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Back to the Data Processing Agreement

22 février 2025

Annex 2 to the Data Processing Agreement

List of Technical and Organizational Measures (TOM)

Place of Data Processing

Besides the registered office of Threema in 8808 Pfäffikon SZ (municipality of Freienbach), the IT systems of Threema, on which personal data is processed and, if necessary, stored, are located in two data centers of an ISO 27001-certified colocation partner in Zurich.

1. Confidentiality

1.1. Admission Control Measures

Appropriate measures to prevent unauthorized persons from gaining physical access to the IT systems of Threema on which personal data is processed:

Technical Measures Organizational Measures
Alarm system Key management
Personnel separation system Reception
Biometric admission control Visitor log
Manual locking system Visitor badges
Video surveillance Visitors accompanied by employees
Lockable server racks Employed facility management staff
Security personnel at the data center

1.2. Access Control Measures

Appropriate measures to prevent unauthorized persons from using the IT systems of Threema on which personal data is processed:

Technical Measures Organizational Measures
Use of own server hardware Permission management
No cloud solutions or shared hosting Centrally created and managed user profiles
Logins with username, strong password and two-factor or multi-factor authentication Password-protected user accounts
Access with Secure Shell (SSH) State of the art security measures for home office
Use of security tokens for one-time password (OTP) authentication Restricted group of people for the use of administrative user accounts
Firewalls
Access only via Virtual Private Network (VPN)
Encryption of data carriers, hard disks, smartphones and work computers
Automatic desktop lock

1.3. Permission Control Measures

Appropriate measures to ensure that, when using the IT systems, authorized employees of Threema can only access the personal data that is subject to their access authorization and that personal data cannot be read, copied, changed or deleted without authorization:

Technical Measures Organizational Measures
Access logging Restricted group of people for the use of administrative user accounts
Access to IT systems via SSH Limited number of administrators
Transport Layer Security (TLS) encryption Management of permissions by administrators
Use of security tokens Regular checks of permissions (permission audits)
Virtual Private Network (VPN) for remote access
State of the art cryptographic procedures

1.4. Separation Control Measures

Appropriate measures to ensure that personal data collected for different purposes can be processed logically and physically separated on the IT systems of Threema:

Technical Measures Organizational Measures
Separation of production, staging and test environments Permission management for databases
Logical separation of systems and databases Defined requirements for development environments
Multi-tenant capability for relevant applications Defined requirements for the execution of tests in software development
Virtual Local Area Network (VLAN) segmentation of networks Continuous Integration for automated testing
Logical separation of customer systems

2. Integrity

Appropriate measures to ensure that personal data cannot be read, copied, changed or deleted without authorization during its transport (“data in transit”) or storage (“data at rest”) and that it is possible to determine where personal data is transmitted to:

Technical Measures Organizational Measures
Access only via VPN Need-to-know principle
Logging of accesses and retrievals
Use of security tokens
Transport Layer Security (TLS) encryption
Encryption for storage (“data at rest”) and transport (“data in transit”)
Encrypted backups

3. Availability

3.1. Availability Control Measures

Appropriate measures to ensure that personal data on the IT systems of Threema is protected against loss or destruction:

Technical Measures Organizational Measures
Fire and smoke detectors Concept for business continuity
Fire extinguishing installations Concept for defense against Distributed Denial of Service (DDoS) attacks
Temperature and humidity monitoring at the data center Use of two data centers for redundancy
Air-conditioned server room
Measures for uninterrupted power supply in an emergency
Redundant Array of Independent Disks (RAID) system
Video surveillance
Redundant internet connection

3.2. Recovery Measures

Appropriate measures that enable Threema to quickly restore the availability of and access to personal data on its IT systems following an incident:

Technical Measures Organizational Measures
Backup monitoring Concept for data recovery
Manual data recovery Control of the backup procedure
Backups according to criticality Regular data recovery tests
Storage of encrypted backups in both data centers (redundancy)
Additional encrypted backups of certain critical data outside the data centers

4. Procedures for Reviewing, Assessing and Evaluating Effectiveness

Technical Measures Organizational Measures
Technical access for employees to compliance documents on data protection and information security Data security concept with internal rules of conduct
Regular updates of software, firewall and spam filters Defined requirements for “Privacy by Design” and “Privacy by Default”
Application of data protection-friendly default settings Defined requirements for secure software development
Monitoring remote access Avoidance of sub-processing for the processing of personal data as far as possible
Sub-processing for the processing of personal data only for non-essential functions of Threema products
Documentation of the implemented encryption in cryptography whitepaper
Regular external audits on the security of the implemented encryption
Regular internal and external audits of procedures and software