6. Governance and Gates #
This section defines the minimum decision points (“gates”) every vendor change must pass. Each gate requires specific approvals and evidence. No production change may bypass a gate without an approved exception.
6.1 Intake Gate (initiate) #
Purpose Confirm the business need, data sensitivity, residency, and high‑level risk before design/build.
Required inputs
- Business case and high‑level requirements (owner, scope, success criteria).
- Data classification overview (what PI is processed; whether images are captured; expected volumes).
- Residency statement (Canada‑only by default; any known cross‑border touchpoints).
- Initial risk/privacy triggers (e.g., new PI, new purpose, new integration).
Approvals
- Product/Process Owner: business need and initial requirements.
- ISO: initial security/privacy posture; gate to Design or request more info.
- Legal/Privacy when privacy triggers exist (DPIA required or not).
PENDING: DPIA trigger checklist location/link
Deliverables (store with project record)
- Intake form (one page), high‑level data flow sketch, decision and next steps.
6.2 Design Gate (approve to build) #
Purpose Ensure security, privacy, and operational patterns are correct before implementation.
Required evidence
- Updated requirements mapped to acceptance criteria.
- Data flow diagram (systems, stores, integrations, subprocessors) and residency map.
- Identity design (SSO/MFA, roles, service accounts), logging design (events/fields), crypto and key handling.
- API and file‑upload protections; WAF posture; rate limits; secure headers; error handling.
- Privacy elements (minimization, retention/deletion, subject‑rights enablement).
- Operational patterns (monitoring/alerts, backups/restore approach, rollback concept).
Approvals
- Product/Process Owner: business fit.
- ISO: security/privacy design approval.
- Legal/Privacy: when DPIA/residency exception is required.
- IT Operations: feasibility and observability acceptance.
6.3 Pre‑Production Gate (approve to release) #
Purpose Verify the build is secure, tested, observable, and reversible.
Required evidence (minimal release package)
- SBOM for the release build. PENDING: Format — SPDX/CycloneDX; delivery location
- Security test summaries: SAST, SCA, secrets scan, DAST (web/API), container/IaC scans when applicable.
- Open findings register with POA&M; waivers (if any) approved by ISO and time‑bound.
- Change log (functional, security, operational impacts).
- Deployment plan and rollback plan (pre‑checks, triggers, steps, validation).
- Logging schema (if changed) and SIEM routing verified; dashboards/alerts defined.
- Data‑flow update (if changed); updated admin/user guides (if changed).
- UAT evidence and acceptance sign‑off by Product/Process Owner.
Approvals
- Product/Process Owner: UAT complete, acceptance confirmed.
- ISO: security evidence and risk posture.
- IT Operations: operational readiness (monitoring, runbooks, backups/restore).
6.4 Go‑Live Gate (deploy to production) #
Purpose Confirm final readiness and authorize production deployment.
Readiness checks
- Deploy window/notice met; on‑call and escalation paths active.
- Backups verified recent; recovery steps known; rollback rehearsed (tabletop minimum).
- WAF/API protections enabled; alerts routed and tested.
- Access reviews completed for admin/support roles; break‑glass controls sealed.
Approvals
- ISO + Product/Process Owner (joint).
- Executive Sponsor when residual risk/exception remains.
6.5 Post‑Go‑Live Review (stabilize and learn) #
Purpose Validate stability/security post‑deployment and capture improvements.
Activities (within 30 days)
- Review incidents, alerts, error rates, and performance; confirm no new PII exposure.
- Verify completion of outstanding POA&M items; close waivers or re‑justify with new expiry.
- Update runbooks, dashboards, and training where needed; feed backlog with improvement items.
Ownership
- ISO coordinates; Product/Process Owner and Vendor provide data; IT Operations supplies telemetry.
6.6 Exceptions at Gates #
Any attempt to pass a gate with missing evidence or unmitigated risk requires a documented exception that includes scope, rationale, risk assessment, compensating controls, owner, and expiry. ISO recommends; Executive Sponsor approves. Privacy‑impacting exceptions require Legal/Privacy review. PENDING: Exception template location
Gate artifacts retention All gate decisions and evidence packages must be retained with the project/release record per the Records Management and Retention Schedule. PENDING: Repository/path for storing gate artifacts