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 enterprise 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.
- Automated decision-making disclosure obligations. Ready for December 2026.
- 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
- Bias, fairness, and automated decision-making disclosure obligations
| 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 & roadmap
Certifications & Roadmap
Zato's certification roadmap is structured across five phases, progressing from readiness baseline through to full multi-standard certification.
| Phase | Target | Status |
|---|---|---|
| Phase 0 | Readiness baseline against ISO 27001, ISO 42001, and SOC 2. | In progress |
| Phase 1 | SOC 2 Type I issuance and ISO 27001 Stage 1 documentation audit. | Scheduled |
| Phase 2 | ISO 27001 certification and SOC 2 Type II observation start. | Planned |
| Phase 3 | ISO 42001 certification, SOC 2 Type II report, and ISO 27701 extension. | Planned |
| Phase 4 | ISO 27017 / 27018 attestation and first surveillance audits. | Planned |
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. |
| Automated decision-making disclosure | AU | Ready for Dec 2026 | Privacy notices identify AI-assisted decision categories and human review pathways. |
| 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/IEC 27001 | International | In progress | ISMS implemented with audit sequencing aligned to roadmap phases. |
| SOC 2 Type II | International | In progress | Type I and Type II sequencing aligned to assurance milestones. |
| ISO/IEC 42001 | International | Planned | AI management system and impact assessment model under development. |
| 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 | trust@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 | privacy@zatohq.com. Access, correction, erasure, and cross-border transfer inquiries. |
| Regulatory authorities | legal@zatohq.com. Formal correspondence from competent authorities. |
Terms of Use
Terms of Use
By accessing or using the Zato platform, you agree to these terms. These terms govern your use of Zato's products and services.
Acceptance
By using Zato, you confirm that you have read, understood and agree to be bound by these Terms of Use and our Privacy Policy.
Use of the platform
Zato grants you a limited, non-exclusive, non-transferable licence to use the platform for your firm's internal compliance and accounting operations. You may not use Zato for any unlawful purpose or in a way that may harm Zato or third parties.
Data and confidentiality
All data you upload or generate within Zato remains your property. Zato processes your data solely to deliver the services described in your agreement. We do not sell or share your data with third parties for commercial purposes.
Intellectual property
The Zato platform, including all software, AI models, interfaces and documentation, is the intellectual property of Zato Origin NZ Ltd. Nothing in these terms transfers any IP rights to you.
Limitation of liability
To the maximum extent permitted by law, Zato's liability is limited to the fees paid by you in the three months preceding the relevant claim. Zato is not liable for indirect, incidental or consequential loss.
Changes to terms
We may update these terms from time to time. We will notify you of material changes via email or in-platform notice. Continued use of the platform after changes constitutes acceptance.
Governing law
These terms are governed by the laws of New Zealand. Any disputes will be resolved in the courts of New Zealand, unless otherwise agreed.