Data Security Policy

Effective Starting: June 17, 2020

PagerDuty, Inc. (“PagerDuty”) and Customer agree that this PagerDuty Data Security Policy (“Data Security Policy”) is hereby incorporated into and made a part of the written agreement between them that references this policy (the “Agreement”). Any capitalized terms used but not defined herein shall have the meaning described in the Agreement. In the event of any conflict between the terms of the Agreement and this Data Security Policy, this Data Security Policy shall govern with respect to the security measures in place for Customer Personal Data.  The term Customer Personal Data as used herein includes Contact Information.

1. Data Protection
   The Service uses industry-accepted encryption methods and products to protect Customer Personal Data and communications during transmissions between a customer’s network and the Service including encryption for data in transit over public networks and encryption for data at rest.
   1. Encryption in Transit
      All data transferred over public networks is encrypted via Secure Sockets Layer (SSL) and HTTPS/Transport Layer Security (TLS).
   2. Encryption at Rest
      Data at rest is encrypted using at least AES-256 or higher levels of encryption. PagerDuty shall not make copies of Customer Personal Data save as reasonably necessary to provide the Service and for backup purposes.
2. Data Deletion
   Upon termination of the Service for which PagerDuty is processing Customer Personal Data, PagerDuty shall, upon Customer’s request and subject to the limitations described in the Agreement, delete Customer Personal Data in accordance with the procedures and timeframes specified in the Agreement.
3. Access Control
   PagerDuty follow the “Principle of Least Privilege”, with the intent of reducing access and only allowing employees access to the tools, systems, and data they need to perform their job. Access to production systems are role-based, centralized, auditable, and regularly reviewed. PagerDuty will take reasonable steps to ensure that no person shall be appointed by PagerDuty to process Customer Personal Data unless that person:

   (a) is competent and qualified to perform the specific tasks assigned by PagerDuty;

   (b) has been authorized by PagerDuty; and

   (c) has been instructed by PagerDuty in the requirements relevant to the performance of the obligations of PagerDuty, in particular the limited purpose of the data processing.

4. Asset Management
   All PagerDuty assets are tracked and managed within a central repository.  All corporate laptops are full disk encrypted and wiped per industry standards when decommissioned.
   All infrastructure equipment housing Customer Personal Data resides within certified third-party data centers within AWS.  AWS currently uses the techniques detailed in NIST 800-88 (“Guidelines for Media Sanitization”) as part of the decommissioning process.
5. Passwords
   PagerDuty requires industry best practices around password requirements and storage.  Furthermore, we require Single Sign On (“SSO”) with multi-factor authentication requirements internally, as well as an option to our customers who wish to use SSO.
6. Change Management
   All changes to PagerDuty software follow PagerDuty’s change management process and require testing and approval prior to release to production.
7. Business Continuity and Disaster Recovery
   PagerDuty will ensure that the systems where Customer Personal Data is stored have a disaster recovery plan that addresses geographic availability, multiple site availability, and replication of critical systems and data. PagerDuty will ensure that its third-party data center has adequate Disaster Recovery plans in place and that they are tested annually. All networking components, load balancers, web servers and application servers that are part of the PagerDuty platform are configured in a redundant configuration. All Customer Personal Data is stored on a primary database server that is clustered with a backup database server for redundancy. All Customer Personal Data is automatically backed up every six hours. PagerDuty performs regular recovery testing.
8. Incident Management and Breach Notification
   PagerDuty maintains security incident management policies and procedures. PagerDuty will promptly notify Customer in the event PagerDuty becomes aware of an actual or reasonably suspected unauthorized disclosure of Customer Personal Data.
9. Risk Management 
   Our approach to enterprise risk management at PagerDuty has multiple layers, designed to focus on how we address risk as part of ongoing business operations throughout the year, not just as a point-in-time exercise on an annual basis.  PagerDuty maintains enterprise and cybersecurity risk assessment procedures, including annual risk assessments.
10. Security Training
    All new PagerDuty employees and contractors attend security training during the on-boarding process.  Additionally, all employees and contractors are required to take annual information security awareness training.  Training is tracked and monitored for compliance.
11. Third-Party Audit and Compliance 
    PagerDuty undergoes annual SOC 2 Type 2 audits, performed by an external third-party.  A copy of the report is available under NDA (defined below) upon Customer request.
12. Threat and Vulnerability Management
    PagerDuty uses several sources and tools for identifying, tracking, responding to, and remediating vulnerabilities. We subscribe to all relevant security mailing lists for our operating systems, datastores, load balancer, web frameworks, languages, as well as to industry and government mailing lists.
    1. Vulnerability Management and Penetration Testing
       We perform regular and continuous scans of our systems to identify vulnerabilities.  PagerDuty performs annual penetration tests performed by a third-party.  Reports are available under NDA upon Customer request.
    2. Patch Management
       Patches and upgrades are automatically applied when a system is rebooted, or deployed fleet wide via our configuration management software. Patches are applied based on the severity level of the vulnerability according to our patch management guidelines.
13. General Controls
    PagerDuty will implement, or be responsible for its Sub-processors’ implementation of, measures designed to:
    (a) deny unauthorized person’s access to data-processing equipment used for processing Customer Personal Data (equipment access control);
    (b)   prevent the unauthorized reading, copying, modification or removal of data media containing Customer Personal Data (data media control);
    (c) prevent unauthorized inspection, modification or deletion of stored Customer Personal Data (storage control);
    (d) prevent the use of automated data-processing systems by unauthorized persons using data communication equipment used to process Customer Personal Data (user control);
    (e) limit access to Customer Personal Data by persons authorized to use an automated data-processing system to the scope and duration of their access authorization (data access control);
    (f) enable verification of the individuals to whom Customer Personal Data has been transmitted or made available using data communication equipment (communication control);
    (g) enable verification of which individuals input Customer Personal Data into automated data-processing systems and when (input control);
    (h) prevent the unauthorized reading, copying, modification or deletion of Customer Personal Data during transfers of that data or during transportation of data media (transport control);
    (i) enable restoration of installed systems used to process Customer Personal Data in case of interruption (recovery);
    (j) ensure that the functions of the system used to process Customer Personal Data perform, that the appearance of faults in the functions is reported (reliability) and prevent stored Customer Personal Data from corruption by means of a malfunctioning of the system (integrity).
14. Logging and Monitoring
    PagerDuty shall ensure that all PagerDuty systems used to store Customer Personal Data, including firewalls, routers, network switches and operating systems, log information to their respective system log facility or a centralized syslog server (for network systems).
15. Intrusion Detection
    PagerDuty, or an authorized third party, will monitor the Service for unauthorized intrusions using network-based and log-based intrusion detection mechanisms.
16. Physical Security.
    PagerDuty’s third-party production data centers have an access system that controls access to the data center. This system permits only authorized personnel to have access to secure areas. The facility is designed to withstand adverse weather and other reasonably predictable natural conditions, is secured by around-the-clock guards, biometric access screening and escort-controlled access, and is also supported by on-site back-up generators in the event of a power failure.
17. Human Resource Security
    1. Employee Handbook
       All PagerDuty employees must read and agree to the company policies, including Code of Business Conduct and Ethics outlined in the PagerDuty Employee Handbook.
    2. Acceptable Use Policy (AUP)
       Our Acceptable Use Policy outlines requirements around:
       • Hardware, Software, Mobile Device, e-mail, and Network Use;
       • Social Media; and
       • Data Classification, Handling, and Ownership
    3. Non-Disclosure Agreement (NDA)
       All employees and contractors must sign a Non-Disclosure Agreement or similar obligations of confidentiality prior to employment (“NDA”). Third-party services must sign an NDA before use.