01: Scope and purpose
Scope and Purpose
This document sets out the controls, standards and governance mechanisms Zato deploys to protect client data and maintain the trust of accounting firms.
This framework applies to all Zato systems, personnel, sub-processors and third-party integrations that handle Client Personal Data or Firm Data as those terms are defined in Zato's Data Processing Agreement.
International standards referenced
| Standard | Role in Zato's compliance posture |
|---|---|
| ISO/IEC 27001:2022 | Information Security Management System baseline expected by audit firms and corporate procurement teams. |
| SOC 2 Type II | Independent attestation over Security, Availability, and Confidentiality controls. |
| ISO/IEC 42001:2023 | Certifiable AI management standard that supports Zato's AI governance posture. |
| ISO/IEC 27701:2019 | Privacy information management extension to ISO 27001. |
| ISO/IEC 27017 / 27018 | Cloud control and privacy controls for public cloud environments. |
| NIST CSF 2.0 / NIST AI RMF 1.0 | Taxonomy used for customer questionnaires and AI risk communication. |
02: Regulatory perimeter
Regulatory Perimeter
Zato operates within a dual-jurisdiction regulatory framework, serving accounting firms in both Australia and New Zealand. Each jurisdiction has distinct privacy obligations that Zato addresses through aligned controls.
Australia
- Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs 1–13). Operational compliance.
- Notifiable Data Breach scheme integrated into incident response procedures.
- AML/CTF substrate support for accounting firm compliance obligations.
New Zealand
- Privacy Act 2020 and Information Privacy Principles (IPPs 1–13). Operational compliance.
- IPP 3A indirect collection notification paths and transfer-mapping controls.
- AML/CFT substrate support for accounting firm compliance obligations.
- Breach notification pathways established and tested.
03: Infrastructure & data residency
Infrastructure & Data Residency
Zato is built on AWS infrastructure with data residency controls that allow clients to elect the region in which their data is stored and processed.
| Area | Approach |
|---|---|
| New Zealand clients | AWS Asia Pacific (New Zealand): ap-southeast-6, Auckland Region, with Bedrock and AgentCore available in-region. |
| Australian clients | AWS Asia Pacific (Sydney): ap-southeast-2, as primary, with Melbourne available for recovery and supporting services. |
| Data plane | Persistent stores, queues, backups, observability data, and audit logs remain in the tenant's elected region. |
| Model inference | In-region inference by default. Where cross-region inference is required, routing is constrained to approved AU geographic profiles. |
Cross-border data transfer controls
- Comparable privacy safeguards across Australia and New Zealand are assessed before cross-border disclosures.
- Contractual controls flow APP-equivalent and IPP-equivalent protections through DPAs and intra-group mechanisms.
- Technical confinement allows customers to elect single-region residency where required.
04: Trust architecture
Trust Architecture
Zato's trust architecture is designed to protect client data at every layer of the stack, from identity and access management through to incident response.
| Control family | Implementation | Reference |
|---|---|---|
| Identity & access | SSO support, MFA, just-in-time elevation, and controlled service credentials. | ISO 27001 A.5.15–A.5.18 |
| Encryption | TLS in transit, AES-256-GCM at rest, customer-managed keys where required. | ISO 27001 A.8.24 |
| Tenant isolation | Per-tenant encryption keys and logically segregated processing boundaries. | ISO 27017 / ISO 27018 |
| Logging & monitoring | Immutable event journaling, SIEM centralisation, alerting, and evidence retention. | SOC 2 CC7.2 |
| Vulnerability & patching | Software composition analysis, SAST, DAST, penetration testing, and severity SLAs. | ISO 27001 A.8.8 / A.8.29 |
| Business continuity & DR | Documented RPO/RTO, cross-AZ deployment, and annual recovery testing. | ISO 22301 / SOC 2 A1.2 |
| AI lifecycle | AI impact assessments, prompt and model registry, evaluation, monitoring, and human review. | ISO 42001 / NIST AI RMF |
| Incident response | 24×7 response readiness with statutory-clock awareness across AU and NZ requirements. | ISO 27001 A.5.24–A.5.28 |
05: AI & LLM concerns
AI & LLM Governance
Zato's agentic AI architecture introduces risks that require specific mitigation. The following table describes how Zato addresses each concern.
AI risks addressed
- Training-data leakage and prompt injection
- Cross-tenant context bleed and PII exposure in prompts
- Hallucination, output integrity, and tool-execution risk
- Auditability, model versioning, data egress, and availability risk
| Concern | Mitigation | Technical support |
|---|---|---|
| Training-data leakage | Customer inputs and outputs are not used to train foundation models under Bedrock privacy terms. | Bedrock privacy commitments |
| Prompt injection | Instruction/data separation, allowlisted tools, output validation, and guardrails. | Bedrock Guardrails / Gateway policy |
| Cross-tenant bleed | Per-tenant IAM identity, per-tenant memory, and tenant-scoped retrieval indices. | AgentCore Identity / Memory |
| Hallucination | Grounded generation, confidence checks, and escalation to human review when thresholds are not met. | Contextual grounding / Zato orchestration |
| Auditability | Each model invocation, tool call, and memory access is recorded in an append-only event journal. | AgentCore Observability / CloudWatch |
| Data egress | In-region inference by default, VPC endpoints, and constrained cross-region routing. | Bedrock regional controls |
06: Anonymisation & de-identification
Anonymisation & De-identification
Zato applies a layered transformation approach to reduce re-identification risk across different processing contexts.
| Technique | Use case |
|---|---|
| Suppression | Remove fields that are not required downstream. |
| Masking | Expose field presence without revealing sensitive values. |
| Generalisation | Reduce granularity for analytics and low-risk processing. |
| Deterministic tokenisation | Support joins without revealing source identifiers. |
| Format-preserving encryption | Preserve value shape for systems that require specific formats. |
| Salted hashing | Irreversible pseudonymisation when re-identification is never required. |
| Date shifting | Preserve interval logic while obscuring absolute dates. |
| Synthetic data | Non-production development, QA, and demonstration environments. |
07: Certifications
Certifications
Zato is independently audited and certified across five international standards covering information security, AI governance, quality management, and personal data protection. Certificates and audit reports are available upon request.
| Standard | Coverage | Status |
|---|---|---|
| ISO 9001 | Quality management systems. | Certified |
| ISO 27001:2022 | Information security management systems. | Certified |
| ISO 42001 | Artificial intelligence management systems. | Certified |
| GDPR | Personal data protection (EU General Data Protection Regulation). | Compliance statement |
| SOC 2 | Security, availability, and confidentiality controls (AICPA). | Independent attestation |
All certificates and audit reports are available on request under NDA. Contact security@zatohq.com for copies and vendor due-diligence documentation.
08: Compliance matrix
Compliance Matrix
The following matrix summarises how Zato addresses each regulatory instrument and international standard relevant to ANZ accounting firms.
| Instrument | Jurisdiction | Status | How |
|---|---|---|---|
| Privacy Act 1988 · APPs 1–13 | AU | Operational | APP-aligned privacy notice, APP 11 controls, and NDB integration into incident response. |
| Privacy Act 2020 · IPPs 1–13 | NZ | Operational | IPP-aligned privacy practices and breach notification pathways. |
| IPP 3A: indirect collection | NZ | Operational | Indirect collection notification paths and transfer-mapping controls. |
| AML/CTF / AML/CFT substrate | AU / NZ | Client-substrate ready | Retention, evidence lineage, and workflow support for accounting firm compliance obligations. |
| ISO 9001 | International | Certified | Quality management system certified to ISO 9001. Certificate available on request. |
| ISO/IEC 27001:2022 | International | Certified | Information security management system independently audited and certified. Certificate available on request. |
| ISO/IEC 42001 | International | Certified | AI management system independently audited and certified. Certificate available on request. |
| SOC 2 | International | Independent attestation | Security, availability, and confidentiality controls independently attested. Report available on request under NDA. |
| GDPR | EU | Compliance statement | Personal data protection controls independently audited against GDPR. Audit documentation available on request. |
| AWS underlying infrastructure | International | Inherited | AWS attestations and certifications are reviewed through vendor management and available through AWS Artifact under NDA. |
09: Compliance inquiries
Compliance Inquiries
Direct all compliance and privacy inquiries to the appropriate contact below. We aim to acknowledge all inquiries within one business day.
| Area | Contact |
|---|---|
| General trust & compliance | security@zatohq.com. Vendor questionnaires, DPA requests, sub-processor disclosure, certification artefacts. |
| Security incident notification | security@zatohq.com. Incidents involving Zato systems and coordinated disclosure. |
| Privacy & data subject requests | security@zatohq.com. Access, correction, erasure, and cross-border transfer inquiries. |
| Regulatory authorities | security@zatohq.com. Formal correspondence from competent authorities. |
10: Compliance documents
Compliance Documents
Certificates and audit reports are released after review, and we keep a record of every release. Australian and New Zealand artefacts are certified and held separately, so tell us which entity your review covers.
AU Australia — Zato Australia Pty Ltd
ISO/IEC 27001:2022
Information security management system certificate.
SOC 2 Type II
Independent attestation over security, availability and confidentiality controls.
ISO/IEC 42001:2023
AI management system certificate.
ISO 9001:2015
Quality management system certificate.
GDPR
Data protection and lawful processing position.
NZ New Zealand — Zato New Zealand Limited
ISO/IEC 27001:2022
Information security management system certificate.
SOC 2 Type II
Independent attestation over security, availability and confidentiality controls.
GDPR
Data protection and lawful processing position.
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11: Sub-processors
Sub-processors
The services that help us deliver and operate the platform. Customers can subscribe to change notifications by contacting security@zatohq.com.
| Subprocessor | Purpose | Data location | Status |
|---|---|---|---|
| AWS | Cloud infrastructure, hosting, storage and in-region model inference. | Australia (ap-southeast-2) and New Zealand (ap-southeast-6) | Active |
| Xero | Accounting ledger integration and client data sync. | Australia and New Zealand | Active |
| Microsoft Entra ID | Single sign-on identity provider. | Global | Active |
| Workspace, identity, analytics and productivity services. | Global | Active | |
| SerpAPI | Web search enrichment for Auto-Coding and agents. | Global | Active |
Client data is stored and processed in the region the firm elects:
AWS Asia Pacific (Sydney) ap-southeast-2 for Australian clients and AWS Asia Pacific
(New Zealand) ap-southeast-6 for New Zealand clients, with model inference in-region by
default. As disclosed in clause 8.1 of our
Data Processing Addendum, Zato, its affiliates and its
sub-processors may also process personal data in Australia, New Zealand and India. The current
sub-processor list is available on request, and customers can subscribe to change notifications via
security@zatohq.com.
12: Shared responsibility
Shared Responsibility
Security is a shared model. This is the line between what Zato operates and what remains with your firm.
| Area | Zato | Your firm |
|---|---|---|
| Infrastructure | Hosting, network controls, encryption in transit and at rest, patching and monitoring. | Nothing. Managed entirely by Zato. |
| Application security | Secure development, testing, vulnerability management and release control. | Reporting suspected issues to the security team. |
| Identity and access | SSO support, role based access control, authentication and audit logging. | Deciding who gets access, assigning roles, and removing leavers promptly. |
| Client data | Storing and processing data in the elected region per the DPA. | Accuracy and lawful basis for the data uploaded, and consents required from clients. |
| Output review | Producing output, and the controls and audit trail around it. | Professional review of output before it is relied on or filed. |
| Devices and endpoints | Zato-managed devices and personnel. | Your own devices, email, endpoint protection and network. |
13: Security reviews
Security Reviews
Submit your firm’s security questionnaire and our team will complete it.
Running a security review?
Submit your firm's security questionnaire through the Security centre and our team will complete it. Most standard questionnaires are answered from our existing control evidence, so turnaround is quick. If your reviewer needs something that is not covered here, ask and we will point you to the right artefact.
14: Terms of Use
Terms of Use
The Zato Terms of Use, together with the Data Processing Addendum and Appendix A (Technical and Organisational Security Measures), govern access to and use of the Zato platform. They cover provision of the Services, customer responsibilities, fees, proprietary rights, confidentiality, warranties, indemnification, limitation of liability, term and termination, and the contracting entity and governing law that apply in Australia and New Zealand.
The full and current text is published in one place so there is a single authoritative version.
Read the full Terms of Use