Zero Trust Network Access (ZTNA) Policy

Version: 3.2.1



This policy defines Thriveworks' Zero Trust Network Architecture (ZTNA) and outlines the identity, device, network, and application access controls that secure clinical and corporate environments across AWS, Heroku Shield, and hybrid infrastructure. It governs how access is granted, monitored, and enforced using Perimeter 81, Google Workspace, and integrated security platforms to protect sensitive data and ensure regulatory compliance.




Created:

Current Effective Approval:

05/03/2025




Logical Domain Strategy

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Policy Summary


Thriveworks' Zero Trust Network Architecture (ZTNA) Policy establishes a comprehensive and technically rigorous framework for securing access to clinical and corporate resources across its hybrid cloud infrastructure. This policy is a foundational pillar of Thriveworks' broader cybersecurity strategy and compliance posture, aligning with HIPAA, HITRUST, and the NIST Cybersecurity Framework (CSF) 2.0. It outlines how access to sensitive systems and data is governed, continuously validated, and contextually enforced using a combination of identity-aware controls, encrypted connectivity, and posture-based device verification.

At its core, the ZTNA model replaces traditional perimeter-based security with a dynamic, risk-adaptive framework that assumes breach and treats every access request as untrusted by default. The policy is enforced through the Harmony SASE platform, Perimeter 81, and Google Workspace Enterprise, enabling secure access via identity-bound sessions, always-on VPN tunnels, and browser-isolated gateways. These controls are tightly integrated with SentinelOne endpoint telemetry, SumoLogic SIEM, and Datadog observability to enable real-time monitoring, threat correlation, and automated response.

ZTNA at Thriveworks is implemented across multiple tiers of enforcement:

Federated identity and Role-Based Access Control (RBAC) are managed through Google Workspace and Workday HRIS, ensuring only verified users receive access aligned to their job function.

Device posture checks are mandatory and run continuously every 20 minutes for all active sessions, validating antivirus, encryption, agent health, and OS patch levels.

Network access is segmented by Zero Trust Networks (ZTNs), each representing an isolated trust boundary for environments like production, DevOps, and third-party testing.

Application-level access is brokered via reverse proxies and policy-based publishing models, with strict enforcement of least privilege and session isolation.

All ZTNA events and policy decisions are logged in real-time and retained for seven years. These logs feed into a unified analytics and threat detection architecture, where anomalies are correlated across user behavior, geo/IP intelligence, and endpoint status. Thriveworks partners with eSentire as a managed SOC to deliver 24/7 threat detection and incident response, with high-severity alerts triggering immediate escalation and containment workflows.

To ensure resilience, the ZTNA mesh is designed with fault tolerance and geographic redundancy, including active-active tunnel configurations and regional gateway clusters. Quarterly disaster recovery drills validate failover performance, policy recovery, and encrypted tunnel restoration, aligning operational recovery objectives with business continuity plans.

This policy not only protects regulated workloads, including electronic Protected Health Information (ePHI), but also serves as a living control framework that evolves through change management, post-incident reviews, and quarterly access audits. It affirms Thriveworks' commitment to proactive, risk-informed, and regulation-aligned security in the delivery of digital mental health services.

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Introduction

Thriveworks delivers accessible, technology-enabled mental healthcare services through a secure and scalable cloud-native infrastructure. To protect sensitive health data, ensure high availability of clinical operations, and maintain continuous regulatory compliance with frameworks such as HIPAA and NIST CSF, Thriveworks has implemented a Zero Trust Network Access (ZTNA) architecture grounded in identity-aware access controls, encrypted connectivity, and endpoint compliance enforcement.

This policy defines the ZTNA architecture and security standards used at Thriveworks to manage access between end users, internal applications, and multi-cloud environments. Our enterprise network includes:

AWS Resources

Cloud hosting EKS clusters for microservices, EC2-based SQL Server workloads, and business-critical APIs

Heroku (Shield)

Private Spaces, used for deploying regulated applications with restricted ingress policies and private networking

Harmony (SASE)

Our primary ZTNA platform, which provides secure access to internal resources via identity-bound browser sessions, Always-On VPN, and encrypted IPSec tunnels

Google Workspace (E+)

Core identity provider, MFA and Single Sign-On (SSO) authority

SumoLogic (SIEM)

Unified security solution providing logging, event correlation, and long-term retention

eSentire

SOCaaS partner which delivers 24/7 threat detection, log analysis, and incident response via integration with our endpoint and network telemetry

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Purpose and Environment

The purpose of this Zero Trust Network Access (ZTNA) Policy is to define the security architecture, control objectives, and operational enforcement mechanisms used by Thriveworks to govern access to corporate systems, clinical applications, and protected health information (PHI) across a distributed cloud infrastructure. Thriveworks operates a complex hybrid environment that includes containerized workloads in Amazon Elastic Kubernetes Service (EKS), persistent SQL databases hosted on Amazon EC2, HIPAA-aligned applications deployed in Heroku Shield Private Spaces, and SFTP integrations with external payers and partners. Ensuring that access to these systems is explicitly authorized, contextually evaluated, and continuously monitored is a foundational requirement for regulatory compliance and business continuity.

Implementation

Unlike traditional perimeter-based security models that rely on static IP whitelisting and VPN concentrators, Thriveworks implements a modern Zero Trust security posture, which assumes breach and requires dynamic authentication, continuous device validation, and segmented application-level access enforcement. This policy governs how that posture is operationalized using Perimeter 81 as the ZTNA platform, with secure connectivity extended through a combination of browser-based access, Always-On VPN clients, and site-to-site IPSec tunnels. These tunnels connect Thriveworks' ZTNA mesh to backend services in AWS Virtual Private Clouds (VPCs) and allow for direct access to backend database clusters, microservice APIs, and application orchestration layers that are otherwise isolated from the public internet.

Access Control Framework

Access decisions are rooted in identity, posture, and session context. Google Workspace serves as the central identity provider and SAML/OIDC authority, integrating directly with Perimeter 81 to enforce Single Sign-On (SSO) and Multi-Factor Authentication (MFA) for all users. Endpoint compliance is validated using Perimeter 81's device posture enforcement engine, ensuring that only corporate-managed systems with active EDR agents, disk encryption, and updated antivirus definitions are allowed to establish secure sessions. Web-based traffic is routed through geographically distributed Secure Web Gateway (SWG) nodes, where domain filtering, TLS inspection, and DLP controls are applied before allowing outbound requests to reach the open internet.

Monitoring and Response

All access activity—whether to internal applications, backend AWS services, or external web resources—is centrally logged to SumoLogic, where it is correlated with device metadata, user identity, and session behavior. These events are continuously monitored by eSentire, Thriveworks' managed Security Operations Center (SOC), which provides 24/7 threat detection, enrichment, and incident response in coordination with internal security engineering staff.

Compliance and Governance

This policy establishes a binding technical and procedural framework for managing user and system access across the enterprise. It defines the configuration standards, review processes, and enforcement models that ensure all access to internal systems is contextually validated, logged, and limited to the minimum necessary privilege, in accordance with the principles of Zero Trust and the requirements of HIPAA, HITRUST (in the future), and the NIST Cybersecurity Framework.

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System Design Methodology


ZTNA at Thriveworks is designed to eliminate implicit trust in the network and instead validate every access request dynamically. User and device access is granted only when multiple contextual signals—such as identity, endpoint posture, network location, and risk score—meet predefined policy criteria. Key pillars of our implementation include:


1. Identity

Identity Federation with RBAC and MFA via Google Workspace

2. Posturing

Device Posture Checks to ensure endpoints meet security baselines before connecting to internal, secure zero trust networks

3.Network Architecture

Split and Full Tunnel Routing via Harmony Secure Web Gateways and IPSec tunnels, connecting clinical and DevOps users to backend systems in AWS, Heroku Spaces and secure cloud resources

4. Audit & Threat

Application-level Access Control using Harmony’s private access publishing model for remote access to SQL, RDP, web, and SFTP services

5. Access Control & Policy

Application-level Access Control using Harmony’s private access publishing model for remote access to services. SWG and Internet Access Policies that filter and inspect all web traffic

This policy formally documents Thriveworks Zero Trust strategy and its operational enforcement model across all cloud platforms, networks, and access methods.

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System Design

1. Identity

Thriveworks ZTNA architecture is grounded in federated identity management that ties all access decisions to verified user identity, assigned role, and contextual risk. Google Workspace serves as the authoritative identity provider (IdP) for all employees, contractors, and service accounts across the organization. Integration with Harmony SASE ensures that all authentication events are centrally managed, enabling fine-grained control over access to networks, applications, and administrative functions.

All users authenticating through Harmony SASE are subject to enforced Single Sign-On (SSO) using Google credentials and Multi-Factor Authentication (MFA) using either hardware-based security keys (YubiKey) for IT administrators or app-based authenticators for everyone else. SSO is enforced not only at the login stage but also at the point of application access, gateway registration, and policy approval workflows.

Access entitlements are assigned using Role-Based Access Control (RBAC), with user roles derived directly from Workday HRIS attributes and synchronized to Google Workspace organizational units (OUs) and groups. These groups are mapped into Harmony SASE Member Access Groups, which control:

Network-level Access

Network-level access to backend resources via TW-AWS-Ops and end user access to full-encrypt networks Thriveworks Secure & Thriveworks Clinical

Application Access

Application-specific permissions (e.g., SQL Server RDP access, SFTP portals) - web published, non-agent based connections

Session Controls

Policy-based session controls utilizing device posture requirements

Temp access

Contractor and temporary employee access is time-bound and scoped to least-privilege by default. These accounts are provisioned via Freshservice workflows and require both business justification and managerial approval.

Termination & Offboarding

Termination or offboarding events in Workday automatically trigger de-provisioning workflows that revoke access across all systems, including Harmony, Google Workspace, and connected SaaS applications.

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1. Identity

System Design

Privileged access is tightly governed under separate administrative roles, which include additional session verification policies. Admin actions such as network configuration changes, tunnel modifications, and application publishing are logged and reviewed on a biweekly basis. Just-In-Time access may be granted through manual overrides for emergency operations, but must be documented and expire within 24 hours unless renewed.

Elevated Account Access Workflow

Thriveworks utilizes a Freshservice automation workflow to facilitate time-bound administrative access for approved users. When a user submits a service request for elevated privileges, the system verifies their membership in a pre-approved access group. If authorized, their account is temporarily elevated to an administrative role across designated systems. This access is automatically revoked after 24 hours, reverting the user to their baseline non-administrative role without requiring manual intervention. All elevation events are logged and audited to ensure accountability and compliance with least privilege principles.


To maintain integrity and compliance, quarterly access reviews are conducted across all Access Groups, in coordination with department heads and security auditors. These reviews validate:

Membership

Delivery of account membership accuracy

Job alignment

Dynamic user alignment to job function

Expiration management

Temporary user expiration management

Audit trail

Audit trail of manual resource modifications or escalations

All access data is logged to SumoLogic, correlated with endpoint identity and IP metadata, and monitored by eSentire SOC for anomalous patterns, privilege escalation attempts, or policy violations.

This section governs how Thriveworks establishes and enforces the principle of least privilege, using verified identity, system-integrated role data, and continuous session monitoring to limit access to what is necessary.

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System Design

2. Posturing

Thriveworks enforces device trust through continuous posture assessment and agent-based compliance validation as a prerequisite for all Zero Trust Network Access. This strategy ensures that only verified and healthy endpoints—meeting security baselines and running corporate-approved configurations—can access internal networks, applications, or internet gateways via Perimeter 81.

Posture validation begins prior to tunnel initiation or application access. Harmony's native posture engine runs checks at two critical intervals: upon connection attempt, and every 20 minutes thereafter while the session is active. These posture assessments are enforced for both Windows and macOS platforms, and they apply to users connecting via Always-On VPN or browser-based session proxies.

Windows Endpoints

Posture checks validate the presence and operational status of:

  • Microsoft Defender Antivirus with real-time protection enabled
  • Active SentinelOne agent with recent heartbeat
  • Operating system version and patch level compliance
  • Full disk encryption enabled via BitLocker

Mac Endpoints

MacOS endpoint enforcement checks include:

  • System firewall enabled
  • FileVault disk encryption activated
  • Active SentinelOne agent running with threat protection enabled
  • Operating system version and patch level compliance

All posture check failures result in access denial until remediated. The posture engine provides client-side remediation prompts and communicates health state directly to the Perimeter 81 policy engine. Devices failing posture checks are logged with endpoint ID, OS version, user identity, and failure reason.

Devices must be managed and enrolled through Thriveworks' endpoint management platform prior to being used for work-related access. Corporate-issued devices are automatically provisioned with required posture agents, while BYOD access is strictly limited to web-only access via isolated Secure Web Gateway nodes and must meet a reduced compliance profile.

Any attempt to disable posture agents, tamper with security controls, or route traffic through unapproved endpoints is considered a policy violation and triggers automated alerting to the eSentire Security Operations Center (SOC), which correlates posture data with identity, geography, and historical session behavior.

All posture policy configurations are version-controlled and reviewed quarterly by Systems & Security Engineering. Any changes to enforcement logic, threshold values, or supported platforms must be:

Documented

Proposed via Freshservice change request with associated CMDB assets

Reviewed

Reviewed and approved by the appropriate CAB

Validated

Deployed to stage networks for validation prior to production rollout

Posture failures and remediation activity are logged centrally in SumoLogic and retained for a minimum of seven years in accordance with HIPAA and Thriveworks data retention policy.

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System Design

3. Network Architecture

Thriveworks implements a multi-layered network architecture purpose-built to support a Zero Trust security model across hybrid and multi-cloud environments. This architecture is anchored by Harmony SASE’s gateway-based mesh overlay, which interconnects users, services, and infrastructure through encrypted tunnels and strict access segmentation. The environment spans cloud-native assets in AWS and Heroku, remote workforce endpoints, and backend services segmented by risk domain, business unit, and geography.

Zero Trust Networks (ZTNs)

Each Zero Trust Network (ZTN) in Perimeter 81 is a logically isolated construct representing a distinct trust boundary. ZTNs are assigned to environments such as development (e.g., TW-Dev-US-Tunnel), production (Thriveworks Clinical Network), infrastructure (TW-AWS-Ops), and penetration testing (Tech Pentest Environment). Each ZTN is configured with dedicated firewall policies, DNS resolution scopes, IP pools, and posture requirements.

Gateways within each ZTN are regionally distributed and tied to specific policy enforcement layers. Gateways serve as ingress points where authentication, posture validation, and routing decisions are enforced before traffic is allowed to enter the internal network. These gateways operate as ephemeral inspection nodes with TLS termination and session identity correlation for visibility and control.

Regional Gateway & Tunnel Strategy

Harmony SASE gateways are deployed across North America, South America, Europe, and Asia, with current core regions including Atlanta, Los Angeles, Dallas, New York, Chicago, São Paulo, and Mumbai. Each region supports:

Site-to-site IPSec tunnels for AWS VPC connectivity

Gateway-to-gateway routing with enforcement of inter-zone isolation

Endpoint-to-application segmentation using DNS override

Required & Baseline Configuration

IPSec Tunnels

IPSec tunnels interlink Harmony's secure web gateways with AWS transit gateways, VPC-attached VPN endpoints, and Heroku Shield Private Space endpoints. These tunnels are encrypted using AES256/SHA512 and negotiated via IKEv2 with strict lifetimes, rekey intervals, and Diffie-Hellman Group 21.

Gateways are intentionally not deployed inside the VPCs themselves, ensuring traffic routing occurs via least-privilege paths and denies lateral movement unless explicitly permitted. Routing tables in AWS VPCs are designed to accept traffic only from defined IPSec tunnel CIDRs and to reject any traffic originating outside authorized ZTN peers.

Segmentation Policy

ZTNA-level segmentation

Users only connect to the ZTN(s) assigned to their role, validated by Google Workspace group membership.

Network-level segmentation

IPSec tunnel definitions include precise subnet ranges per application or data domain (e.g., 10.16.2.0/24 for SQL, 172.8.0.0/16 for services, 172.168.144.0/20 for legacy workloads).

Service-level segmentation

DNS resolution rules isolate services by region, environment, and purpose. For example, RDP to EC2 database hosts is only resolvable and routable by members of the Ops or DBA Access Groups.

Application-level segmentation

Perimeter 81 Applications are published through reverse proxy rules tied to Access Groups, binding browser or protocol-level access (HTTPS, RDP, SFTP) to explicit roles, devices, and time-based access conditions.

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3. Network Architecture

System Design

Required & Baseline Configuration

DNS and Traffic Steering

All internal service resolution is handled by the Perimeter 81 DNS override engine. Queries to internal domains (e.g., sql.prod.thrive.local) are resolved to private IP addresses only within authorized ZTNs. Public DNS resolution for external traffic is routed through regional Secure Web Gateways (SWGs) to ensure inspection, filtering, and logging. DNS over HTTPS (DoH) is enforced to prevent local DNS leakage, and clients are prevented from resolving non-sanctioned internal domains by default.

Traffic destined for internet endpoints is steered through the closest available SWG node based on user geography. These nodes perform TLS inspection, URL filtering, and malware scanning before permitting egress. Inbound requests to internal systems are denied unless initiated from authorized ZTN gateways and matched against published application policies.

High Availability and Resilience

Gateways are deployed in multi-zone clusters with failover enabled between at least two physical regions for all production-facing ZTNs. IPSec tunnels are configured in active-active mode wherever the downstream AWS VPN configuration supports multipath redundancy. In scenarios where failover occurs (e.g., gateway degradation, regional outage), routing and application access seamlessly shift to redundant paths via dynamic DNS updates and load-balanced gateway assignments.

Quarterly failover tests are conducted for all critical gateway regions and tunnel endpoints. Test outcomes are logged in Freshservice and reviewed during post-mortem analysis by the Cloud Infrastructure team.

Policy Compliance and Auditing

All gateway configurations, tunnel definitions, subnet mappings, and DNS override policies are version-controlled and reviewed quarterly. Unauthorized changes are blocked by admin-scoped RBAC enforcement in Perimeter 81 and must go through a Change Advisory Board (CAB) workflow via Freshservice.

Network logs—including tunnel negotiation, gateway registration, DNS queries, and session metadata—are sent to SumoLogic and correlated with user identity and posture results. Anomalies in connection attempts, route deviation, or policy violations are escalated to the eSentire SOC for triage and response.

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3. Network Architecture

System Design

Resilience & Recovery

Thriveworks ensures that the Zero Trust Network Access (ZTNA) environment is resilient against regional disruptions, infrastructure failures, and system degradations. Recovery operations are governed by the following principles:

Recovery Time Objective (RTO)

Core access functionality (ZTNA tunnels, gateway routing, identity enforcement) will be restored within 1 hour of a disruption impacting clinical or production-facing systems.

Recovery Point Objective (RPO):

Configuration state data, audit logs, and policy definitions are replicated with a maximum allowable loss window of 15 minutes.

Failover Strategy:

Gateways and IPSec tunnels are deployed in active-active configurations across at least two regions. Real-time health monitoring triggers DNS-based redirection to operational nodes.

Test Validation:

Recovery processes are tested quarterly, with success criteria including: tunnel re-establishment within SLA, application reachability checks, latency thresholds under 100ms, and telemetry validation to SumoLogic.

Backup & Configuration Replication:

All Harmony SASE's configurations (ZTNs, gateway definitions, posture templates) are backed up and version-controlled. Recovery testing includes restoring a known-good config and verifying application-layer routing and access policies.

Post-Recovery Review:

After every recovery event or failover drill, a formal review is conducted by the Cloud Infrastructure and Security teams. Root cause, gaps in resilience, and improvements are documented and integrated into the quarterly governance report.

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Logging, Monitoring, and Threat Detection

System Design

Thriveworks employs a multi-tiered security telemetry and monitoring strategy that aligns with Zero Trust principles and supports real-time visibility into user behavior, endpoint health, and network activity. Logging is not a passive archival mechanism, but an active enforcement layer tied to behavioral anomaly detection, automated alerting, and incident response. Telemetry is collected from every critical layer of the infrastructure stack—including endpoints, network gateways, cloud services, applications, and identity systems—and is centralized in a unified analytics platform to support correlation and threat detection.

Data Sources and Log Ingestion

Thriveworks collects structured and unstructured logs & event data from the following sources:

Harmony SASE

VPN tunnel initiation, application access events, SWG policy matches, device posture status, DNS queries, and ZTN connection failures

Google Workspaces

Login events, MFA challenges, suspicious behavior detection, OAuth scopes

SentinelOne

Endpoint alerts, quarantines, file execution, script behavior, and policy violations

SumoLogic

Application logs, container logs (EKS), RDS/EC2 OS logs, systemd logs, and custom application telemetry from Heroku and AWS Lambda

AWS

CloudTrail, GuardDuty, VPC Flow Logs, API Gateway, IAM activity, AWS Config

Datadog

System metrics, audit logs, process execution traces, and distributed tracing for high-risk services

Meraki

SD-WAN Org activity events, flow logs, air-marshal and administrative events

Cribl

Data engine, field management, aggregation layer & security data pipeline

All logs are ingested in near-real-time into SumoLogic, where they are parsed, normalized, enriched with identity and geo/IP metadata, and tagged by severity and source. Heroku workload telemetry is passed into Datadog for high-resolution metric correlation and alert pipeline management, span & trace tagging for WAF function and Intrusion Detection.

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Logging, Monitoring, and Threat Detection

System Design

Logical Aggregation Mesh Architecture


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Logging, Monitoring, and Threat Detection

System Design

Log Enrichment and Contextualization

Before analysis, logs are enriched with context to support actionable insights and reduce false positives. Enrichment layers include:

Identity: Mapped from Google Workspace (primary email, department, org unit)

Device Fingerprint: OS, MAC address, SentinelOne agent ID, policy status

GeoIP and ASN: Country, region, ISP, ASN risk reputation

Session Metadata: Tunnel ID, posture pass/fail, application name, gateway region

Threat Intelligence Correlation: Integration with threat feeds from Cisco Talos, AlienVault OTX, and eSentire proprietary feeds

Monitoring Rules and Alerting

Monitoring pipelines are defined and maintained in Datadog and SumoLogic. Detection rules are designed around known attack patterns, behavior-based anomalies, and policy violations. Key categories include:

ZTNA Access Anomalies: Concurrent logins from disjointed geographies, unexpected ZTN gateway assignments, access outside of working hours

Endpoint Threats: Multiple malware detections, disabled AV, tampered SentinelOne agents, suspicious persistence mechanisms

Insider Threats: Bulk file downloads, repeated failed access to restricted applications, elevated role changes without approved change requests

Cloud Service Abuse: High API call rates, IAM permission changes, unauthorized S3 access, disabled logging or config rules

Application Misuse: Repeated failed login attempts, command injection in logs, RDP brute force attempts, access to deprecated subnets or services

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Logging, Monitoring, and Threat Detection

System Design

Threat Detection and SOC Integration

Thriveworks partners with eSentire to deliver 24/7 managed threat detection and response (MDR). All logs and telemetry data are shared with eSentire’s SOC via secure ingestion APIs, enabling:

Correlation of Thriveworks-specific rules with broader threat campaigns

Behavioral baselining of users, devices, and applications

Rapid triage and escalation of confirmed indicators of compromise (IOCs)

Support for containment decisions

Forensics & Long-term Analysis

All audit and system logs are retained and searchable for a minimum of 7 years, with a tiered architecture:

Hot Storage (0-30 days)

Indexed and searchable in SumoLogic

Warm Storage (30-180 days)

Archived to S3 Glacier Instant Retrieval

Cold storage (180 days - 7 years)

Stored in Glacier Deep Archive

Readiness policy include:

Pre-approved access to logs for IR team and Security Engineering

Use of case-specific search indexes and anomaly detectors

Integration with Zeek/Suricata for packet-level reconstructions during incidents

Chain-of-custody protocols for handing off log bundles in legal or regulatory cases

Monitoring Governance and Policy Compliance

Monitoring configurations and detection rules are maintained as code and stored in a Git-backed configuration repository with peer review and signed commits. Rule updates are versioned and reviewed biweekly by Security Engineering.

Key monitor governance and compliance policies include:

No suppression of alerts without written approval from the Cloud Security Lead

All new application services must define logging patterns and alert thresholds before going live

Quarterly control validation exercises are conducted to test alert efficacy and identify log coverage gaps

All monitoring and logging policies are reviewed annually to align with evolving compliance frameworks (HIPAA, NIST 800-53, HITRUST)

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Configuration Governance

Change Management Policy

Thriveworks enforces a structured, risk-aware change management process to govern all configuration modifications related to Zero Trust Network Access (ZTNA) infrastructure. This policy defines the technical, procedural, and governance requirements for proposing, evaluating, approving, and executing changes across all security-relevant components, including Perimeter 81 resources, tunnel endpoints, access policies, secure web gateway rules, posture configurations, and application access.

The change management framework is implemented in Freshservice, where all ZTNA-related assets are tracked through a fully populated Configuration Management Database (CMDB). Assets include gateways, IPSec tunnels, DNS override entries, firewall policies, access groups, application profiles, and posture enforcement templates. Each asset is manually registered and linked to:

Freshservice Request portal

Upstream and downstream dependencies (e.g., Heroku apps, AWS VPCs, Secure Web Gateway nodes)

Service ownership groups and business units

Real-time operational telemetry sources (e.g., Datadog monitors, SumoLogic alerts)

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Change Management Policy

Configuration Governance

Request Lifecycle

All configuration changes must begin with the creation of a Freshservice Change Request (CR) by an authorized administrator. The CR must include:

A detailed summary of the change purpose and technical justification

Asset relationships (selected directly from the CMDB) that are affected by the change

Exact components being created, modified, or deprecated

Risk assessment based on likelihood and downstream impact

References to all research materials: security advisories, external documentation, architectural diagrams

Linked evidence gathered during research and staging validation, such as:

  • Log excerpts showing anomalous behavior or errors
  • Screenshot or CLI output from pre-change and post-change states
  • Metric deviations in Datadog from controlled test executions
  • Scan results from SumoLogic, Nessus, or custom compliance scripts

Rollback plans, escalation paths, and verification steps to confirm whether the change had the intended outcome.


CAB Review & Approval

Once the CR has passed its initial technical and dependency reviews, it is submitted to the Change Advisory Board (CAB) for evaluation. The CAB is a multi-disciplinary governance team responsible for:

Validating the security and operational integrity of proposed changes

Identifying unaccounted dependencies or regression risks

Reviewing the change window, planned downtime (if any), and conflict with other changes

CAB approval is required before any changes are applied in production environments. The CAB approval log is digitally signed and timestamped in Freshservice for audit retention. Urgent changes (e.g., those involving an active security incident) may be fast-tracked via an emergency change process but must be post-validated by CAB within 48 hours of implementation.

Execution and Documentation

After CAB approval, the administrator executes the change in accordance with documented procedures. Every step must be tracked in the Freshservice CR timeline, including:

CLI commands or API calls issued in Perimeter 81, AWS, or other tools

Success/failure output from the CLI or control plane logs

System validation using test scripts or canary policies to ensure correct behavior

Any need to revert due to errors or observed regressions

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Change Management Policy

Configuration Governance

Following execution, the CR must be updated to include:

Final state validation results (logs, screenshots, endpoint behavior summaries)

Screenshots of Perimeter 81 policy change history or SumoLogic validation

Newly created or modified assets added to the CMDB and linked to impacted services

Notes on downstream impact, including user behavior, session logs, latency metrics, or authentication anomalies

In the case of IPSec tunnel updates, this may include:

  • New phase-1/phase-2 configuration parameters
  • Rekey timing validation
  • Route injection testing with packet captures (pcap) if needed

Governance Controls and Auditing

All CRs are version-controlled and tagged by environment (e.g., staging, production, clinical) with immutable timestamps. The Freshservice CMDB maintains a complete audit history for each asset, including:

Previous change request IDs associated with the asset

Temporal relationship maps to dependent services and networks

Auto-generated impact radius graphs for visualizing blast radius during assessment

Change metrics such as Mean Time to Approve (MTTA), Mean Time to Deploy (MTTD), and Mean Time to Detect Reversion (MTTRv) are calculated monthly. These are reviewed during Quarterly Security and Operations Governance meetings to identify process bottlenecks and improve cross-team efficiency.

All change-related data—logs, evidence attachments, audit trails—are retained in S3 and Glacier with a 7-year lifecycle per HIPAA and NIST CSF policy alignment.

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Audit Readiness

NIST CSF Control Mapping - ZTNA Policy

This section documents the formal mapping between Thriveworks’ Zero Trust Network Architecture (ZTNA) Policy and the NIST Cybersecurity Framework (CSF) version 2.0. It serves as a compliance reference that demonstrates how ZTNA-related controls align with key cybersecurity functions and subcategories defined by NIST.

Purpose of this matrix: The primary objective of this matrix is to support internal and external audits, enable regulatory readiness, and ensure that Thriveworks can clearly show how its Zero Trust strategy satisfies the requirements of industry-standard frameworks such as HIPAA, HITRUST, and NIST CSF. By linking policy implementations to specific CSF subcategories, Thriveworks strengthens its evidence base for compliance and risk management activities.

Why this matters: Zero Trust is a foundational strategy for modern cybersecurity, particularly in cloud-first and hybrid environments. Mapping the policy to NIST CSF 2.0 provides measurable assurance that access controls, monitoring, response mechanisms, and identity management practices are both robust and aligned with industry expectations. It also facilitates continuous improvement by identifying any gaps or underrepresented controls for future enhancement.

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Audit Readiness

Auditor-Facing SOP (Artifact Collection)

The scope of this SOP covers identity enforcement, posture validation, network segmentation, session monitoring, incident response, and configuration governance across the compliance boundary defined — Thriveworks ZTNA infrastructure.

System Walkthrough (With Evidence)

1

Access Control (PR.AC-P1, PR.AC-P2)

Verify: MFA and SSO enforcement via Google Workspace

  • Screenshot of MFA config in Google Admin
  • Screenshot of login logs in Google Workspace Security Center
  • RBAC group memberships from Workday mapped to Perimeter 81
2

Device Posture (PR.PT-P3, DE.CM-P3)

Verify: Active SentinelOne agent, disk encryption, OS patch level

  • Screenshot of posture policy in Harmony
  • Sample failed posture log in SumoLogic (timestamp + device ID)
3

ZTNA Segmentation (PR.PT-P1, DE.CM-P4)

Verify: IPSec tunnel config, gateway failover, app segmentation

  • Screenshot of gateway settings and tunnel CIDRs
  • SumoLogic log of a gateway switch during a DR test
  • Published applications list tied to roles
4

Monitoring and Detection (DE.CM-P1, DE.CM-P6, RS.AN-P1)

Verify: Alerts for ZTNA anomalies and SOC workflows

  • Example Freshservice ticket created from a failed policy
  • SumoLogic alert rule definition
  • Datadog dashboard showing endpoint health
5

Resilience & Recovery (RC.RP-P1, RC.IM-P1)

Verify:

Tunnel failover, config restore, DR validation

  • DR test results with latency metrics
  • Config diff showing rollback/recovery
  • Meeting notes from DR test post-mortem
6

Change Management (PR.MA-P1)

  • Screenshots of CMDB entries tied to ZTNA assets
  • Example CAB approval for tunnel modification
  • Audit trail from Freshservice with timestamps and approvals
7

Log Retention

  • Diagram or screenshot of your 7-year log retention policy in SumoLogic/Glacier
  • Config sample showing AWS lifecycle policy
  • Sample retrieval of archived logs for an incident
8

Version Control & Review

  • SOP and policy are reviewed annually or after major infra changes
  • Reviewed by: Security Engineering, Compliance, Cloud Ops
  • Store versions in your documentation repo with changelog (date, change owner, summary)

Zero Trust Network (ZTNA) Policy

20

v3.2.1

Policy Review & Approval

This Zero Trust Network Access (ZTNA) Policy is a living document and shall be reviewed at least annually, or upon any significant change to Thriveworks technology stack, organizational structure, or applicable regulatory landscape. Additional reviews may also be initiated following disaster recovery tests, incident investigations, or business continuity planning updates.

All changes to this policy require executive leadership approval. The final, approved version will be distributed to all relevant personnel and made available through Thriveworks central documentation repository. Compliance with the latest version of this policy is mandatory for all affected teams.

Ben Bone
Vice President, Technology


Policy Responsibilities:

Leads the configuration policy review cycle and cross-functional coordination. The VP is responsible for collecting input from Compliance, Security, IT Operations, and DevOps teams to ensure policy updates are technically accurate, operationally practical, and aligned with Thriveworks’ risk management and compliance objectives. Proposed changes are consolidated and prepared for executive review and final approval.

Marc Brooks
Chief Admin Officer & General Counsel


Policy Responsibilities:

Serves as the executive sponsor of the ZTNA Policy, providing final approval authority. The CAO is responsible for ensuring that the policy aligns with Thriveworks’ broader organizational objectives, regulatory commitments, and strategic risk tolerance. This includes reviewing proposed updates, validating that appropriate stakeholder collaboration has occurred, and formally endorsing the policy before publication or reissuance.

Zero Trust Network (ZTNA) Policy

21

v3.2.1