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Table of Contents
Introduction ....................................................................................................................................................... 3
ISO Certifications for the Office 365 Services Stack ........................................................................................... 4
Using this Document .......................................................................................................................................... 4
Audit Assurance and Compliance: Controls AAC-01 through AAC-03 ............................................................... 5
Application and Interface Security: Controls AIS-01 through AIS-04 ................................................................. 6
Business Continuity Management and Operational Resilience: Controls BCR-01 through BCR-11 .................. 7
Change Control and Configuration Management: Controls CCC-01 through CCC-05 ..................................... 10
Datacenter Security: Controls DCS-01 through DCS-09 ................................................................................... 12
Data Security and Information Lifecycle Management: Controls DSI-01 through DSI-07 ............................... 14
Encryption and Key Management: Controls EKM-01 through EKM-04 ........................................................... 16
Governance and Risk Management: Controls GRM-01 through GRM-11 ....................................................... 18
Human Resources: Controls HRS-01 through HRS-11 ...................................................................................... 21
Identity and Access Management: Controls IAM-01 through IAM-13 ............................................................ 23
Interoperability and Portability: Controls IPY-01 through IPY-05 .................................................................... 27
Infrastructure and Virtualization Security: Controls IVS-01 through IVS-13 .................................................... 28
Mobile Security: Controls MOS-01 through MOS-20 ....................................................................................... 31
Security Incident Management, E-discovery, and Cloud Forensics: Controls SEF-01 through SEF-05 ............ 33
Supply Chain Management, Transparency and Accountability: Controls STA-01 through STA-09 ................. 34
Threat and Vulnerability Management: Controls TVM-01 through TVM-03 ................................................... 37
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Introduction
Office 365 provides a set of productivity applications that bring together online versions of our email and
collaboration software with our familiar Microsoft Office applications in the cloud. Office 365 is developed
and managed by the Office 365 Engineering and Operations team, which uses a limited set of Platform as a
Service (PaaS) and Infrastructure as a Service (IaaS) services provided by Microsoft Azure (Azure) and
Microsoft’s Cloud Infrastructure and Operations team (MCIO).
Office 365 applications run on a cloud infrastructure and are accessible from various client devices. While
customers remain in control of their data and have control over some feature and implementation settings,
Microsoft manages and controls the underlying cloud infrastructure, networks, servers, operating systems,
storage, and the individual configurations thereof. The Office 365 stack, including the portion that is
customer-managed, is illustrated below:
A review of the ISO 27001 and ISO 27002 publicly available standards is also recommended. ISO standards
are available at the International Organization for Standardization web site. We also recommend that you:
Visit the independent auditor (BSI) attestation of the Office 365 ISO 27001 Certification
Visit the independent auditor (BSI) attestation of the Microsoft Azure ISO 27001 Certification
Visit the independent auditor (BSI) attestation of the Microsoft Cloud Infrastructure and Operations
(MCIO) ISO 27001 Certification
In addition, you can download several ISO audit reports from Microsoft’s Service Trust Portal (STP), which is
available to all Office 365 tenants (including trial subscribers).
On the following pages, Office 365 security practices are mapped to the control guidance provided by the
CCM. The first two columns (CCM Control Domain and ID and CCM v3.0.1 Control Specification) consist of
content directly from the CCM identifying relevant controls. The third column (Office 365 Response)
consists of short explanations of how Office 365 controls satisfy the CSA recommendations.
The CCM responses included in this document are in alignment with our ISO 27001, 27018 and SOC
attestations and scoped to the following Office 365 services that are hosted in Microsoft datacenters:
Exchange Online
Exchange Online Protection
SharePoint Online, including OneDrive for Business
Skype for Business
Office Online
Office Services Infrastructure
Suite User Experience
Domain Name Service
Security Workload Environment
1
ISO 27002 is not a certification but provides a suggested set of suitable controls for an Information Security
Management System (ISMS).
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Audit Assurance & Audit plans shall be developed and Office 365 independent audit reports and certifications are shared with customers in
Compliance maintained to address business process the format native to the type of audit. These certifications and attestations
Audit Planning disruptions. Auditing plans shall focus on accurately represent how Office 365 obtains and meets its security and compliance
reviewing the effectiveness of the objectives and serve as a practical mechanism to validate the Office 365 security and
AAC-01 implementation of security operations. All compliance promises for customers.
audit activities must be agreed upon prior to
executing any audits.
Audit Assurance & Independent reviews and assessments shall be SOC, ISO 27001 certifications, and other audit reports for Office 365 can be found at
Compliance performed at least annually to ensure that the the Office 365 and Microsoft Online Services Security, Audits and Certifications page,
Independent organization addresses nonconformities of and the website of our external ISO auditor, the BSI Group.
Audits established policies, standards, procedures,
and compliance obligations. Applicable audits of Office 365 are carried out at least annually by certified
AAC-02 independent assessors, including SOC 1/2, ISO 27001, ISO 27018, and FedRAMP.
Audit Assurance & Organizations shall create and maintain a Office 365 has designed and implemented an Information Security Management
Compliance control framework which captures standards, System (ISMS) framework that addresses industry best-practices for information
Information regulatory, legal, and statutory requirements security and privacy. The ISMS has been documented and communicated in a
System Regulatory relevant for their business needs. The control customer-facing Information Security Policy, which is available for download from
Mapping framework shall be reviewed at least annually the STP.
to ensure changes that could affect the
AAC-03 business processes are reflected. Office 365 performs annual ISMS reviews, the results of which are reviewed by
security and compliance management. This involves monitoring ongoing
effectiveness and improvement of the ISMS control environment by reviewing
security issues, audit results, and monitoring status, and by planning and tracking
necessary corrective actions.
Office 365 has implemented a common controls framework which maps and aligns
control domains and activities across services, requirements, and operations for each
audit and certification. This mechanism is regularly maintained and updated with
new controls when standards are incorporated into the Office 365 control
framework.
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Office 365 validates services using third party penetration testing based upon the Open
Web Application Security Project (OWASP) top ten and Council of Recognized Ethical
Security Testers (CREST)-certified testers. The outputs of testing are tracked through the
risk register.
Application & Prior to granting customers access to data, The Office 365 approach to customer access and trust principles is defined on the
Interface assets, and information systems, identified Office 365 Trust Center. The principles include built-in security, privacy by design,
Security security, contractual, and regulatory continuous compliance, and transparent operations.
Customer requirements for customer access shall be
Access addressed. Before using Office 365 services, customers are required to review and agree with the
Requirements acceptable use of data and the Office 365 service agreement, as well as security and
privacy requirements, which are defined in the Microsoft Online Services Use Rights,
AIS-02 Microsoft Online Subscription Agreement, Microsoft Office 365 Platform Privacy
Statement and Technical Overview of the Security Features in Microsoft Office 365
Platform.
To help customers comply with their own requirements, Office 365 builds services with
common privacy and security requirements in mind. Office 365 is kept up to date with
the ever evolving industry standards and regulations. The service is verified to meet
requirements specified in ISO 27001, ISO 27018, HIPAA, FedRAMP and others. The data
processing agreement details privacy, security, and handling of customer data, which
helps comply with local regulations.
Microsoft was the first major cloud service provider to make contractual privacy
commitments (as well as to incorporate the best practices encompassed by ISO 27018)
that help assure the privacy protections built into in-scope Office 365 services are strong.
Application & Data input and output integrity routines (i.e., Office 365 defines acceptable standards to ensure that data inputs to application
Interface reconciliation and edit checks) shall be systems are accurate and within the expected range of values. Where appropriate, data
Security implemented for application interfaces and inputs are sanitized or otherwise rendered safe before being inputted to an application
Data Integrity databases to prevent manual or systematic system.
processing errors, corruption of data, or
AIS-03 misuse. Microsoft developers follow the Microsoft SDL methodology which includes specific
requirements for data input and output validation checks. Additional information can be
found at the Microsoft Security Development Lifecycle website.
Internal processing controls are implemented within the Office 365 environment in order
to limit the risks of processing errors. Internal processing controls exist in applications, as
well as in the processing environment. Examples of internal processing controls include,
but are not limited to, the use of hash totals, and checksums.
Application & Policies and procedures shall be established Microsoft maintains and regularly updates the Information Security Policy which defines
Interface and maintained in support of data security to Microsoft policies. The policies address the purpose, scope, roles, responsibilities,
Security include (confidentiality, integrity and compliance requirements, and required coordination among the various Microsoft
Data Security / availability) across multiple system organizations providing some level of support for the security of Office 365.
Integrity interfaces, jurisdictions and business
functions to prevent improper disclosure, The Information Security Policy contains policies that must be met in the delivery and
AIS-04 alteration, or destruction. operation of Office 365. Standards and Procedures to facilitate execution of these
policies are documented in the Office 365 control framework. These standards and
procedures act as adjuncts to the security policy and provide implementation level
requirements and details to carry out specific operational tasks.
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BCR-06
Business Policies and procedures shall be established, Office 365 has established alternate storage sites to permit the storage and recovery
Continuity and supporting business processes and of Office 365 backup information. All alternate sites are active sites leveraging near
Management & technical measures implemented, for real-time data replication. Each alternate site is redundant and managed by
Operational equipment maintenance ensuring continuity Microsoft in accordance with the recovery time objectives established in the
Resilience and availability of operations and support Business Continuity Plans.
Equipment personnel.
Maintenance Additionally, Microsoft provides alternate telecommunications services with
consideration for reducing the likelihood of sharing a single point of failure with
BCR-07 primary telecommunications services. Microsoft manages a fiber network where
redundant communication links are established following disparate paths through
the Microsoft fiber network. This is a continuously operational solution. These
redundant links are found in all Microsoft datacenters in which Office 365 operates.
Business Protection measures shall be put into place to Office 365 has established alternate storage sites to permit the storage and recovery
Continuity react to natural and man-made threats based of Office 365 backup information. All alternate sites are active sites leveraging near
Management & upon a geographically-specific Business real-time data replication. Each alternate site is redundant and managed by
Operational Impact Assessment Microsoft in accordance with the recovery time objectives established in the
Resilience Business Continuity Plans.
Equipment Power
Failures Microsoft datacenters have dedicated uninterruptible power supplies (UPS) and
emergency power support, which may include generators. Regular maintenance and
BCR-08 testing is conducted for both the UPS and generators, and datacenters have made
arrangements for emergency fuel delivery.
CCC-02
Change Control & Organization shall follow a defined quality Office 365 has developed formal standard operating procedures (SOPs)
Configuration change control and testing process (e.g. ITIL governing the change management process. These SOPs cover both software
Management Service Management) with established development and hardware change and release management, and are
Quality Testing baselines, testing, and release standards that consistent with established regulatory guidelines including ISO 27001, SOC
focus on system availability, confidentiality, 1/SOC 2, NIST 800-53, and others.
CCC-03 and integrity of systems and services.
Microsoft also uses Operational Security Assurance (OSA), a framework that
incorporates the knowledge gained through a variety of capabilities that are
unique to Microsoft. OSA combines this knowledge with the experience of
running hundreds of thousands of servers in datacenters around the world.
Microsoft uses OSA to minimize risk by ensuring that ongoing operational
activities follow rigorous security guidelines and by validating that guidelines are
being followed effectively.
Download additional information about how Office 365 uses OSA for change and
configuration management here.
Critical security review and approval checkpoints are included during the system
development life cycle. Business, operational, and technical risks are identified and
the areas covered include compliance, security, privacy, and service continuity. As an
early pioneer for integrated security development, the SDL is at the core of
Office 365, and is a detailed, robust practice that Microsoft has developed over many
years. It covers patches, updates, and threat mitigation.
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CCTV is used to monitor physical access to datacenters and the information systems.
Cameras are positioned to monitor perimeter doors, facility entrances and exits,
interior aisles, caged areas, high-security areas, shipping and receiving, facility
external areas such as parking lots and other areas of the facilities.
Datacenter Security Automated equipment identification shall be Microsoft datacenters are operated by the Microsoft Cloud Infrastructure and
Equipment used as a method of connection Operations (MCIO) team, which maintains a current, documented and audited
Identification authentication. Location-aware technologies inventory of equipment and network components for which it is responsible. MCIO
may be used to validate connection employs automated mechanisms to detect discrepancies in device configuration by
DCS-03 authentication integrity based on known comparing them against the defined policies. MCIO turns off unused ports by default
equipment location. to prevent unauthorized access.
Datacenter Security Authorization must be obtained prior to Microsoft asset and data protection procedures provide prescriptive guidance
Off-Site relocation or transfer of hardware, software, around the protection of logical and physical data and include instructions
Authorization or data to an offsite premises. addressing relocation. Customers control where their data is stored while using
Office 365 services during provisioning of their tenant. Details are included in the
DCS-04 data maps in the Trust Center.
DSI-01
Data Security & Policies and procedures shall be established, Office 365 has documented and maintains a data flow diagram which accounts for all
Information and supporting business processes and system connections, the ports and protocols those connections use to communicate,
Lifecycle technical measures implemented, to and the classification of data flowing through the connections. The data flow diagram
Management inventory, document, and maintain data documents inner-system connections and also documents connections with 3rd
Data Inventory / flows for data that is resident (permanently parties. The Office 365 Security Policy requires that this documentation is reviewed
Flows or temporarily) within the service's and updated regularly.
geographically distributed (physical and
DSI-02 virtual) applications and infrastructure
network and systems components and/or
shared with other third parties to ascertain
any regulatory, statutory, or supply chain
agreement (SLA) compliance impact, and to
address any other business risks associated
with the data. Upon request, provider shall
inform customer (tenant) of compliance
impact and risk, especially if customer data is
used as part of the services.
Data Security & Data related to electronic commerce (e- Office 365 does not provide e-commerce solutions.
Information commerce) that traverses public networks
Lifecycle shall be appropriately classified and Customer data will be used only to provide Office 365 services to the customer. This
Management protected from fraudulent activity, can include troubleshooting aimed at preventing, detecting, and repairing problems
eCommerce unauthorized disclosure, or modification in affecting the operation of the services and the improvement of features that involve
Transactions such a manner to prevent contract dispute the detection of, and protection against, emerging and evolving threats to the user
and compromise of data. (such as malware or spam).
DSI-03
More information on the commitments that Microsoft has made regarding the use of
customer data can be found in the Office 365 Trust Center.
Data Security & Policies and procedures shall be established Office 365 classifies data according to the Office 365 data classification scheme and
Information for the labeling, handling, and security of applies security and privacy controls associated with the data classification. Office 365
Lifecycle data and objects which contain data. treats data created by customers (SharePoint documents, email messages, etc.) as
Management Mechanisms for label inheritance shall be ‘customer data’ which, along with access control data, is subject to the most rigorous
Handling / implemented for objects that act as of all security and privacy controls.
Labeling / Security aggregate containers for data.
Policy
DSI-04
Data Security & Production data shall not be replicated or Microsoft does not use customer data in non-production environments. In addition,
Information used in non-production environments. Any Office 365 is specifically designed to prevent the possibility of production data being
Lifecycle use of customer data in non-production moved or replicated outside of the Office 365 environment. These controls include:
Management environments requires explicit, documented Physical and logical network boundaries with strictly enforced change control
Non-Production approval from all customers whose data is policies.
Data affected, and must comply with all legal and Segregation of duties requiring a business need to access an environment.
regulatory requirements for scrubbing of Highly restricted physical and logical access to the cloud environment.
DSI-05 sensitive data elements. Strict controls based on SDL and OSA that define coding practices, quality
testing and code promotion.
Ongoing security, privacy and secure coding practices awareness and training.
Continuous logging and audit of system access.
Regular compliance audits to ensure control effectiveness.
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DSI-06
Data Security & Policies and procedures shall be established Microsoft uses best practice procedures and a media wiping solution that is NIST 800-
Information with supporting business processes and 88 compliant when disposing of media. For hard drives that can’t be wiped, Microsoft
Lifecycle technical measures implemented for the uses a destruction process that destroys the media (e.g., disintegrate, pulverize, or
Management secure disposal and complete removal of incinerate) and renders the recovery of information impossible. The appropriate
Secure Disposal data from all storage media, ensuring data is means of disposal is determined by the asset type. Records of the destruction are
not recoverable by any computer forensic retained.
DSI-07 means.
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Encryption & Key Keys must have identifiable owners (binding Microsoft has policies, procedures, and mechanisms established for effective key
Management keys to identities) and there shall be key management to support encryption of data in storage and in transmission for the key
Entitlement management policies. components of the Office 365 service.
EKM-01 Specifically, the Microsoft Public Key Infrastructure Operational Security Standard (PKI
OSS) supports procedures including binding keys to specific owners.
Encryption & Key Policies and procedures shall be established The Microsoft PKI OSS defines the policies and procedures that define key
Management for the management of cryptographic keys in management. The Standard accounts for various aspects of the key lifecycle, including
Key Generation the service's cryptosystem (e.g., lifecycle the following procedures:
management from key generation to Classify the Impact Level of Certification Authority Procedure
EKM-02 revocation and replacement, public key Configure Security Monitoring for Servers and Devices Procedure
infrastructure, cryptographic protocol design Define Standard Server Security Configuration for Certification and
and algorithms used, access controls in place Registration Authorities Procedure
for secure key generation, and exchange and Define Trusted and Authorized Roles Procedure
storage including segregation of keys used Delete Certification Authority Cryptographic Keys Securely Procedure
for encrypted data or sessions). Upon Dispose of Hardware Security Modules and Related Tokens or Cards Securely
request, provider shall inform the customer Procedure
(tenant) of changes within the cryptosystem, Dispose of Storage Devices and Media Securely Procedure
especially if the customer (tenant) data is Document and Maintain Security Architecture Procedure
used as part of the service, and/or the Document Certification Authority Hierarchy Procedure
customer (tenant) has some shared
Ensure Availability of Certificate Status Information Procedure
responsibility over implementation of the
Ensure Certificates Comply with Minimum Certificate Profile Procedure
control.
Establish Certification Practices Procedure
Evaluate Risks of Non-User Domain Accounts Procedure
Isolate Certification Authority System Network Procedure
Issue Certificates to External Parties Securely Procedure
Issue Server Authentication Certificates Securely Procedure
Keep Software Current and Install Security Updates Procedure
Log Key and Certificate Lifecycle Events Procedure
Maintain Audit Records and Inventories Securely Procedure
Maintain Hardware Security Modules Inventory Procedure
Maintain Server Inventory for Certification and Registration Authorities
Procedure
Minimize Network Exposure of Certification Authorities Procedure
Model Threats to the Certification Authority/RA System Procedure
Physically Protect Certification Authority System Servers and Network Devices
Procedure
Periodically Review Audit Records Procedure
Physically Protect Hardware Security Modules and Related Tokens or Cards
Procedure
Physically Protect PKI Facilities Procedure
Plan and Follow Certification Authority Key Generation Ceremony Procedure
Plan Business Continuity and Disaster Recovery Procedure
Plan Security Incident Response Procedure
Protect Against Malicious Code Procedure
Restrict Subordinate CA Certificate Usage Procedure
Review Proposed Operational Changes Procedure
Securely Back up Certification Authority Cryptographic Keys Procedure
Segregate Sensitive Operational Roles Procedure
Encryption & Key Policies and procedures shall be established, Customer data in transit is protected using TLS. Office 365 is configured to negotiate
Management and supporting business processes and FIPS compliant TLS protocols with supported client browsers, though non-FIPS
Sensitive Data technical measures implemented, for the use compliant protocols are supported for legacy browser support. The Office 365 FIPS
Protection of encryption protocols for protection of 140-2 encryption modules used for transmitted information are certified by NIST via
sensitive data in storage (e.g., file servers, certificates 1334, 1335, and 1336.
EKM-03 databases, and end-user workstations), data
in use (memory), and data in transmission
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(e.g., system interfaces, over public Office 365 uses BitLocker to encrypt customer data at rest at the volume-level.
networks, and electronic messaging) as per BitLocker encryption is a data protection feature that is integrated with Windows.
applicable legal, statutory, and regulatory BitLocker is one of the technologies used to safeguard against threats in case there are
compliance obligations. lapses in other processes or controls (e.g., access control or recycling of hardware)
that could lead to someone gaining physical access to disks containing customer data.
In this case, BitLocker eliminates the potential for data theft or exposure as a result of
lost, stolen, or inappropriately decommissioned computers and disks.
For additional information, see the white paper Data Encryption Technologies, which
is available for download from the STP.
Office 365 uses Windows servers for its services. The Windows Server operating
system has protections in place for preventing code execution in restricted memory
locations, including: No Execute (NX), Address Space Layout Randomization (ASLR),
and Data Execution Prevention (DEP). Additionally, the Microsoft SDL requires secure
coding practices including explicit consideration for safe memory handling
requirements.
Encryption & Key Platform and data-appropriate encryption Office 365 uses a variety of encryption technologies for securing data, and provides
Management (e.g., AES-256) in open/validated formats scenarios for both Microsoft-managed keys and customer-imported keys (e.g., bring
Storage and and standard algorithms shall be required. your own key aka control your own key). For specific information on the encryption
Access Keys shall not be stored in the cloud (i.e. at technologies and the methods for managing the crypto keys, see the white paper Data
the cloud provider in question), but Encryption Technologies, which is available for download from the STP.
EKM-04 maintained by the cloud consumer or trusted
key management provider. Key management
and key usage shall be separated duties.
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GRM-08
Governance and The organization's business leadership (or The Information Security Policy undergoes a formal management review and update
Risk Management other accountable business role or function) process at least annually. In the event that a significant change is required in the
Policy Reviews shall review the information security policy security policy, it may be reviewed and updated outside of the regular schedule.
at planned intervals or as a result of changes
GRM-09 to the organization to ensure its continuing
alignment with the security strategy,
effectiveness, accuracy, relevance, and
applicability to legal, statutory, or regulatory
compliance obligations.
Governance and Aligned with the enterprise-wide framework, Office 365 performs an annual formal risk assessment. As part of the overall ISMS
Risk Management formal risk assessments shall be performed framework, baseline security requirements are constantly being reviewed, improved
Risk Assessments at least annually or at planned intervals, and implemented. The Office 365 controls for risk and vulnerability assessment of the
(and in conjunction with any changes to Office 365 infrastructure encompass all areas in this section and meet the
GRM-010 information systems) to determine the requirements of the standards against which we audit, as demonstrated by reports
likelihood and impact of all identified risks identified on the Office 365 Trust Center.
using qualitative and quantitative methods.
The likelihood and impact associated with
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Human Resources Policies and procedures shall be established, Office 365 teams and personnel are required to adhere to applicable policies, which
Mobile Device and supporting business processes and do not permit mobile computing devices to be connected to the production
Management technical measures implemented, to environment. Mobile computing access points on the Microsoft corporate network
manage business risks associated with are required to adhere to wireless device security requirements.
HRS-05 permitting mobile device access to
corporate resources and may require the
implementation of higher assurance
compensating controls and acceptable-use
policies and procedures (e.g., mandated
security training, stronger identity,
entitlement and access controls, and device
monitoring).
Human Resources Requirements for non-disclosure or Microsoft Legal and Human Resources maintain policies and procedures defining the
Non-Disclosure confidentiality agreements reflecting the implementation and execution of non-disclosure and confidentiality agreements.
Agreements organization's needs for the protection of
data and operational details shall be
HRS-06 identified, documented, and reviewed at
planned intervals.
Human Resources Roles and responsibilities of contractors, The Information Security Policy exists in order to provide Microsoft staff and
Roles / employees, and third-party users shall be contractor staff with a current set of clear and concise Information Security Policies
Responsibilities documented as they relate to information including their roles and responsibilities related to information assets and security.
assets and security. These policies provide direction for the appropriate protection of Office 365. The
HRS-07 Information Security Policy has been created as a component of an overall ISMS for
Office 365.
Human Resources Policies and procedures shall be established, Mobile and wireless devices are not permitted within Microsoft datacenters where
Technology and supporting business processes and customer data is stored. Wireless access to Office 365 production environments is
Acceptable Use technical measures implemented, for prohibited.
defining allowances and conditions for
HRS-08 permitting usage of organizationally-owned
or managed user end-point devices (e.g.,
issued workstations, laptops, and mobile
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CCM Control Domain CCM v3.0.1 Control Specification Office 365 Response
and ID
Identity & Access Access to, and use of, audit tools that Log and monitor access is highly restricted to only authorized staff with a business
Management interact with the organization's information need to access such systems. Access to such data requires approval before
Audit Tools Access systems shall be appropriately segregated permissions are granted.
and access restricted to prevent
IAM-01 inappropriate disclosure and tampering of Systems that monitor and alert on audit data are segmented at the network and
log data. host layer and access is restricted to limited authorized staff via Role Based Access
Control (RBAC).
Identity & Access User access policies and procedures shall be Log and monitor access is highly restricted to only authorized staff with a business
Management established, and supporting business need to access such systems. Access to such data requires approval before
Credential Lifecycle / processes and technical measures permissions are granted.
Provision implemented, for ensuring appropriate
Management identity, entitlement, and access Systems that monitor and alert on audit data are segmented at the network and
management for all internal corporate and host layer and access is restricted to limited authorized staff via RBAC.
IAM-02 customer (tenant) users with access to data
and organizationally-owned or managed Office 365 has adopted applicable corporate and organizational security policies,
(physical and virtual) application interfaces including the Information Security Policy. The policies have been approved,
and infrastructure network and systems published and communicated across Office 365 teams. The Information Security
components. These policies, procedures, Policy requires that access to Office 365 assets to be granted based on business
processes, and measures must incorporate justification, with the asset owner's authorization and limits based on "need-to-
the following: know" and "least-privilege" principles. In addition, the policy also addresses
• Procedures and supporting roles and requirements for access management lifecycle including access provisioning,
responsibilities for provisioning and de- authentication, access authorization, removal of access rights and periodic access
provisioning user account entitlements reviews.
following the rule of least privilege
based on job function (e.g., internal Access to Microsoft buildings is controlled, and access is restricted to those with
employee and contingent staff card reader (swiping the card reader with an authorized ID badge) or biometrics for
personnel changes, customer-controlled entry into Datacenters. Front desk personnel are required to positively identify FTEs
access, suppliers' business relationships, or authorized contractors without ID cards. Staff must wear identity badges at all
or other third-party business times, and are required to challenge or report individuals without badges. Guests
relationships) must be escorted by authorized Microsoft personnel.
• Business case considerations for higher
levels of assurance and multi-factor Password policies for corporate domain accounts are managed through Microsoft
authentication secrets (e.g., corporate Active Directory policy that specifies minimum requirements for
management interfaces, key generation, password length, complexity, and expiry.
remote access, segregation of duties,
emergency access, large-scale Accounts for Office 365 personnel are managed through Microsoft’s corporate
provisioning or geographically- Active Directory. Security group membership must be approved by the designated
distributed deployments, and personnel security group owners within Office 365. Office 365 has implemented multifactor
redundancy for critical systems) authentication for all network access by Office 365 personnel through the use of
• Access segmentation to sessions and smart cards and TPM modules. All Microsoft users connect to the system via
data in multi-tenant architectures by Terminal Server Gateways (TSGs) and the TSGs require the user to present a
any third party (e.g., provider and/or certificate bound to the card (something you have) with a PIN (something you
other customer (tenant)) know).
• Identity trust verification and service-to-
service application (API) and information In the case of a terminating user, automated procedures are in place to disable the
processing interoperability (e.g., SSO user’s Active Directory accounts upon termination. Accounts with access to
and federation) Office 365 are also disabled after 90 days of inactivity.
• Account credential lifecycle
management from instantiation through
revocation
• Account credential and/or identity store
minimization or re-use when feasible
• Authentication, authorization, and
accounting (AAA) rules for access to
data and sessions (e.g., encryption and
strong/multi-factor, expireable, non-
shared authentication secrets)
• Permissions and supporting capabilities
for customer (tenant) controls over
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CCM Control Domain CCM v3.0.1 Control Specification Office 365 Response
and ID
authentication, authorization, and
accounting (AAA) rules for access to
data and sessions
Adherence to applicable legal, statutory,
or regulatory compliance requirements
Identity & Access User access to diagnostic and configuration Access control policy is a component of overall policies and undergoes a formal
Management ports shall be restricted to authorized review and update process. Access to Office 365 assets is granted based upon
Diagnostic / individuals and applications. business requirements and with the asset owner’s authorization.
Configuration Ports
Access Additionally:
The Microsoft MCIO team controls physical access to diagnostic and configuration
ports through physical datacenter controls. Diagnostic and configuration ports are
only accessible by arrangement between service and asset owners, and hardware
and software support personnel requiring access. Ports, services, and similar
facilities installed on a computer or network facility, which are not specifically
required for business functionality, are disabled or removed.
Identity & Access Policies and procedures shall be established In support of the Access Control requirements in the Information Security Policy,
Management to store and manage identity information Office 365 maintains Active Directory deployments for identifying and
Policies and about every person who accesses IT authenticating Microsoft users in the environment. Office 365 personnel accessing
Procedures infrastructure and to determine their level of the Office 365 system are uniquely identified by their Active Directory username
access. Policies shall also be developed to and authenticate using two-factor authentication. Active Directory strictly enforces
IAM-04 control access to network resources based unique identifiers and logs activities attempted and executed by each user.
on user identity.
Identity & Access User access policies and procedures shall be In support of the Information Security Policy, Office 365 service teams defined roles
Management established, and supporting business as part of a comprehensive RBAC access model. Each service team has identified
Segregation of Duties processes and technical measures roles that, if shared by a single person, would allow for malicious activity without
implemented, for restricting user access as collusion. When such role pairs exist, no individual is allowed to belong to both
IAM-05 per defined segregation of duties to address roles. Account permissions and role access are reviewed as part of an annual
business risks associated with a user-role account review process.
conflict of interest.
Identity & Access Access to the organization's own developed Access to Office 365 source code libraries is limited to authorized personnel. Source
Management applications, program, or object source code libraries enforce control over changes to source code by requiring a review
Source Code Access code, or any other form of intellectual from designated Office 365 staff prior to code check-in. An audit log detailing
Restriction property (IP), and use of proprietary modifications to the source code library is maintained.
software shall be appropriately restricted
IAM-06 following the rule of least privilege based on
job function as per established user access
policies and procedures.
Identity & Access The identification, assessment, and Identification, assessment, and prioritization of risks related to external parties and
Management prioritization of risks posed by business access controls is performed as part of the Office 365 risk management program
Third Party Access processes requiring third-party access to the and verified as part of the ISO 27001 audit. Third party security and privacy
organization's information systems and data requirements are established through vendor due-diligence reviews, conducted by
IAM-07 shall be followed by coordinated the designated Office 365 manager, and included in signed contractual agreements
application of resources to minimize, prior to engaging in third party services. The engaging team within Office 365 is
monitor, and measure likelihood and impact responsible for managing their third party relationships, including contract
of unauthorized or inappropriate access. management, monitoring of metrics such as service level agreements, and vendor
Compensating controls derived from the risk access to relevant applications.
analysis shall be implemented prior to
provisioning access.
Identity & Access Policies and procedures are established for Office 365 uses Active Directory to manage staff user accounts. Security group
Management permissible storage and access of identities membership must be approved by the designated security group owners within
Trusted Sources used for authentication to ensure identities Office 365. Automated procedures are in place to disable staff Active Directory
are only accessible based on rules of least accounts when staff users are terminated. Staff user accounts are disabled after 90
IAM-08 privilege and replication limitation only to days of inactivity. Office 365 service teams employ the concept of least privilege,
users explicitly defined as business allowing only authorized accesses for service team users that are necessary to
necessary.
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accomplish assigned tasks in accordance with business functions and organizational
need.
Identity & Access Provisioning user access (e.g., employees, Office 365 uses Active Directory to manage and provision user accounts. Security
Management contractors, customers (tenants), business group membership must be approved by the designated security group owners
User Access partners and/or supplier relationships) to within Office 365. Automated procedures are in place to disable Active Directory
Authorization data and organizationally-owned or accounts upon the user's leave date. Domain-level user accounts are disabled after
managed (physical and virtual) applications, 90 days of inactivity.
IAM-09 infrastructure systems, and network
components shall be authorized by the Strong authentication, including the use of multi-factor authentication, helps limit
organization's management prior to access access to customer data to authorized personnel only. Sample audits are performed
being granted and appropriately restricted by both Microsoft and third parties to attest that access is only for appropriate
as per established policies and procedures. business purposes. When access is granted, it is carefully controlled and logged, and
Upon request, provider shall inform revoked as soon as it is no longer needed.
customer (tenant) of this user access,
especially if customer (tenant) data is used The operational processes and controls that govern access and use of customer
as part the service and/or customer (tenant) data in Office 365 are rigorously maintained and regularly verified by independent
has some shared responsibility over auditors.
implementation of control.
Identity & Access User access shall be authorized and The Information Security Policy requires that access to Office 365 assets be granted
Management revalidated for entitlement appropriateness, based on business justification, with the asset owner's authorization and limited
User Access Reviews at planned intervals, by the organization's based on "need-to-know" and "least-privilege" principles. In addition, the policy also
business leadership or other accountable addresses requirements for access management lifecycle including access
IAM-10 business role or function supported by provisioning, authentication, access authorization, removal of access rights and
evidence to demonstrate the organization is periodic access reviews. Managers and owners of applications and data are
adhering to the rule of least privilege based responsible for reviewing who has access on a periodic basis.
on job function. For identified access
violations, remediation must follow Customers control access of their users and are responsible for ensuring
established user access policies and appropriate review of such access.
procedures.
Identity & Access Timely de-provisioning (revocation or Designated security group owners within Office 365 are responsible for reviewing
Management modification) of user access to data and appropriateness of employee access to applications and data on a regular basis.
User Access organizationally-owned or managed Regular access review audits occur to validate appropriate access provisioning has
Revocation (physical and virtual) applications, taken place. Access is modified based on the results of this review.
infrastructure systems, and network
IAM-11 components, shall be implemented as per Membership in security groups must be approved by security group owners. In case
established policies and procedures and of a user who changes roles and no longer works within Office 365, their account is
based on user's change in status (e.g., removed from any security groups that have access to Office 365 services.
termination of employment or other
business relationship, job change or In the case of user termination, automated procedures are in place to disable a
transfer). Upon request, provider shall user’s Active Directory account when a user is terminated.
inform customer (tenant) of these changes,
especially if customer (tenant) data is used
as part the service and/or customer (tenant)
has some shared responsibility over
implementation of control.
Identity & Access Internal corporate or customer (tenant) user Microsoft does not manage any customer (tenant) accounts or access control.
Management account credentials shall be restricted as per Office 365 provides customers with the necessary tools and features to control their
User ID Credentials the following, ensuring appropriate identity, own accounts and perform their own identity management.
entitlement, and access management and in
IAM-12 accordance with established policies and Customers are responsible for keeping customer passwords from being disclosed to
procedures: unauthorized parties and for choosing passwords with sufficient entropy as to be
• Identity trust verification and service-to- effectively non-guessable and for deployment of services such as multi-factor
service application (API) and information authentication.
processing interoperability (e.g., SSO
and Federation) As for Microsoft corporate accounts that have access to Office 365, Microsoft
• Account credential lifecycle maintains Active Directory deployments for identifying and authenticating Microsoft
management from instantiation through users in the environment. Office 365 personnel accessing the Office 365 system are
revocation uniquely identified by their Active Directory username and authenticate using two-
• Account credential and/or identity store factor authentication. Active Directory strictly enforces unique identifiers and logs
minimization or re-use when feasible activities attempted and executed by each user.
• Adherence to industry acceptable and/or
regulatory compliant authentication,
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authorization, and accounting (AAA) In the case of a terminated user, automated procedures are in place to disable the
rules (e.g., strong/multi-factor, user’s Active Directory accounts upon termination. Microsoft staff accounts with
expireable, non-shared authentication access to Office 365 are disabled after 90 days of inactivity.
secrets)
Office 365 has configured Active Directory to ensure that authenticators must
comply with Windows strong password requirements and meet certain password
length requirements. In addition, Windows strong passwords must contain
characters from at least three of these four:
• English lowercase
• English uppercase
• Numbers (0-9)
• Special characters
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Interoperability & The provider shall use open and published Office 365 supports a set of API’s to allow customers to access Office 365 data
Portability APIs to ensure support for interoperability including their mail, calendars, contacts, files, and folders.
APIs between components and to facilitate
migrating applications. For more information regarding Office 365 API’s please see the Office 365 APIs
IPY-01 Platform Overview.
Interoperability & All structured and unstructured data shall Customers can access their data at any time and for any reason without assistance
Portability be available to the customer and provided from Microsoft. Microsoft will use customer data only to provide the services agreed
Data Request to them upon request in an industry- upon, including purposes that are compatible with providing those services.
standard format (e.g., .doc, .xls, .pdf, logs,
IPY-02 and flat files) Office 365 provides authenticated and logged access to customer data which
restricts access to it by Microsoft personnel and subcontractors. We also take strong
steps to protect your customer data from inappropriate use or loss, and to segregate
customer data on shared hardware from that of other customers.
Interoperability & Policies, procedures, and mutually-agreed Office 365 supports a set of API’s to allow customers to access Office 365 data
Portability upon provisions and/or terms shall be including their mail, calendars, contacts, files, and folders.
Policy & Legal established to satisfy customer (tenant)
requirements for service-to-service For more information regarding Office 365 API’s please see the Office 365 APIs
IPY-03 application (API) and information Platform Overview.
processing interoperability, and portability
for application development and
information exchange, usage, and integrity
persistence.
Interoperability & The provider shall use secure (e.g., non- Customers are responsible for ensuring a secure connection to the Office 365 system
Portability clear text and authenticated) standardized for the purpose of importing and exporting data. For an overview of the Office 365
Standardized network protocols for the import and APIs platform please see the Office 365 APIs Platform Overview.
Network Protocols export of data and to manage the service,
and shall make available a document to
IPY-04 consumers (tenants) detailing the relevant
interoperability and portability standards
that are involved.
Interoperability & The provider shall use an industry- Office 365 uses both physical servers and virtualized servers. Virtualized servers use
Portability recognized virtualization platform and industry-standard Microsoft virtualization technologies. This includes the use of
Virtualization standard virtualization formats (e.g., OVF) Microsoft Azure which employs virtual servers leveraged by Office 365. For more
to help ensure interoperability, and shall information, see Microsoft Azure Virtual Machines.
IPY-05 have documented custom changes made to
any hypervisor in use and all solution-
specific virtualization hooks available for
customer review.
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Infrastructure & Higher levels of assurance are required for Office 365 uses monitoring agents to verify that audit logs are being generated and
Virtualization Security protection, retention, and lifecycle being uploaded to a centralized log monitoring service. Audit processing failures
Audit Logging / management of audit logs, adhering to generate alerts that are reported to Service Engineer Operations personnel and
Intrusion Detection applicable legal, statutory or regulatory escalated to Office 365 Security as appropriate.
compliance obligations and providing
IVS-01 unique user access accountability to detect Audit logs are retained in accordance with the Office 365 Data Handling Standard,
potentially suspicious network behaviors and access is restricted to staff that have a business need to access the logs. Audit
and/or file integrity anomalies, and to log access is reviewed on a regular basis to ensure access is necessary.
support forensic investigative capabilities in
the event of a security breach.
Infrastructure & The provider shall ensure the integrity of all Each OS is deployed via a “Base Image” that is constructed through a formal build
Virtualization Security virtual machine images at all times. Any process. Each base image is built upon an OS version in which the kernel, and many
Change Detection changes made to virtual machine images other core components, have been modified and optimized to support the
must be logged and an alert raised Office 365 environment.
IVS-02 regardless of their running state (e.g.
dormant, off, or running). The results of a Virtual machines that are used within Office 365 have logging, monitoring, and
change or move of an image and the alerting enabled such that unauthorized changes generate alerts which are
subsequent validation of the image's followed up on by the service teams and Office 365 Security as necessary.
integrity must be immediately available to
customers through electronic methods (e.g. All changes to the baseline images are approved through a formal approval process
portals or alerts). and the baselines are routinely reviewed to assure integrity of the builds.
Infrastructure & A reliable and mutually agreed upon All Office 365 servers regularly synchronize time from MCIO or NIST time servers.
Virtualization Security external time source shall be used to The MCIO time servers are NTP Stratum 1 time servers that synchronize off of the
Clock Synchronization synchronize the system clocks of all relevant Global Positioning System satellites. MCIO and NIST both manage multiple NTP time
information processing systems to facilitate servers in separated geographic locations.
IVS-03 tracing and reconstitution of activity
timelines.
Infrastructure & The availability, quality, and adequate Office 365 service teams include capacity planning as a key feature of their
Virtualization Security capacity and resources shall be planned, datacenter models and data replication plans to ensure that there is sufficient
Information System prepared, and measured to deliver the capacity for information processing, telecommunications, and environmental
Documentation required system performance in accordance support. Capacity is reviewed at least monthly.
with legal, statutory, and regulatory
IVS-04 compliance obligations. Projections of
future capacity requirements shall be made
to mitigate the risk of system overload.
Infrastructure & Implementers shall ensure that the security Procedures have been established and implemented to regularly scan for
Virtualization Security vulnerability assessment vulnerabilities on all virtual and non-virtual assets. Vulnerability scanning is
Management - tools or services accommodate the performed on server operating systems, databases, and network devices with the
Vulnerability virtualization technologies used (e.g. appropriate vulnerability scanning tools. The vulnerability scans are performed on a
Management virtualization aware). quarterly basis at a minimum. Office 365 contracts with independent assessors to
perform penetration testing of the Office 365 boundary. Internal Office 365 Red
IVS-05 Team versus Blue Team exercises are also routinely performed and results used to
make security improvements.
Infrastructure & Network environments and virtual instances Firewall rules and access control lists (ACL) are documented and reviewed on at
Virtualization Security shall be designed and configured to restrict least a quarterly basis. Changes are required to follow the approved firewall rule
Network Security and monitor traffic between trusted and change control process.
untrusted connections. These configurations
IVS-06 shall be reviewed at least annually, and Traffic flow policies are implemented on boundary protection devices that deny
supported by a documented justification for traffic by default. These policies are reviewed every month to determine if any
use for all allowed services, protocols, and changes are required.
ports, and by compensating controls.
Infrastructure & Each operating system shall be hardened to The Office 365 team leverages United States Government Configuration Baseline
Virtualization Security provide only necessary ports, protocols, and (USGCB) and Center for Internet Security (CIS) Benchmarks in the development of
OS Hardening and services to meet business needs and have in their base images. Operating system images are hardened restricting services, ports
Base Controls place supporting technical controls such as: and protocols to the minimum set necessary for business functionality.
antivirus, file integrity monitoring, and
IVS-07 logging as part of their baseline operating The use of anti-malware software is a principal mechanism for protection of
build standard or template. Office 365 assets from malicious software. The anti-malware software detects and
prevents the introduction of computer viruses, malware, rootkits, worms, and other
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malicious software onto the service systems. Anti-malware software provides both
preventive and detective control over malicious software. Anti-malware software is
installed as part of the initial build on all systems.
Infrastructure & Production and non-production For the Office 365 infrastructure, production and non-production environments are
Virtualization Security environments shall be separated to prevent both physically and logically separated. Office 365 employs network-based and
Production / Non- unauthorized access or changes to host-based boundary protection devices such as firewalls, load balancers, IP Filters,
Production information assets. Separation of the and front-end components to achieve this logical separation. Additionally, access to
Environments environments may include: stateful both environments is controlled using Role Based Access Controls so that only
inspection firewalls, domain/realm authorized personnel may logically access the intended environment. All access to
IVS-08 authentication sources, and clear the production environment requires multi-factor authentication.
segregation of duties for personnel
accessing these environments as part of
their job duties.
Infrastructure & Multi-tenant organizationally-owned or Multiple forms of protection have been implemented throughout Office 365 to
Virtualization Security managed (physical and virtual) applications, prevent customers from compromising Office 365 services or applications or
Segmentation and infrastructure system and network gaining unauthorized access to the information of other tenants or the Office 365
components, shall be designed, developed, system itself:
IVS-09 deployed and configured such that provider Logical isolation of tenant data for all Office 365 workloads is achieved
and customer (tenant) user access is through Azure Active Directory authorization and role-based access control.
appropriately segmented from other tenant SharePoint Online provides data isolation mechanisms at the storage level.
users, based on the following Office 365 also uses rigorous physical security, background screening, and a
considerations: multi-layered encryption strategy to protect the confidentiality and integrity
• Established policies and procedures of customer data.
• Isolation of business critical assets o All Office 365 and datacenters have biometric access controls, with
and/or sensitive user data, and sessions the majority of the datacenters used to provide Office 365
that mandate stronger internal controls requiring palm prints to gain physical access, and all U.S.-based
and high levels of assurance Microsoft employees are required to successfully complete a
• Compliance with legal, statutory and standard background check as part of the hiring process. For more
regulatory compliance obligations information on data access security measures, see Administrative
Access.
o Office 365 uses service-side technologies that encrypt customer
data at rest and in transit. For customer data at rest, Office 365
uses volume-level and file-level encryption. For customer data in-
transit, Office 365 uses multiple encryption technologies for
communications between datacenters and between clients and
servers, such as Transport Layer Security (TLS), and Internet
Protocol Security (IPsec). For specific details on the encryption
mechanisms used throughout Office 365, see Data Encryption
Technologies in Office 365, available from the STP.
Together, these protections provide robust logical isolation controls that provides
equivalent threat protection and mitigation to that provided by physical isolation
alone.
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communications to the administrative
consoles).
Infrastructure & Policies and procedures shall be established, Office 365 does not permit or allow wireless connections in the Office 365 network
Virtualization Security and supporting business processes and environment.
Wireless Security technical measures implemented, to protect
wireless network environments, including
IVS-12 the following:
• Perimeter firewalls implemented and
configured to restrict unauthorized
traffic
• Security settings enabled with strong
encryption for authentication and
transmission, replacing vendor default
settings (e.g., encryption keys,
passwords, and SNMP community
strings)
• User access to wireless network devices
restricted to authorized personnel
• The capability to detect the presence of
unauthorized (rogue) wireless network
devices for a timely disconnect from the
network
Infrastructure & Network architecture diagrams shall clearly Internal Office 365 data flow diagrams clearly define boundaries and data flows
Virtualization Security identify high-risk environments and data between zones having different data classification, trust levels, or compliance and
Network Architecture flows that may have legal compliance regulatory requirements.
impacts. Technical measures shall be
IVS-13 implemented and shall apply defense-in- Communication channels are logically or physically isolated from other networks.
depth techniques (e.g., deep packet Customer information is encrypted during transmission over external networks.
analysis, traffic throttling, and black-holing)
for detection and timely response to Network filtering is implemented to prevent spoofed traffic and restrict incoming
network-based attacks associated with and outgoing traffic to trusted platform components.
anomalous ingress or egress traffic patterns
(e.g., MAC spoofing and ARP poisoning Office 365 sits behind load balancers and traffic filters to control the flow of traffic.
attacks) and/or distributed denial-of-service Additionally, Office 365 has established automated controls to monitor and detect
(DDoS) attacks. internally initiated denial of service attacks. For more information about how
Microsoft protects Office 365 from denial of service attacks, see Defending Office
365 Against Distributed Denial of Service Attacks, available for download from the
STP.
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Mobile Security Anti-malware awareness training, specific to Mobile and wireless devices are not permitted within Microsoft datacenters where
Anti-Malware mobile devices, shall be included in the customer data is stored. Wireless access to Office 365 production and customer
provider's information security awareness environments is prohibited.
MOS-01 training.
Mobile Security The company shall have a documented policy See response to MOS-01.
Approved prohibiting the installation of non-approved
Applications applications or approved applications not
obtained through a pre-identified application
MOS-03 store.
Mobile Security The BYOD policy and supporting awareness See response to MOS-01.
Approved Software training clearly states the approved
for BYOD applications, application stores, and
application extensions and plugins that may
MOS-04 be used for BYOD usage.
Mobile Security The provider shall have a documented See response to MOS-01.
Awareness and mobile device policy that includes a
Training documented definition for mobile devices
and the acceptable usage and requirements
MOS-05 for all mobile devices. The provider shall post
and communicate the policy and
requirements through the company's
security awareness and training program.
Mobile Security All cloud-based services used by the See response to MOS-01.
Cloud Based Services company's mobile devices or BYOD shall be
pre-approved for usage and the storage of
MOS-06 company business data.
Mobile Security The company shall have a documented See response to MOS-01.
Compatibility application validation process to test for
mobile device, operating system, and
MOS-07 application compatibility issues.
Mobile Security The BYOD policy shall define the device and See response to MOS-01.
Device Eligibility eligibility requirements to allow for BYOD
usage.
MOS-08
Mobile Security An inventory of all mobile devices used to See response to MOS-01.
Device Inventory store and access company data shall be kept
and maintained. All changes to the status of
MOS-09 these devices (i.e., operating system and
patch levels, lost or decommissioned status,
and to whom the device is assigned or
approved for usage (BYOD)) will be included
for each device in the inventory.
Mobile Security A centralized, mobile device management See response to MOS-01.
Device Management solution shall be deployed to all mobile
devices permitted to store, transmit, or
MOS-10 process customer data.
Mobile Security The mobile device policy shall require the use See response to MOS-01.
Encryption of encryption either for the entire device or
for data identified as sensitive on all mobile
MOS-11 devices and shall be enforced through
technology controls.
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Mobile Security The mobile device policy shall prohibit the See response to MOS-01.
Jailbreaking and circumvention of built-in security controls on
Rooting mobile devices (e.g. jailbreaking or rooting)
and shall enforce the prohibition through
MOS-12 detective and preventative controls on the
device or through a centralized device
management system (e.g. mobile device
management).
Mobile Security The BYOD policy includes clarifying language See response to MOS-01.
Legal for the expectation of privacy, requirements
for litigation, e-discovery, and legal holds.
MOS-13 The BYOD policy shall clearly state the
expectations regarding the loss of non-
company data in the case a wipe of the
device is required.
Mobile Security BYOD and/or company-owned devices are See response to MOS-01.
Lockout Screen configured to require an automatic lockout
screen, and the requirement shall be
MOS-14 enforced through technical controls.
Mobile Security Changes to mobile device operating systems, See response to MOS-01.
Operating Systems patch levels, and/or applications shall be
managed through the company's change
MOS-15 management processes.
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Security Incident Points of contact for applicable regulation Office 365 has designated responsibilities and established processes to maintain
Management, E- authorities, national and local law contacts with external authorities across the jurisdictions in which it operates.
Discovery & Cloud enforcement, and other legal jurisdictional
Forensics authorities shall be maintained and
Contact / Authority regularly updated (e.g., change in impacted-
Maintenance scope and/or a change in any compliance
obligation) to ensure direct compliance
SEF-01 liaisons have been established and to be
prepared for a forensic investigation
requiring rapid engagement with law
enforcement.
Security Incident Policies and procedures shall be established, Policies and procedures are authorized by management which support a tiered
Management, E- and supporting business processes and triage model of security related events. Potential security issues are investigated
Discovery & Cloud technical measures implemented, to triage and escalated as appropriate in accordance with the internal Office 365 Security
Forensics security-related events and ensure timely Incident Response plan.
Incident and thorough incident management, as per
Management established IT service management policies
and procedures.
SEF-02
Security Incident Workforce personnel and external business Microsoft Rules of Behavior describes Microsoft users’ responsibilities and
Management, E- relationships shall be informed of their establishes expected behavior when using Office 365 and other Microsoft systems.
Discovery & Cloud responsibilities and, if required, shall All Microsoft users, including employees, vendors, and contractors are required to
Forensics consent and/or contractually agree to report follow the rules of behavior, which are outlined in the Rules of Behavior agreement.
Incident Reporting all information security events in a timely The agreements set expectations about proper use of the system and include
manner. Information security events shall be requirements that staff report security events in a timely manner.
SEF-03 reported through predefined
communications channels in a timely
manner adhering to applicable legal,
statutory, or regulatory compliance
obligations.
Security Incident Proper forensic procedures, including chain In the event a follow-up action concerning a person or organization after an
Management, E- of custody, are required for the presentation information security incident requires legal action, proper forensic procedures
Discovery & Cloud of evidence to support potential legal action including chain of custody shall be required for preservation and presentation of
Forensics subject to the relevant jurisdiction after an evidence to support potential legal action subject to the relevant jurisdiction. Upon
Incident Response information security incident. Upon notification of a security breach, impacted customers (tenants) and other external
Legal Preparation notification, customers and/or other business relationships shall be given the opportunity to participate as is legally
external business partners impacted by a permissible in the forensic investigation.
SEF-04 security breach shall be given the
opportunity to participate as is legally Security incident response plans and collection of evidence adheres to ISO 27001
permissible in the forensic investigation. standards. Office 365 has established processes for evidence collection and
preservation for troubleshooting an incident and analyzing the root cause. In case a
security incident involves legal action such as subpoena form, the guidelines
described in the trouble shooting guide are followed.
Security Incident Mechanisms shall be put in place to monitor An incident management framework has been established and communicated with
Management, E- and quantify the types, volumes, and costs defined processes, roles and responsibilities for the detection, escalation and
Discovery & Cloud of information security incidents. response of incidents. Incident management teams perform constant monitoring,
Forensics including documentation, classification, escalation, and coordination of incidents
Incident Response per documented procedures. Events, thresholds and metrics have been defined and
Metrics configured to detect incidents and alert the appropriate Office 365 teams and
management.
SEF-05
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Supply Chain Providers shall inspect, account for, and Microsoft requires all third parties (external information system services) who are
Management, work with their cloud supply-chain partners engaged with Office 365 to sign a MSSA. The MSSA requires the third party to
Transparency and to correct data quality errors and associated comply with all applicable Microsoft security policies and implement security
Accountability risks. Providers shall design and implement procedures to prevent disclosure of confidential Microsoft information. Microsoft
Data Quality and controls to mitigate and contain data includes provisions in the MSSA and any associated Statements of Work (SOW) with
Integrity security risks through proper separation of each vendor addressing the need to employ appropriate security controls. Vendors
duties, role-based access, and least-privilege that handle sensitive data must be in compliance with Microsoft vendor privacy
STA-01 access for all personnel within their supply practices and data protection requirements.
chain.
Supply Chain The provider shall make security incident The Office 365 process for managing a security incident conforms to the approach
Management, information available to all affected prescribed by NIST 800-61. Microsoft’s security incident response includes several
Transparency and customers and providers periodically dedicated teams that work together to prevent, monitor, detect, and respond to
Accountability through electronic methods (e.g. portals). security incidents.
Incident Reporting
Office 365 maintains and notifies customers of potential changes and events that
STA-02 may affect security or availability of the services through an online Service
Dashboard. Service health information is available at any time by signing into Office
365. Changes to the security commitments and security obligations of Office 365
customers are updated on the Office 365 website in a timely manner.
For more information, see Office 365 Security Incident Management, available for
download from the STP.
Supply Chain Business-critical or customer (tenant) Office 365 employs sophisticated software-defined service instrumentation and
Management, impacting (physical and virtual) application monitoring that integrates at the component or server level, the datacenter edge,
Transparency and and system-system interface (API) designs our network backbone, Internet exchange sites, and at the real or simulated user
Accountability and configurations, and infrastructure level, providing visibility when a service disruption is occurring and pinpointing its
Network / network and systems components, shall be cause.
Infrastructure designed, developed, and deployed in
Services accordance with mutually agreed-upon Proactive monitoring continuously measures the performance of key subsystems of
service and capacity-level expectations, as the Office 365 services platform against the established boundaries for acceptable
STA-03 well as IT governance and service service performance and availability. When a threshold is reached or an irregular
management policies and procedures. event occurs, the monitoring system generates warnings so that operations staff
can address the threshold or event.
Supply Chain The provider shall perform annual internal Office 365 performs risk assessments of its environment to review the effectiveness
Management, assessments of conformance to, and of information security controls and safeguards, as well as to identify new risks. The
Transparency and effectiveness of, its policies, procedures, and risks are assessed annually and the results of the risk assessment are presented to
Accountability supporting measures and metrics. management through a formal risk assessment report. Supplier scorecards have
Provider Internal been developed to allow comparison and visibly monitor the performance of our
Assessments suppliers using a balanced scorecard approach.
STA-04
Supply Chain Supply chain agreements (e.g., SLAs) Third party security and privacy requirements are established through vendor due-
Management, between providers and customers (tenants) diligence reviews, conducted by the designated Office 365 manager, and included in
Transparency and shall incorporate at least the following signed contractual agreements prior to engaging in third party services. The
Accountability mutually-agreed upon provisions and/or engaging team within Office 365 is responsible for managing their third party
Supply Chain terms: relationships, including contract management, monitoring of metrics such as service
Agreements • Scope of business relationship and level agreements, and vendor access to relevant applications.
services offered (e.g., customer (tenant)
STA-05 data acquisition, exchange and usage,
feature sets and functionality, personnel
and infrastructure network and systems
components for service delivery and
support, roles and responsibilities of
provider and customer (tenant) and any
subcontracted or outsourced business
relationships, physical geographical
location of hosted services, and any
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known regulatory compliance
considerations)
• Information security requirements,
provider and customer (tenant) primary
points of contact for the duration of the
business relationship, and references to
detailed supporting and relevant
business processes and technical
measures implemented to enable
effectively governance, risk
management, assurance and legal,
statutory and regulatory compliance
obligations by all impacted business
relationships
• Notification and/or pre-authorization of
any changes controlled by the provider
with customer (tenant) impacts
• Timely notification of a security incident
(or confirmed breach) to all customers
(tenants) and other business
relationships impacted (i.e., up- and
down-stream impacted supply chain)
• Assessment and independent
verification of compliance with
agreement provisions and/or terms
(e.g., industry-acceptable certification,
attestation audit
• report, or equivalent forms of assurance)
without posing an unacceptable
business risk of exposure to the
organization being assessed
• Expiration of the business relationship
and treatment of customer (tenant)
data impacted
• Customer (tenant) service-to-service
application (API) and data
interoperability and portability
requirements for application
development and information exchange,
usage, and integrity persistence
Supply Chain Providers shall review the risk management Security risks related to external parties, such as customers, contractors and
Management, and governance processes of their partners vendors are identified and addressed through the following:
Transparency and so that practices are consistent and aligned 1. Customer risks are assessed in coordination with Microsoft’s in-house
Accountability to account for risks inherited from other legal department (known as Corporate, External, and Legal Affairs (CELA))
Supply Chain members of that partner's cloud supply and appropriate customer agreements are established.
Governance Reviews chain. 2. Third parties undergo a review process through Global Procurement and
an approved vendor list has been established. Purchase orders to engage
STA-06 a third-party require a MSSA to be established or a review to be
performed by CELA. Vendors requiring access to source code need to be
approved by the GM and CELA, and sign a Source Code Licensing
Agreement.
3. Additional risks related to granting access to facilities and information systems
are controlled and managed by Microsoft internal IT. Physical and network
security for offsite vendor facilities are governed by Microsoft.
Supply Chain Policies and procedures shall be Office 365 has established procedures and designated responsibilities for managing
Management, implemented to ensure the consistent changes to third-party services. Office 365 has designated teams that manage third-
Transparency and review of service agreements (e.g., SLAs) party relationships including contract management, monitoring metrics such as
Accountability between providers and customers (tenants) service-level agreements, and third party access to systems, in accordance with
Supply Chain Metrics across the relevant supply chain these procedures as well as corporate-wide third party management processes.
(upstream/downstream). Reviews shall be
STA-07 performed at least annually and identify any The services provided by third-party vendors are monitored against the service
non-conformance to established levels by designated responsible persons in Office 365, as defined in the SOW.
agreements. The reviews should result in Procedures for monitoring breaches to contractual obligations and handling issues
actions to address service-level conflicts or with vendors are established.
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inconsistencies resulting from disparate
supplier relationships.
Supply Chain Providers shall assure reasonable Office 365 contractually requires that its subcontractors meet important privacy and
Management, information security across their information security requirements. Requirements and contracts are reviewed at least annually
Transparency and supply chain by performing an annual or as renewed.
Accountability review. The review shall include all
Third Party partners/third party-providers upon which
Assessment their information supply chain depends on.
STA-08
Supply Chain Third-party service providers shall The services provided by third-party vendors are monitored against the service
Management, demonstrate compliance with information levels by designated responsible persons from Office 365 and contractually requires
Transparency and security and confidentiality, access control, that its subcontractors meet important privacy and security requirements. Third
Accountability service definitions, and delivery level party service providers are routinely audited by both Microsoft and independent
Third Party Audits agreements included in third-party audit teams.
contracts. Third-party reports, records, and
STA-09 services shall undergo audit and review at
least annually to govern and maintain
compliance with the service delivery
agreements.
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Threat and Policies and procedures shall be established, In support of the Information Security Policy, Office 365 runs multiple layers of anti-
Vulnerability and supporting business processes and virus software to ensure protection from common malicious software. Servers
Management technical measures implemented, to prevent within the Office 365 environment run anti-virus software that scans files uploaded
Anti-Virus / Malicious the execution of malware on and downloaded from the service for viruses or other malware. Additionally, all
Software organizationally-owned or managed user mails coming into the service run through the Exchange Online Protection engine,
end-point devices (i.e., issued workstations, which uses multiple antivirus and antispam engines to capture known and new
TVM-01 laptops, and mobile devices) and IT threats against the system.
infrastructure network and systems
components. Additional information may be found in the relevant service descriptions and
Service Level Agreement (SLA).
Microsoft has its own Security Response Center (MSRC) that also supplies
information to all our customers covering the whole range Microsoft products.
More information can be found at the Security TechCenter MSRC page.
Threat and Policies and procedures shall be established, Office 365 implements technologies to routinely scan the environment for
Vulnerability and supporting processes and technical vulnerabilities. Additionally, Office 365 contracts with external penetration testers
Management measures implemented, for timely detection who routinely scan the Office 365 system. Identified vulnerabilities are tracked, and
Vulnerability / Patch of vulnerabilities within organizationally- verified for remediation. In addition, regular vulnerability and penetration
Management owned or managed applications, assessments are performed to identify vulnerabilities and determine whether key
infrastructure network and system logical controls are operating effectively.
TVM-02 components (e.g. network vulnerability
assessment, penetration testing) to ensure The MSRC regularly monitors external security vulnerability awareness sites. As
the efficiency of implemented security part of the routine vulnerability management process, Office 365 evaluates our
controls. A risk-based model for prioritizing exposure to these vulnerabilities and leads action across Office 365 to mitigate risks
remediation of identified vulnerabilities shall when necessary.
be used. Changes shall be managed through
a change management process for all Per best practice, Microsoft has full, robust patch management systems that are
vendor-supplied patches, configuration audited and tracked regularly by management. Any issues or requested exceptions
changes, or changes to the organization's would require management approval to address. This process is included in the
internally developed software. Upon request, ongoing audit schedule.
the provider informs customer (tenant) of
policies and procedures and identified
weaknesses especially if customer (tenant)
data is used as part the service and/or
customer (tenant) has some shared
responsibility over implementation of
control.
Threat and Policies and procedures shall be established, The use of mobile code in Office 365 applications is reviewed during multiple
Vulnerability and supporting business processes and phases of the SDL process. The SDL policy documents the usage restrictions and
Management technical measures implemented, to prevent implementation guidance on mobile technologies such as ActiveX, Flash, Silverlight,
Mobile Code the execution of unauthorized mobile code, and JavaScript. It also lists the outdated technologies that are not permitted in
defined as software transferred between Office 365.
TVM-03 systems over a trusted or untrusted network
and executed on a local system without
explicit installation or execution by the
recipient, on organizationally-owned or
managed user end-point devices (e.g., issued
workstations, laptops, and mobile devices)
and IT infrastructure network and systems
components.