Data Protection Policy
The Data Protection Policy ("DPP") governs the receipt, storage, usage, transfer, and disposal of Information, including the data vended and retrieved through the Amazon Services API (including the Marketplace Web Service API). This policy is applicable to all systems that store, process, or otherwise handle data vended and retrieved from the Amazon Services API. This Policy supplements the Amazon Services API Developer Agreement and the Acceptable Use Policy. Failure to comply with this DPP may result in suspension or termination of Amazon Services API access in accordance with the Amazon Services API Developer Agreement.
1. General Security Requirements
Consistent with industry-leading security, Developers will maintain physical, administrative, and technical safeguards, and other security measures (i) to maintain the security and confidentiality of Information accessed, collected, used, stored, or transmitted by a Developer, and (ii) to protect that Information from known or reasonably anticipated threats or hazards to its security and integrity, accidental loss, alteration, disclosure, and all other unlawful forms of processing. Without limitation, the Developer will comply with the following requirements:
1.1 Network Protection. Developers must implement network protection
controls including network firewalls and network access control lists to deny access to
unauthorized IP addresses. Developers must implement network segmentation, intrusion
detection and prevention mechanisms (including defence in depth methods to complement a
firewall’s rulesets, and using IDS and/or IPS signature pattern-based mechanisms to identify and
prevent malicious behaviour transiting the network), and anti-virus and anti-malware tools
periodically (at least monthly). Developers must restrict systems access only to approved internal
employees who have coding and development responsibilities, and who have previously completed
data protection and IT security awareness trainings (“Approved Users”). Developers must maintain
secure coding practices, and conduct data protection and IT security awareness trainings for
Approved Users on at least an annual basis.
1.2 Access
Management. Developers must establish a formal user access registration
process to assign access rights for all user types and services by ensuring that a unique ID is
assigned to each person with computer access to Information. Developers must not create or use
generic, shared, or default login credentials or user accounts and prevent user accounts from
being shared. Developers must implement baselining mechanisms to ensure that at all times only
the required user accounts access Information. Developers must restrict employees and
contractors from storing Information on personal devices. Developers will maintain and enforce
"account lockout" by detecting anomalous usage patterns and log-in attempts, and disabling
accounts with access to Information. Developers must review the list of people and services with
access to Information at least quarterly. Developers must ensure that access is disabled and/or
removed within 24 hours for terminated employees.
1.3 Least Privilege
Principle. Developers must implement fine-grained access control mechanisms to
allow granting rights to any party using the Application and the Application's authorized
operators following the principle of least privilege. Access to Information must be granted on a
"need-to-know" basis.
1.4 Credential Management. Developers
must establish minimum password requirements for personnel and systems with access to
Information. Password requirements must be a minimum of twelve (12) characters, not include any
part of the user’s name, mix of upper-case letters, lower-case letters, numbers, and special
characters, including minimum requirements for each. Developers must establish a minimum
password age of 1-day and a maximum 365-day password expiration for all users. Developers must
ensure that Multi-Factor Authentication (MFA) is required for all user accounts. Developers must
ensure that API keys provided by Amazon are encrypted and only required employees have access to
them.
1.5 Encryption in Transit. Developers must encrypt all
Information in transit with secure protocols such as TLS 1.2+, SFTP, and SSH-2. Developers must
enforce this security control on all applicable internal and external endpoints. Developers must
use data message-level encryption where channel encryption (e.g., using TLS) terminates in
untrusted multi-tenant hardware (e.g., untrusted proxies).
1.6 Risk
Management and Incident Response Plan. Developers must have a risk assessment and
management process that is reviewed by the Developer's senior management annually, which
includes, but is not limited to, assessment of potential threats and vulnerabilities as well as
likelihood and impact in order to track known risks. Developers must create and maintain a plan
and/or runbook to detect and handle Security Incidents. Such plans must identify the incident
response roles and responsibilities, define incident types that may affect Amazon, define
incident response procedures for defined incident types, and define an escalation path and
procedures to escalate Security Incidents to Amazon. Developers must review and verify the plan
every six (6) months and after any major infrastructure or system change, including changes to
the system, controls, operational environments, risk levels, and supply chain. Developers must
notify Amazon (via email to security@amazon.com)
within 24 hours of detecting a Security Incident. It is the Developer’s sole responsibility to
inform relevant government or regulatory agencies as required by applicable local laws.
Developers must investigate each Security Incident, and document the incident description,
remediation actions, and associated corrective process/system controls implemented to prevent
future recurrence. Developers must maintain the chain of custody for all evidences or records
collected, and such documentation must be made available to Amazon upon request (if applicable).
If a Security Incident has occurred, Developers cannot represent or speak on behalf of Amazon to
any regulatory authority or customers unless Amazon specifically requests in writing that the
Developer do so.
1.7 Request for Deletion. Developers must
permanently and securely delete Information upon and in accordance with Amazon's notice
requiring deletion within 30 days of Amazon’s requests unless the data is necessary to meet
legal requirements, including tax or regulatory requirements. Secure deletion must occur in
accordance with industry-standard sanitization processes such as NIST 800-88. Developers must
also permanently and securely delete all live (online or network accessible) instances of
Information 90 days after Amazon's notice. If requested by Amazon, the Developer will certify in
writing that all Information has been securely destroyed.
1.8 Data Attribution. Developers must store Information in a separate database or implement a mechanism to tag and identify the origin of all data in any database that contains Information.
2. Additional Security Requirements Specific to Personally Identifiable Information
The following additional Security Requirements must be met for Personally Identifiable Information ("PII"). PII is granted to Developers for select tax and merchant fulfilled shipping purposes, on a must-have basis. If an Amazon Services API contains PII, or PII is combined with non-PII, then the entire data store must comply with the following requirements:
2.1 Data Retention. Developers will retain PII for no longer than 30 days
after order delivery and only for the purpose of, and as long as is necessary to (i) fulfill
orders, (ii) calculate and remit taxes, (iii) produce tax invoices and other legally required
documents, and (iv) meet legal requirements, including tax or regulatory requirements.
Developers may retain data for over 30 days after order delivery only if required by law and
only for the purposes of complying with that law. Per sections 1.5 (“Encryption in Transit”) and
2.4 (”Encryption at Rest”) at no point should PII be transmitted or stored unprotected.
2.2 Data Governance. Developers must create, document, and abide by a
privacy and data handling and classification of policy for their Applications or services, which
govern the appropriate conduct and technical controls to be applied in managing and protecting
information assets. A record of data processing activities such as specific data fields and how
they are collected, processed, stored, used, shared, and disposed for all PII should be
maintained to establish accountability and compliance with regulations. Developers must
establish a process to detect and comply with privacy and security laws and regulatory
requirements applicable to their business and retain documented evidence of their compliance.
Developers must establish and abide by their privacy policy for customer consent and data rights
to access, rectify, erase, or stop sharing/processing their information where applicable or
required by data privacy regulation. Developers must have technical and organizational processes
and systems in place for assisting Authorized Users with data subject access requests.
Developers must include contractual provisions in employment contracts with employees that
process PII to maintain confidentiality of PII.
2.3 Asset
Management. Developers must maintain baseline standard configuration for
information systems and install patches, updates, defect fixes, and upgrades on a regular basis.
Developers must maintain, and update quarterly, an accurate inventory of software and physical
assets (e.g. computers, mobile devices) with access to PII, which should include all devices in
the Developer’s environment along with the status of maintenance of each device to ensure
compliance against the baseline. Developers must maintain a change management process for all
information systems, such that software and hardware with access to PII are tested, verified,
and approved, with a segregation of duties between change approvers and those testing the
changes before implementation. Physical assets that store, process, or otherwise handle
PII must abide by all of the requirements set forth in this policy. Developers must not store
PII in removable media, personal devices, or unsecured public cloud applications (e.g., public
links made available through Google Drive) unless it is encrypted using at least AES-128 or
RSA-2048 bit keys or higher. Developers must securely dispose of any printed documents
containing PII. Developers must implement data loss prevention (DLP) controls in place to
monitor and detect unauthorized movement of data.
2.4 Encryption at Rest. Developers must encrypt all PII at rest using at
least AES-128 or RSA with 2048-bit key size or higher. The cryptographic materials (e.g.,
encryption/decryption keys) and cryptographic capabilities (e.g. daemons implementing virtual
Trusted Platform Modules and providing encryption/decryption APIs) used for encryption of PII at
rest must be only accessible to the Developer's processes and services.
2.5
Secure Coding Practices. Developers must not hardcode sensitive credentials in
their code, including encryption keys, secret access keys, or passwords. Sensitive credentials
must not be exposed in public code repositories. Developers must maintain separate test and
production environments.
2.6 Logging and Monitoring. Developers
must gather logs to detect security-related events to their Applications and systems including
success or failure of the event, date and time, access attempts, data changes, and system
errors. Developers must implement this logging mechanism on all channels (e.g., service APIs,
storage-layer APIs, administrative dashboards) providing access to Information. Developers must
review logs in real-time (e.g. SIEM tool) or on a bi-weekly basis. All logs must have access
controls to prevent any unauthorized access and tampering throughout their lifecycle. Logs must
not contain PII unless the PII is necessary to meet legal requirements, including tax or
regulatory requirements. Unless otherwise required by applicable law, logs must be retained for
at least 90 days for reference in the case of a Security Incident. Developers must build
mechanisms to monitor the logs and all system activities to trigger investigative alarms on
suspicious actions (e.g., multiple unauthorized calls, unexpected request rate and data
retrieval volume, and access to canary data records). Developers must implement monitoring
alarms and processes to detect if Information is extracted from or can be found beyond its
protected boundaries. Developers should perform an investigation when monitoring alarms are
triggered, and this should be documented in the Developer's Incident Response Plan.
2.7 Vulnerability Management. Developers must create and maintain a plan
and/or runbook to detect and remediate vulnerabilities. Developers must protect physical
hardware containing PII from technical vulnerabilities by performing vulnerability scans and
remediating appropriately. Developers must conduct vulnerability scanning at least every 180
days, penetration tests at least every 365 days, and scan code for vulnerabilities prior to each
release. Developers must have appropriate procedures and plans to restore availability and
access to PII in a timely manner in the event of a physical or technical incident.
3. Audit and Assessment
Developers must maintain all appropriate books and records reasonably required to verify compliance with the Acceptable Use Policy, this DPP, and Amazon Services API Developer Agreement during the period of this agreement and for 12 months thereafter. Upon Amazon's written request, Developers must certify in writing to Amazon that they are in compliance with these policies.
Upon reasonable request, Amazon may, or may have an independent certified public accounting firm selected by Amazon, audit, assess and inspect the books, records, facilities, operations, and security of all systems that are involved with a Developer's Application in the retrieval, storage, or processing of Information. Amazon will keep confidential any non-public information disclosed by a Developer as part of this audit, assessment, or inspection that is designated as confidential or that, given the nature of the information or the circumstances surrounding its disclosure, reasonably should be considered confidential. Developers must cooperate with Amazon or Amazon's auditor in connection with the audit or assessment, which may occur at the Developer's facilities and/or subcontractor facilities. If the audit or assessment reveals deficiencies, breaches, and/or failures to comply with our terms, conditions, or policies, the Developer must, at its sole cost and expense, take all actions reasonably necessary to remediate those deficiencies within an agreed-upon time frame. Upon request, the Developer must provide remediation evidence in the form requested by Amazon (which may include policy, documents, screenshots, or screen sharing of application or infrastructure changes) and obtain written approval on submitted evidence from Amazon before audit closure.
4. Definitions
"Amazon Services API" means any application programming interface (API) offered by Amazon for the purpose of helping Amazon Authorized Users to programmatically exchange data.
"API Materials" means Materials we make available in connection with the Amazon Services API, including APIs, documentation, specifications, software libraries, software development kits, and other supporting materials, regardless of format.
"Application" means a software application or website that interfaces with the Amazon Services API or the API Materials.
"Authorized User” means a user of Amazon’s systems or services who has been specifically authorized by Amazon to use the applicable systems or services.
“Content” means copyrightable works under applicable law and content protected under applicable law.
"Customer" means any person or entity who has purchased items or services from Amazon's public-facing websites.
"Developer" means any person or entity (including you, if applicable) that uses the Amazon Services API or the API Materials for a Permitted Use on behalf of an Authorized User.
"Information" means any information that is exposed through the Amazon Services API, Amazon Portals, or Amazon's public-facing websites. This data can be public or non-public, including Personally Identifiable Information about Amazon Customers.
“Materials” means software, data, text, audio, video, images, or other Content.
"Personally Identifiable Information" ("PII") means information that can be used on its own or with other information to identify, contact, identify in context, or locate an Amazon Customer or Authorized User. This includes, but is not limited to, a Customer or Authorized User's name, address, e-mail address, phone number, gift message content, survey responses, payment details, purchases, cookies, digital fingerprint (e.g., browser, user device), IP Address, geo-location, postal code, or Internet-connected device product identifier.
"Security Incident" means any actual or suspected unauthorized access, collection, acquisition, use, transmission, disclosure, corruption, or loss of Information, or breach of any environment containing Information.