C3 PLATFORMTM

Security

Security, confidentiality, integrity, and application availability are vital to the success of customer business operations. C3 meets these requirements by delivering a unified, cohesive product suite through a scalable and secure hosting model.

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C3 Operations & Security

A.1. Introduction

The C3 Platform™ and C3 Applications employ advanced analytics and machine learning at scale to deliver real-time or near real-time actionable insights for enterprise business imperatives.

C3 understands that the security, confidentiality, integrity, and availability of the C3 Platform™ and the C3 Applications are important to customers. C3 delivers a unified, cohesive suite of products through a scalable and secure hosting model:

  • C3 products are delivered as hosted PaaS and SaaS offerings deployed in secure Virtual Private Clouds. This provides system scalability and data security combined with low overall cost of ownership.
  • C3 implements a rigorous Cyber Security Program to protect critical systems and information assets, constantly monitoring and improving applications, systems, and processes to meet the growing demands and challenges of security.

Security of C3’s hosting operations and C3 Platform™ has been validated in production deployments for leading utility operators and large commercial and industrial organizations around the world.

The C3 Cyber Security Program is a multi-layered security approach that employs technical, physical, and administrative safeguards.

The C3 Cyber Security Program has been developed to comply with the applicable legal and regulatory requirements, including compliance with the NERC CIP smart grid cyber security standards. This program encompasses a comprehensive set of cyber security controls and business processes based on NIST best practices that align with the NERC CIP standards.

Physical Safeguards
  • Physical and Operational Security: C3 combines state-of-the-art data center facilities with industry best practices to ensure operational security. A detailed description of C3’s physical and operational security follows in Section A.2.
Technical Safeguards
  • Network Security: C3 provides Virtual Private Clouds accessible over robust network infrastructure to provide secure and reliable systems. A detailed description of C3’s network security follows in Section A.3.
  • Data Security: Data security is a fundamental requirement that is systematically addressed throughout the C3 Platform™. This includes access controls, encryption, user roles, and data retention/destruction A detailed description of C3’s data security follows in Section A.4.
  • Continuous Monitoring: C3 uses multiple, redundant, continuous monitoring systems application and data security. A detailed description of C3’s continuous monitoring follows in Section A.5.
  • Business Continuity: C3 backup, failover, and redundancy services ensure data availability and protect information from loss or destruction. A detailed description of C3’s business continuity measures follows in Section A.7. Business Continuity: C3 backup, failover, and redundancy services ensure data availability and protect information from loss or destruction. A detailed description of C3’s business continuity measures follows in Section A.7.
Administrative Safeguards
  • Secure Design and Engineering Principles: C3 follows best practice secure software development processes to incorporate security throughout the product development and release lifecycle. A detailed description of C3’s design and engineering methodologies follows in Section A.6.
  • Corporate Governance: Cyber security is a strategic priority for C3. C3 has implemented extensive corporate oversight to ensure its ongoing success. A detailed description of C3’s cyber security corporate governance follows in Section A.9.
  • Third-Party Attestations: C3 offers a variety of third-party attestations regarding cyber security processes and controls.
    • C3 undergoes regular testing by external security experts, including source code reviews, software vulnerability testing, and penetration testing.
    • C3 uses data centers that have been audited for the leading industry IT security standards, including SOC 1/SSAE 16/ISAE 3402 (formerly SAS 70 Type II), SOC 2, FISMA, DIACAP, FedRAMP, PCI DSS Level 1, ISO 27001, International Traffic in Arms Regulations (ITAR), and FIPS 140-2.
  • A detailed description of C3’s third-party attestations follows in Section A.7

A.2. Physical & Operational Security

C3’s customer systems infrastructure is hosted at well-established cloud data centers like Amazon AWS, Microsoft Azure and Google GPC in Northern Virginia, Oregon, and Dublin Ireland depending on data jurisdiction. These data centers represent that they provide best practice security and reliability features, including secure premises with video surveillance, power supply & backup, precision environmental controls, equipment monitoring, comprehensive security policies & controls, and third-party security compliance and attestation, as described below.

Secure premises – Facilities are nondescript and unmarked to help maintain a low profile. All visitors must pass through a security check-in before accessing the facility. Biometric scanning controls data center access, and access is available only to data center personnel and contractors who have a legitimate business need for such privileges. Authorized staff must pass two-factor authentication a minimum of two times to access data center floors. Data center access is logged and monitored. 24x7 onsite staff provide additional protection against unauthorized entry. CCTV camera monitoring is present at all data center locations. Audit logs for sensitive areas are maintained and reviewed regularly.

Power supply and backup – Multiple levels of built-in power redundancy provide a high level of availability. Generators and Uninterrupted Power Supply (UPS) provide backup power sources and prevent power spikes, surges, and brownouts. If a total utility power outage ever occurs, these power systems are designed to ensure that the data centers will continue to operate. The UPS power subsystem is N+1 redundant, with instantaneous failover if the primary UPS fails. If an extended utility power outage occurs, on-site generators can run indefinitely. All on-site generators are tested regularly.

Precision environment – Heating, ventilation, and air conditioning (HVAC) systems provide appropriate and consistent airflow, temperature, and humidity levels. Every data center's HVAC system is N+1 redundant. This ensures that a duplicate system immediately comes online should there be an HVAC system failure. Advanced fire suppression systems are designed to stop fires from spreading in the unlikely event one should occur.

Equipment monitoring – All electrical, mechanical, and life support systems and equipment are monitored to ensure that any equipment issues are immediately identified. Preventative maintenance is performed to maintain continuous operability of all equipment.

Third-party compliance and attestation – The data centers are designed and managed in alignment with security best practices and a variety of established IT standards, including SOC 1/SSAE 16/ISAE 3402 (formerly SAS 70 Type II), SOC 2, FISMA, DIACAP, FedRAMP, PCI DSS Level 1, ISO 27001, International Traffic in Arms Regulations (ITAR), and FIPS 140-2.

Policies – C3’s Executive Management has instituted a set of policies, procedures, and guidelines to ensure the security of the C3 Platformm™ and C3 Applications. These policies apply to all employees. In cases where additional policies and procedures have been called out, these additional policies and procedures apply to employees with access to designated customer projects with access to sensitive data.

Corporate security – C3 maintains stringent physical security at all offices. Each person with authorized access is provided an electronic key to gain entry and move within the facilities. All visitors are required to sign-in and to be escorted by authorized staff.

Background checks – Background checks, as permitted by law, are mandatory for all employees and contractors. These include, as permitted by law, criminal checks, education and employment verification, and reference checks. Drug testing may be performed for designated customer projects.

Proprietary information – All employees and contractors are required to sign a Proprietary Information Agreement as a condition of employment. All subcontractor agreements include rigorous confidentiality and non-disclosure clauses.

Security awareness program – All C3 employees are trained on C3's security policies upon initial hiring and on an annual basis.

Employee access – Formal procedures govern user accounts for all employees. They regulate user roles and access, as well as the ability to add, delete, and modify user accounts. The C3 Human Resources (HR) department provides an immediate alert to the C3 Operations team when an employee has had a change in functional role or has been terminated. C3 Operations then modifies or disables system/network/e-mail access as per the HR alerts within 60 minutes of notification. Privileged user accounts are controlled and reviewed every 60 days.

Asset management – An inventory is kept of all hardware, software, and intellectual property assets. This inventory documents permitted configurations, usage, and access, along with other applicable controls.

Workstation protection – Anti-virus software is installed on all Microsoft Windows workstations (with daily virus signature updates). Preventative controls, such as screen timeout (5 minutes of inactivity) and session timeouts (configured on a per application basis), are required to prevent unauthorized access to unattended systems. Confidential corporate information stored on workstations must be encrypted. Confidential information is not permitted on removable media.

Use of USB enabled removable storage media is enabled on a need-to-have basis. If business needs dictate the use of USB enabled removable storage media, technical security controls are put in place (company owned devices only, device encryption) to ensure sensitive data is secured on a USB device. For employees that have access to sensitive data, USB ports are disabled.

Audits – Multiple security audits are performed regularly, including daily review of user access logs, quarterly review of user access rights and asset policies.

A.3. Network Security

C3 applies security best practices to a state-of-the-art network infrastructure to provide a secure and reliable platform.

C3’s data centers maintain redundant relationships with multiple Internet Service Providers, and employ robust routing using the BGP4 networking protocol to allow network traffic to take the best path. All customer data in transit (network connections to C3) is securely transmitted using HTTPS (SSL/TLS) with 4096-bit RSA encryption.

The C3 network architecture is designed to maximize security, scalability, and reliability.

Network access to and from C3 customer system infrastructure is controlled by network devices (including firewalls), switching access control lists, and load balancing. These boundary devices employ rule sets, access control lists, and configurations to enforce and monitor the flow of information to the C3 servers.

Firewalls and ports – Multiple network devices provide traffic filtering services. The only open inbound ports and protocols are HTTP, HTTPS, and SMTP. All other ports and protocols are explicitly disabled, thereby preventing worms and other network-based attacks.

Bastion servers – Bastion servers provide secure connectivity services deployed within customer-dedicated Virtual Private Clouds. Bastion servers are configured with all unnecessary services, protocols, programs, and network ports disabled to minimize the risk of unauthorized users gaining privileged access to customer-dedicated Virtual Private Clouds. Additionally, Bastion hosts are configured with security groups to provide fine-grained ingress control.

Reverse proxies – Load balancers serve as reverse proxies, distributing system load while further protecting C3 application servers from direct access.

Two-factor authentication – Access to C3 servers requires use of a Virtual Private Network with multi-factor authentication and access monitoring.

Hardening standards – C3 follows the National Security Agency’s (NSA) recommended hardening standards for all deployed server instances. These hardening standards are applied at server instantiation and reviewed monthly.

OS upgrades and patches – Operating system patches are reviewed upon release. Depending on the assessed priority and risk, operating system patches and upgrades are scheduled for implementation in accordance with industry best practices.

Virtual Private Cloud – C3 offers customer-dedicated Virtual Private Clouds. Each Virtual Private Cloud is a private network subnet that isolates customer server instances from any other customer’s deployment. This provides uncompromising cyber security while enabling cost-effective system scalability.

Direct connect – C3 offers customers the options of Virtual Private Network (VPN) encrypted tunnels and private lines to connect to C3’s data centers, thereby ensuring secure transmission along with the option to completely bypass internet service providers (public internet) in the network path.

Development, staging and production environments – C3 implements independent development, staging, and production environments for all customer deployments, thereby further protecting the security and reliability of production systems.

C3 corporate segregation – C3’s internal corporate network is segregated from all customer systems, further restricting unnecessary access to production systems.

A.4. Data Security

C3 has implemented comprehensive defense-in-depth customer data security and protection, encompassing data access administrative controls, data encryption, user roles, and data retention / destruction.

Data access – Access to Customer Data is restricted to authorized personnel only, according to documented processes. Only those C3 personnel explicitly identified in an application implementation role have access to customer systems. For application implementation personnel, customer system access is promptly de-activated as soon as the implementation is complete and access is no longer necessary. Access to all servers is limited, logged, and tracked for auditing purposes.

Data security policies – Customer Data Handling and Secure Document Destruction policies are enforced for the management of all sensitive information. All C3 employees are trained on documented information security and privacy procedures. C3’s Cyber Security Team performs quarterly reviews of C3 personnel who have access to customer environments and systems, to track activity and validate access.

Data and environment separation – Each C3 customer has separate databases with distinct access controls. C3 implements independent development, staging and production environments for each customer system deployment. C3's internal corporate network is segregated from all customer environments.

Data Classification - All C3 employees and contractors have been educated on the C3 data classification policy and must apply these policies in their daily C3 business activities. Sensitive information is either Confidential or Restricted information. This data classification policy is applicable to all electronic information and paper documentation for which C3 is the custodian.

All electronic information managed by C3 must have a designated owner. Owners are responsible for assigning appropriate sensitivity classifications as generally described below, subject to adjustments based on specific customer’s data.

  • Restricted — This classification applies to the most sensitive confidential business information.
  • ePHI — This classification applies to "electronic protected health information," or ePHI according to The Health Insurance Portability and Accountability Act of 1996.
  • Confidential — This classification applies to less sensitive confidential business information.
  • Public —This classification applies to information that is not subject to confidentiality restrictions.

Data Owners are responsible for decisions about who will be permitted to gain access to information, and the uses to which this information will be put. C3 has policies and procedures in-place to ensure that appropriate controls are utilized in the storage, handling, distribution, and regular usage of electronic information as described in this document.

Data encryption – C3 implements enterprise class encryption to provide added data security. Customer Data at rest is encrypted using 256-bit SHA-2 encryption. Any Customer Data in motion is securely transmitted using HTTPS (SSL/TLS) with 4096-bit RSA encryption.

Data protection – C3 implements comprehensive data protection and recovery measures in accordance with the following established industry best practices. Data backups are performed on a nightly basis and are replicated to a designated backup C3 data center. The backup data center is geographically separated and independent from a customer's assigned primary and secondary C3 data centers. All ePHI backup is encrypted and backup data is transferred in a secure, encrypted manner using HTTPS (SSL/TLS) with 4096-bit RSA encryption, and is securely stored in encrypted form at a backup facility. To facilitate rapid data restoration, the primary backup method is an encrypted, hardware-level replication. Backups can be restored and end-user accessible within eight hours of process initiation. Backup data restoration is tested on a monthly basis. All backup activity, including transport, storage, and access, is logged and regularly audited to ensure proper handling.

Data destruction – C3 applies data destruction measures in accordance with established industry guidelines. Standard backup Customer Data retention is 30 days, after which the backup such data is permanently destroyed. C3’s Operations team permanently destroys all Customer Data at the end of the applicable contract, including then-existing customer databases and backup repositories. All Customer Data destruction is logged and regularly audited.

Role-based access – C3 Application access for end-users is controlled via user roles. These roles control security and access rights for standard users, super users, and administrators.

Application access segmentation – End-user application access can also be restricted based on data values. For example, customer end-users can be granted access to only the assets, accounts, or geographic regions that are necessary for their areas of responsibility.

Network IP access – Customer’s access to C3 Applications can be restricted to specific networks and locations (configurable via designated IP space whitelisting and/or blacklisting).

Single Sign On (SSO) – C3 enables customers to use their existing end-user authorization systems to manage access to the C3 Applications. C3 supports SSO integration with any version of LDAP or Active Directory that supports SAML.v2.

Login information protection – To prevent password guessing attacks, account access is automatically suspended after a configurable number of unsuccessful password entry attempts.

Configurable password parameters – Customer system administrators can configure the complexity, length, and expiration requirements of end-user application passwords to adhere to their existing corporate standards.

Configurable application session timeout – C3 Application session timeout can be configured on a per-customer basis, adhering to their existing corporate standards.

A.5. HOSTING OPERATIONS


C3 uses continuous monitoring methods to ensure C3 application and Customer Data security.

Application access logging – C3 tracks all C3 Application access, including failed authentication attempts, and keeps two years of historical records to support reporting and auditing requirements. All successful and unsuccessful access activities are recorded in the system and in application logs, along with username, IP address, action, and date/time of access. Every data change is logged in the system and in application logs.

Alerting – C3 is committed to frequent and transparent customer communication. The C3 Cyber Security Team monitors and alerts customers of suspicious activity including but not limited to multiple failed login attempts, abnormal usage patterns and large data access/downloads. C3 has a formal process to notify customers of a verified security breach, theft, or loss of data. High alert (Priority P1) incidents are responded to on a 24x7 basis, with all incidents tracked in a case management system.

A.6. SECURE DESIGN AND ENGINEERING

The C3 Platform™ is the software foundation that handles data management, multi-layered analysis, and data visualization capabilities for all C3 Applications. The C3 Platform™ has been specifically designed to process and analyze significant volumes of frequently updated data while maintaining high performance levels.

The C3 Platform™ architecture is comprised of multiple services with each handling a specific data management or analysis capability. All the services are modular, and have been architected to execute their respective capabilities intended to maximize security.

C3’s software development process follows the Open Web Application Security Project (OWASP) standards for building secure applications, including mandatory internal review by the C3 Cyber Security Team. The C3 software development cycle includes stringent code review, as well as integration and regression testing prior to release with internal and external testing tools to check for security vulnerabilities. Static code analysis tools are run as a part of the standard software build process, and all deployed software undergoes recurring penetration testing. All test results are shared with the C3 Engineering team and any detected issues are resolved prior to final product release.

To maintain security throughout the entire lifecycle of the C3 Platform™, security testing is performed regularly and systematically. Quarterly vulnerability scans are conducted. All third-party and open source components used in the C3 architecture are selected based on their stability and industry support, and are subject to the same security testing as any internally developed C3 code. All external components of the C3 architecture are kept reasonably current with validated software patches. All patches are reviewed and tested by the C3 Operations Team before deployment as part of C3’s standard change management process. All server instances are re-imaged with hardened and tested OS, software, network, and security versions prior to deployment.

Internal vulnerability and penetration testing – The C3 Cyber Security Team performs vulnerability and penetration testing for every new C3 Application version, using open-source and commercial testing tools. A version is not released until all identified vulnerabilities are corrected and the version successfully passes security testing.

Third-Party vulnerability testing – C3 engages third-party security experts to perform annual penetration testing and security audits. These testing cycles involve source code review, software vulnerability testing, and penetration testing. Any vulnerabilities identified in these testing cycles are immediately corrected, and C3 has consistently passed security audits.

A.7. THIRD PARTY CERTIFICATIONS AND ATTESTATIONS

The C3 Cyber Security Program has been developed to comply with applicable legal and regulatory requirements, including compliance with the NERC CIP smart grid cyber security standards. This program encompasses a comprehensive set of cyber security controls and business processes based on NIST best practices that align with the NERC CIP (versions 3 and 4) standards.

To objectively verify adherence to these processes, C3 works with industry auditors that bring additional levels of scrutiny to the security of C3 Applications and the processes that govern how they are developed, tested, deployed, and supported. C3 has successfully completed multiple third-party security tests, including source code reviews, software vulnerability testing, and penetration testing.

For SaaS and PaaS offerings, C3 uses data centers that are regularly audited for a variety of established IT security standards, including:

  • SOC 1/SSAE 16/ISAE 3402 (formerly SAS 70 Type II)
  • SOC 2
  • FISMA
  • DIACAP
  • FedRAMP
  • PCI DSS Level 1
  • ISO 27001
  • International Traffic in Arms Regulations (ITAR)
  • FIPS 140-2

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