicablePrivileged utility, CLI and API use is restricted to authorised personnel under authentication and authorisation controls.
8.19Installation of software on operational systemsApplicableSoftware installation on operational systems is controlled; application control restricts executables.
8.20Network securityApplicableOne protocol (HTTPS) over ports 80/443, behind AWS Elastic Load Balancers and WAF; virtual and physical network policies are aligned.
8.21Security of network servicesApplicableNetwork-service security levels are identified, implemented and monitored.
8.22Segregation of networksApplicableTenants and services are segregated; virtual networks are configured to policy.
8.23Web filteringApplicableOperations browsers apply ad-blocking / web filtering; servers carry no browser.
8.24Use of cryptographyApplicable2048/256 SSL with perfect forward secrecy in transit and encryption at rest, plus customer-controlled crypto helpers (AES, SHA-256/512, RSA).
8.25Secure development life cycleApplicableSecure-development rules apply; the kernel changes only for security maintenance, shared with AWS.
8.26Application security requirementsApplicableSecurity requirements are specified for any platform change; customer apps run in the isolated user-mode layer.
8.27Secure system architecture and engineering principlesApplicableSeparation of concerns (MVC), least-humans and closed-internet principles are applied by design.
8.28Secure codingApplicableSecure-coding principles (CWE/SANS Top 25, OWASP) guide platform development; the model always delivers encoded output.
8.29Security testing in development and acceptanceApplicableSecurity testing is embedded; the OWASP-based real-time testing service runs continuously.
8.30Outsourced developmentNot applicableNo outsourced development — the platform is developed and maintained in-house. Customer application development occurs in the isolated user-mode layer and cannot affect the kernel.
8.31Separation of development, test and production environmentsApplicableDevelopment, test and production environments are separated and secured.
8.32Change managementApplicablePlatform changes follow change-management procedures; customers are notified of changes that could affect them.
8.33Test informationApplicableTest information is selected, protected and managed; production customer data is not used for testing.
8.34Protection of information systems during audit and testingApplicableAudit and assurance testing is planned and agreed to protect operational systems.
Cloud ExtendedISO/IEC 27017:2026

Four cloud-specific controls.

The 2026 edition retires the old seven CLD controls and defines four standalone cloud controls, layered on the ISO/IEC 27002:2022 set above.

#ControlApplicabilityHow entityOS applies it
5.38CLD — Shared roles and responsibilities within a cloud computing environmentApplicableShared security roles between entityOS (as CSP), its customers (CSCs) and AWS are allocated, documented and communicated: entityOS operates the platform kernel; customers govern their user-mode apps and data configuration.
5.39CLD — Agreement on the roles and responsibilities of the cloud service partnerApplicableWhere a cloud service partner (CSN) is involved, roles and responsibilities are defined and agreed consistently with the shared CSC/CSP allocation; AWS is the principal upstream provider.
8.35CLD — Segregation in virtual computing environmentsApplicableTenants are logically segregated in the multi-tenant environment (isolated since 2000); the data-store releases data only in tenancy context, and CSP administration is separated from tenant resources.
8.36CLD — Detection and prevention of unauthorized use of cloud servicesApplicableUse of the service is monitored for anomalies and unauthorised access or transfer; the real-time testing service and logging detect deviations and raise alerts.
The one exclusion

Documented, and justified.

8.30 Outsourced development — not applicable. The platform is developed and maintained in-house; there is no outsourced development. Customer application development happens in the isolated user-mode layer and cannot affect the kernel. Every other Annex A and ISO 27017:2026 control is applicable and implemented.
This SOA (v3.0) aligns entityOS to ISO/IEC 27001:2022 and ISO/IEC 27017:2026. The current certificate references SOA v2.1 against the 2013/2015 editions; external certification transition to the 2022/2026 editions follows.