Compliance Statement
Updated: January 2025
If you’re considering Cloud Gateway or are already working with us, you should know that we take compliance seriously. Security, data protection, quality, resiliency and our ESG impact are of the utmost importance to us - read how we manage these below.
But before that...
Risk Ledger
We maintain an account on the platform Risk Ledger, a third party collaboration and risk management solution. Here we have completed a comprehensive supplier due diligence assessment.
We are reassessed twice a year and the questions are regularly updated. We can share this with you if you are a customer, for FREE.
Roles
We have defined security, data protection and compliance roles and responsibilities for individual employees. These are recorded in role profiles and policies and include our Senior Leadership Team who take pride in our ability to uphold our ISMS, QMS and data privacy in everything that we do.
Risk management
As an ISO 27001 and ISO 9001 certified organisation, we take a risk-based approach to operations. Risk management is an integral part of our processes and we intentionally provide and encourage an open environment whereby risks can be raised anytime, by any member of staff.
Security
How do we maintain and deliver a secure product to you?
Certificates and accreditations
Our service is built to adhere to the HMG UK Official guidelines, which in turn adheres to the National Cyber Security Centre (NCSC) cloud security principles.
ISO 27001
Since 2020, we have been continually awarded ISO 27001 certification by a UKAS accredited body.
ISO 27001 specifies the requirements for establishing, implementing, maintaining and continually improving an information security management system.
Download: ISO27001 certificate
CyberEssentials PLUS
Since 2022, we have been awarded Cyber Essentials and Cyber Essentials PLUS certificates.
CyberEssentials PLUS is a UK-based scheme designed to test and conclude that an organisation has a minimum level of cyber security protection in place.
Product infrastructure
Cloud Gateway hosts its product on the major cloud platform Amazon Web Services (AWS). The AWS data centres are located in the United Kingdom. Our products and services can be configured to other locations if required.
Hosting Cloud Gateway on these major cloud platforms provides us with extra benefits such as security tools, server maintenance, and redundancy.
See Business continuity for further information on redundancy.
Data centres
We house our networking equipment in specially selected data centres in the UK. The data centres are kept secure and operational by the providers and benefit from CCTV, fire detection and suppression systems, airflow systems, power redundancy, access control, visitor management and more. All data centre providers are ISO 27001, ISO 22301, 14001 and 5001 certified, as well as SOC 2 Type II certified.
HR infrastructure
Personnel security is managed through a number of policies and procedures.
Security checks and clearance
We vet our employees before they begin working for the company via BPSS background checks. Additional security clearance is obtained whenever it is required for our customer accounts (e.g. SC level).
Confidentiality
Confidentiality clauses are included in all employee contracts.
We also ensure confidentiality clauses or Non-Disclosure Agreements with third parties where necessary. See Supplier management for further information.
On and offboarding employees
See Access control
Staff security training
All employees are required to complete compliance and security training when they join Cloud Gateway, and annually thereafter. This training covers security, quality, data protection, ESG (see below) and general compliance topic areas.
Access control
Across the business, the principle of least privilege is enforced and role-based access controls are in place to prevent unauthorised disclosure or access to information. Access to information is frequently audited.
Joiner, mover and leaver processes ensure access provision and revocation at appropriate times for employees (which is immediately for leavers).
Segregation of duties
Responsibilities are segregated so that departments manage areas within their expertise, such as networking, development, security, compliance, service delivery and internal operations. There are no role-related crossovers within the business.
Authentication
Employees accessing the production network are required to use multiple factors of authentication, such as SSO, VPN connection and individual application access controls.
Encryption
We protect data and communications to uphold the confidentiality and integrity of all data, whether at rest or in transit.
Any customer data that we store is encrypted to AES-256 or AES-XTS.
All of our network management functionality uses SSH, HTTPS and SNMPv3.
Physical security
We are a hybrid-working organisation that makes use of office “hubs”. These hubs are rented from third parties, who provide physical security features. Although there is no information processing or storing equipment in any hub, they benefit from CCTV, manned reception desks, security personnel and access control (e.g. access cards and physical keys).
Operations security
Change management
We make use of a comprehensive change management programme. Further information on this can be found in the Quality section.
Passwords
Our employees must comply with an internal policy that sets requirements such as password length, characters, storage and re-use. A password management tool is enforced across the Technical team. A password management tool is in use to enforce this.
Antimalware
Industry-standard antimalware software is installed across all endpoints and servers. The application updates daily automatically.
Back ups
To ensure operational resiliency, back ups of the product infrastructure and service data are taken no less frequently than daily and networking components hourly. All back ups are cloud based.
The Cloud Gateway Portal is backed up in real time and replicated across several availability zones within the UK.
Logging and monitoring
Activity logging is enabled across information systems and networks. Administrators are prohibited from disabling logging activity or tampering with audit log information.
Patching and updates
We take a proactive but risk-balanced approach to patches and updates. Where we can safely make use of automatic patching, we do.
Vulnerabilities
Vulnerabilities are proactively identified, logged and dealt with using industry-standard tools and according to defined processes.
We also consume information on possible vulnerabilities through various threat intelligence feeds.
Network security
A cloud firewall at the boundary of our management network protects against unauthorised network ingress and egress. All allowed connections are subject to approval.
Network segregation
All customer networks are fully segregated.
Penetration tests
Every year, a penetration test known as an “IT Health Check” is used to ethically attempt to enter our network without authorisation, as well as review our perimeter security configurations.
The organisation that conducts the penetration test is both CHECK and CREST certified.
Secure coding
Cloud Gateway follows a secure development lifecycle (SDLC) and aligns to the OWASP framework to limit exposure to security risk.
Development, testing, staging and production environments are all separated and no production data is used in the development or test environments.
Before releasing development work into production, security testing is folded into acceptance testing to review security controls such as enforced encryption, back ups, logging and monitoring, etc.
Supplier management
All suppliers are subject to due diligence assessments prior to onboarding. We review the supplier’s processes and accreditations in security, data protection, quality management, and resiliency, as well as their ESG strategies, business ethics, and legal and regulatory compliance.
Incident management
If you are a customer, we will notify you of any incident that may affect you.
Our employees are trained in incident response processes, including communication channels and escalation paths. As well as procedures for identifying, reporting, and responding to incidents, we will raise problem records and conduct post-incident reports with root cause analysis to aid trend identification and implement lessons learned.
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Data protection
Cloud Gateway is a GDPR compliant organisation
Processed fairly, lawfully and in a transparent manner
Used only for limited, specified stated purposes and not used or disclosed in any way incompatible with those purposes
Adequate, relevant, and limited to what is necessary
Accurate and, where necessary, up to date
Not kept for longer than necessary
Kept safe and secure
Encryption at rest and in transit where it can be enforced
Access control such as the principle of least privilege and role-based access control
Audit logs to track access and administrator activity
Authentication procedures (SSO, MFA)
Backup and restore procedures
Data collection minimisation
Data retention schedule procedures
Introduction
We place great importance on data protection and privacy.
We recognise our obligations to meet the requirements of the GDPR and comply with the six data protection principles. Personal data is always:
ICO registration
Our ICO registration number is ZA413371.
Data residency
Personal data of customers is stored in the United Kingdom and European Union. However, our products and services can be configured to other locations if required.
Data controller or data processor
We are a data controller of the personal information you share with us to onboard you as a customer and of the cookies you allow us to track on our website.
As a network connectivity provider, we are not commonly a data processor for our customers. Data is transferred through our gateway and across the network we have connected for you. By its very nature, we cannot access encrypted data, and therefore are not a data processor of this traffic.
Data transferred in an unencrypted format, which may be the requirement for some customers and is the choice of the customer, and that contains personal information of UK/EU citizens, we are a data processor if we are required to access packet information of the transfer. We may access this information to provide troubleshooting support and investigation. Access to this information is restricted to only our technical engineers, and under no other circumstances are engineers obliged to or permitted to view traffic content.
Technical and organisational safeguards
Internally we implement various technical and organisational safeguards to protect personal information. These include:
Cloud Gateway does not collect any customer’s special category information.
Data retention
We only retain personal information for as long as it is necessary to be kept, which may include compliance with legal obligations.
At the end of a contract, or upon request from a customer where retention is not required by law, we will delete personal information in accordance with our Privacy policy.
Data destruction
We are a generally paperless company. If there is any case of physical records containing confidential/sensitive information, it must be securely disposed of, i.e. shredded.
We outsource the destruction of digital data to a third party, who meets the security and compliance requirements of the Ministry of Defence and the US Department of Defence, and destroys data via degaussing, Blancco and EDR-HDC.
Your rights
As per our Privacy policy, if you wish to exercise any of your rights under the GDPR, please email compliance@cloudgateway.co.uk. Our Data Protection Officer will get back to you.
We are registered with the ICO, you can search their database here to access our registration information.
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Quality
How do we deliver a quality product and service?
Certifications and accreditations
ISO 9001
Since 2020, we have been awarded ISO 9001 certification by a UKAS accredited body.
ISO 9001 specifies the requirements for establishing, implementing, maintaining and continually improving a quality management system.
Quality product
We place a great deal of care and emphasis on the products we offer our customers, from technical solutions to end-user capability in the Cloud Gateway Portal, we are always looking for new products to benefit you. In fact, we actively seek ideas from our customers and staff alike.
When designing new products, we follow project management guidelines to include relevant stakeholders, gain approvals, record expectations, test deliverables and communicate releases before rolling them into production.
Change management
We practise an ITIL aligned change management process that governs all changes to our production systems/services. This includes peer review, implementation plans, testing, rollback plans, risk profiles and Change Advisory Boards (CAB).
ITIL
Our service desk is composed of excellent agents committed to providing you quality support. Our processes align with the ITIL framework, carefully managing maintenance and changes, and our agents are all ITIL certified.
Customer focus and satisfaction
We truly are a customer focused organisation. After every engagement with our Service Desk, customers have the opportunity to provide feedback and under our Premium Support plan, we deliver monthly service reviews to make sure you are happy with the product and service you are receiving.
We strongly encourage our customers to provide as much feedback as possible and as often as possible, to help us monitor and continually improve our delivery of service.
We also generate an Net Promoter Score (NPS) to gauge our success at every stage of your journey. From marketing, sales, finance, support and technical delivery, we want to understand how satisfied you are with Cloud Gateway.
Complaints
We have an established complaints process that allows customers to raise concerns and ensure prompt review and resolution of any instances.
All complaints are documented, investigated and addressed in a timely manner to maintain service quality and customer satisfaction.
If you are a customer and wish to raise a complaint or have any questions about this process, please refer to your Onboarding Pack for instructions and a procedure document.
Continual service improvement
We have designed and implemented a continual service improvement process to make use of both internal and external feedback on the quality of our service delivery. We encourage our customers and staff to raise improvement ideas that we then record, review and plan for production where they meet the criteria of the process. We factor in how we will be able to monitor the success of these improvements to validate them as well.
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Business continuity
Keeping you connected is as crucial to us as it is to you.
Our network is highly resilient with redundant equipment and failover sites, and we offer dual WAN links to our customers as well.
The Cloud Gateway Portal is replicated across several availability zones within the UK.
We take backups of important information as per the Back up section.
To make sure the resiliency works as we expect it to, we have designed and tested continuity plans that we test on an annual basis.
As far as internal operations are concerned, we are a remote working organisation meaning we don’t rely on physical offices and there is no risk to operations should we need to work from home. All of the IT systems we use are cloud based with resiliency and are subject to due diligence assessments. See Supplier management for further information.
Environment, social and governance
Cloud Gateway’s commitment to ESG
We align with the UK government Procurement Policy Note 06/20 (PPN 06/20) when monitoring, reviewing and implementing initiatives for ESG.
We are committed to making positive contributions across ESG frameworks. We invest significant attention and focus in these areas and have a taskforce dedicated to delivering change across the company.
Environmental
Not only are we dedicated to limiting our environmental impact and making positive contributions to the environment, we are also committed to achieving Net Zero Scope 1 and 2 emissions by 2030, and Net Zero across Scope 3 by 2035.
Our recently updated Carbon Reduction Plan demonstrates our commitment to understanding and lowering our carbon footprint. We changed our carbon auditing partner in 2024 to ensure the highest standard of reporting, making use of the ISO 14064 and Greenhouse Gas Protocol calculation standards.
This year there has been a reduction in our overall carbon impact. In particular, our scope 3 emissions have reduced from 50 tonnes of CO2 to 30 tonnes of CO2.
We are pleased to report that we have offset our CO2 emissions using Carbon Neutral Britain’s ‘Climate Leader’ initiative. The offsetting contributions are used for projects that are either VCS (Verified Carbon Standard) VER (Voluntary Emissions Reduction) or CER (Certified Emission Reduction) certified. They are also often based in the developing world and focused on education, employment, clean water, energy and positive impacts to local wildlife.
You can find our CO2 reduction initiatives in our Carbon Reduction Plan, and our overarching Environmental policy can be found here.
Social
Local and wider community impact
In 2024 we launched a Volunteering Initiative, permitting all staff to spend two working days on volunteering efforts. As well as employees participating in causes close to their homes and hearts, we organised several corporate volunteering events of various kinds, including environmental cleanup days, community competitive sports and supporting nature reserves.
Fair treatment
We create a community for our employees to feel at home in and operate a fair, inclusive workplace and actively tackle workforce inequality. We fully comply with the Equality Act 2010 by promoting a non-discriminatory, diverse environment where all employees and applicants are treated fairly, regardless of age, disability, gender, race, religion, sexual orientation, or any other protected characteristic.
We stand against any form of harassment or bullying and operate with zero tolerance for discrimination, harassment, or victimisation.
Supporting staff
We support our workforce actively through wellbeing initiatives such as a Buddy System, line manager touchpoints and staff performance reviews that specifically address wellbeing and stress.
We heavily invest and promote ongoing learning and development for our staff and contribute to the wider community through volunteering and mentorship initiatives, such as supporting young people to write CVs.
Governance
Senior leadership
Our Senior Leadership Team is composed of both men and women and we have a diverse workforce free from discrimination or bias. Transparency is one of our core company values and so whistleblowing policies and management of conflicts of interest help us to operate openly.
Modern slavery
Every year we release a Modern Slavery Statement on our website to demonstrate our adherence to the Modern Slavery Act.
Health and safety
Not only are we compliant with health and safety legislation, we are committed to fostering a positive health and safety culture and maintaining a safe environment.
This includes preventing accidents and work-related ill health, providing proper equipment and clear information and training, conducting assessments and ensuring effective emergency procedures.
Anti-bribery and corruption
We have a zero-tolerance approach to bribery and corruption.
We conduct business fairly, openly, and ethically, adhering to the legal standards such as the Fraud Act 2006 and the Bribery Act 2010.
Staff are required to act with integrity, safeguard resources and report any suspicious or actual incidents of bribery or corruption. We have a policy for fair and appropriate investigation.
Insurances
Cloud Gateway has multiple insurances:
Professional indemnity
Employer’s liability
Public liability
Products liability
Cyber incident response and cyber crime
If you are a customer and require further details please contact the Service Desk to make your enquiry.
Legislation
We keep on top of applicable legislation and regulation internally and with the support of external counsel. Employees are directly assigned responsibility to ensure our compliance.
Social value portal
We remain a user of the Social Value Portal.
The mission of Social Value Portal is to engage, enable and empower organisations in the pursuit of social, economic and environmental wellbeing. This aligns with our commitments and brings rigour and transparency to the means by which we measure, manage, and report social value.
Importantly, Social Value Portal enables us to track and report on the positive impact we are having on society. We can measure how we are performing against the National TOMs; an accredited framework aligned to the government and UN's key objectives around ESG.
We are very proud to have already contributed over £1,000,000 worth of social value.