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Technical andOperational Security

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CONTENTS
1EXECUTIVE SUMMARY ............................................................................................................................................ 3

2

APPLICATION SECURITY .......................................................................................................................................... 3
2.1 Access Control and Identity Management ................................................................................................................. 3
2.2 Audit Trails .................................................................................................................................................................. 4
2.3 User Authorization ...................................................................................................................................................... 4

3

DATA SECURITY AND PROTECTION .......................................................................................................................... 5
3.1 Customer Data ............................................................................................................................................................ 5
3.2 Data in Motion Encryption.......................................................................................................................................... 5
3.3 Data at Rest Encryption .............................................................................................................................................. 5
3.4 Backup and Recovery .................................................................................................................................................. 5
3.5 Data Protection and Retention Policies ...................................................................................................................... 5

4

INFRASTRUCTURE SECURITY ................................................................................................................................... 7
4.1 Physical Security ......................................................................................................................................................... 7
4.2 Network Security ........................................................................................................................................................ 8
4.3 System Security ........................................................................................................................................................... 8
4.4 Veeva Internal Corporate Security.............................................................................................................................. 9

5

SOFTWARE SECURITY PRACTICES .......................................................................................................................... 10
5.1 Secure Software Development ................................................................................................................................. 10
5.2 Application Change Management ............................................................................................................................ 10
5.3 Application Vulnerability Assessments ..................................................................................................................... 10

6

COMPLIANCE ........................................................................................................................................................ 12
6.1 Legal Requirements .................................................................................................................................................. 12
6.2 Privacy Requirements ............................................................................................................................................... 12
6.3 Service Organization Control Reports (SOC 2) .......................................................................................................... 12
6.4 ISO 27001:2013 ......................................................................................................................................................... 12
6.5 21 CFR Part 11 ........................................................................................................................................................... 12
6.6 EU Annex 11 .............................................................................................................................................................. 12
6.7 Sarbanes Oxley (SOX) - Section 404 (IT).................................................................................................................... 13
6.8 Governance, Risk, and Compliance (GRC) Framework ............................................................................................. 13
6.9 Business Continuity / Disaster Recovery .................................................................................................................. 13

7

INFORMATION SECURITY POLICIES ........................................................................................................................ 14
7.1 Policies and Practices (SLAs) ..................................................................................................................................... 14
7.2 Security Organization and Management .................................................................................................................. 14
7.3 Veeva Personnel Security and Training ...................................................................................................................... 15
7.4 Data Breach............................................................................................................................................................... 15

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CONCLUSION ........................................................................................................................................................ 16

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1 Executive Summary
Data security is a critical consideration for any company evaluating cloud-based software providers. Veeva is fully committed toensuring the confidentiality, integrity, and availability of customer data managed by its platform and applications. Our teams
utilize established information security frameworks and always employ secure software development best practices.
All of Veeva’s applications are compliant with the strictest security regulations, including U.S. FDA’s Title 21 CFR Part 11 andEuropean Commission’s Annex 11. Having achieved ISO 27001 certification, Veeva integrates security into every phase of
product development and daily operations. Compliance with the ISO 27001 framework and regulations on electronic data andsystems has enabled Veeva to meet and often exceed rigorous vendor assessment requirements in hundreds of customer
audits.
This paper describes the technology, practices, and controls that Veeva uses to keep your data secure in Veeva SiteVault.

2 Application Security
Application security ensures the protection of SiteVault customer data. The security policies and profiles defined within SiteVault
are enforced through authentication, authorization, and audit safeguards.
SiteVault makes content easily accessible in the cloud while ensuring customer data is only accessed by those with valid credentials
and proper access rights.

2.1

Access Control and Identity Management
2.1.1 User Authentication
In SiteVault, Veeva creates the customer’s first Regulatory user. Additional user accounts are set up and maintainedby the customer’s Regulatory user(s). Each user added will have their own SiteVault user account. Once user
accounts have been created, users must be authenticated before they can access any data.

2.1.2 Login Policies
SiteVault is configured with strong user password strength, including complexity, a default session duration, andpassword length requirements based on industry’s best practices. All access attempts are logged.
In order to protect login credentials, user passwords are salted and then hashed using a multiple-iteration algorithm.
This one-way hash function cannot be reverse engineered back to the original password. Even when two identicalpasswords from different users are stored in the protected authentication servers, the encrypted password strings aredifferent.

2.1.3 Session Management
SiteVault issues a session-specific cookie that keeps users logged into their accounts for a limited duration as
configured by the Veeva SiteVault administrator. This cookie uses a secure random number hash algorithm andexpires after the duration set by the Veeva SiteVault administrator, requiring users to re-authenticate their session upon
expiration. Before rendering a webpage that corresponds to an application request, Veeva confirms that the calculateduser hash value in the session-specific cookie matches the user hash value that was set during the login phase. For
Cross-Site Request Forgery (CSRF) protection, Veeva leverages CSRF tokens associated with the user’s current
session.

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2.2

Audit Trails
SiteVault automatically logs all user activity against a record in audit logs. The audit logs provide visibility into user
activity and are a key requirement for compliance with Electronic Records and Electronic Signature (ERES)
regulations. SiteVault users can view audit log information such as date and time stamp, username, and the eventor activity being processed for documents and objects. For example, if a field value is updated, the before and aftervalues are visible in the audit log for the record.

2.3

User Authorization
Veeva SiteVault administrators configure user access and activities down to the “atomic” level within the application.
They specify access ranging from user administration and application functionality down to individual documents andtheir associated fields. SiteVault application is pre-configured with three user types: Regulatory, Study team, andExternal. Every customer user in SiteVault must be assigned to one of the pre-configured user types.

2.3.1 External AccessCustomer’s SiteVault regulatory users can easily add External users to provide seamless collaboration with sponsors,
contract manufacturers, auditors, regulatory authorities and other partners. To view any customer data, an Externaluser must also be assigned (by a customer’s Regulatory user) to one or more studies.

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3 Data Security and Protection
SiteVault is designed as a multi-tenant cloud application - all customers use a shared pool of computing resources. All
communication and data are also protected using industry standard encryptions.

3.1

Customer Data
There are five types of customer artifacts that are stored:
1.
2.
3.
4.
5.

Metadata
Annotation data
Application configurations
Content files
Full-text search indexes

The first three are stored directly in the database. The content files and full-text search indexes are stored on a fileserver. Content files are encrypted, and file location pointers are calculated using a value stored in the database;
therefore, individuals must have access to the database in order to locate a piece of content.
SiteVault prevents customers from accessing each other’s data by leveraging “atomic” security as noted in section 2.3.

3.2

Data in Motion Encryption
All network communication to SiteVault, from the initial login prompt to document transfer and the viewing of reports,
uses industry standard Transport Layer Security (TLS) encryption.
Veeva uses an industry leading, external certificate authority for its TLS digital certificates with 2048-bit
asymmetric keys and SHA-256 signatures and enforces a minimum of 128-bit symmetric key encryption.

3.3

Data at Rest Encryption
Customer documents are stored in the SiteVault file system using AES 128-bit encryption. Documents are also stored
in Amazon Web Services’ (AWS) S3 buckets, where an additional AES-256 layer of encryption is applied.

3.4

Backup and Recovery
Veeva has implemented a backup and recovery strategy with a four-hour recovery point objective (RPO) and a 24-hour
recovery time objective (RTO).
Customer data is protected to ensure high availability (HA). Data is replicated from the primary site to a disasterrecovery (DR) region at regular intervals, by storing the documents in AWS S3 with cross-region replication. DR sitedata is backed up to AWS S3 nightly and stored for 2 years. Backups are verified using automated daily restore
scripts, with fully rehearsed disaster recovery tests performed every month and restore tests at least twice per year.

3.5

Data Protection and Retention Policies
3.5.2 Employee handling of data
Veeva company policies and procedures explicitly prohibit any caching of customer data on company computers, withthe exception of those employees who require access to customer data to perform activities in their job role (e.g.,
Professional Services implementation or Customer Support). Data destruction and revocation of system access are
explicitly stated as responsibilities of those personnel working with customer data.

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3.5.2 Administrator access to customer data‘
Only Veeva administrators providing support or addressing technical issues, and handpicked members of the Veeva
product development team have the ability to access select customer data. Access is only granted in accordance with
the Veeva Terms of Service (ToS) and is limited by policy to allow the least access necessary to provide support ormeasure product performance, following the principle of least privilege.

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4 Infrastructure Security
4.1

Physical Security
4.1.1 Data Center
Customer data is stored in industry-leading ISO 27001 certified data centers around the world that issue SOC2
Type II reports. All facilities feature 24-hour manned physical security, mantraps, biometric access control, andvideo surveillance. Veeva does not have direct access to servers, which are managed by the data center
providers’ or managed services’ personnel. All data centers are audited annually by an independent third party.
Veeva data centers are designed to protect customer data from hardware and environmental risks.
Infrastructure is maintained in a strictly controlled environment to ensure optimal performance and protection.
This includes the ability to withstand regional natural disasters. To ensure uninterrupted data access,infrastructure components are powered by redundant electrical supplies (e.g. breakers), UPS modules, andgenerators. Veeva and the data center operations personnel are continually monitoring system and network
performance to ensure maximum service availability.

4.1.2 Operational Access
Only data center personnel can physically access servers. Data center personnel therefore perform all hardware
maintenance. All operational activities, including facility access and replacing hardware components or removable
media, are monitored, tracked, and audited.
Within Veeva, only a small number of technical operations administrators can access production infrastructure andperform system maintenance tasks. Veeva continually monitors access logs to verify all administrator activities.
Operating system level security is provided using continuous monitoring tools, such as host based intrusion detection
software, which instruments the kernel and monitors all network and process activity. This allows automated detectionof unauthorized access attempts, including any suspected network connections, file access or suspicious processes
that are launched.

4.1.3 Amazon Web Services (AWS) Security
Veeva has a shared responsibility with AWS based on the standard AWS Shared Responsibility model. Veeva is
primarily responsible for network management, AWS Console access, and AWS resources, and are secured
using a variety of tools, including cloud configuration monitoring software, that continuously monitors andremediates any issues that arise. This allows Veeva to monitor how networks are configured within AWS – totrigger immediate alerts in case of policy violations or suspicious network traffic, as well as track user behavior of
AWS accounts and associated access keys. Finally, these automated tools also inspect how AWS resources,
such as S3 for object storage, or EC2 for compute instances, are configured to ensure they follow best practices.
Access to Veeva’s internal corporate network is controlled through user accounts, which require eight-character
minimum length passwords with password complexity requirements, multifactor authentication for remote access,and auto-expiration. SiteVault is housed on a separate production network in AWS which has stricter controls,
including continuous monitoring by the security team. Access to the production servers and operations network is
controlled through VPN access to a hardened jump host with two-factor authentication.

4.1.4 Asset Management
Veeva maintains an inventory of its critical information assets in an Enterprise asset inventory system and has
identified all applications that process sensitive data. Veeva also tracks IT assets assigned to employees andensures retrieval as part of the employee exit process.

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4.1.5 Malware Protection
All company laptops have malware protection that are managed and monitored by Veeva IT Operations.
Users are trained on security best practices and malware prevention as part of their security awarenesstraining.

4.1.6 Media Handling
Operating procedures are defined to protect documents and computer media containing customer data or
any other type of sensitive information. Media is properly sanitized or securely disposed in compliance to
NIST SP 800-88, Guidelines for Media Sanitization.

4.1.7 Mobile Device Security
Customer data is stored on laptops only for specific purposes such as implementation or troubleshooting,and all files are encrypted using AES 256-bit keys.

4.2 Network Security
4.2.1 Firewalls
External facing systems, including servers hosting customer data, are protected by firewalls. Changes tofirewall rules are reviewed and approved, and the firewalls are monitored 24/7 by the data center provider’ssecurity operations center.
Production servers only have two services directly accessible to the Internet: secure web (ports 80/443) and aseries of secure FTP ports (56000 range). Port 80 is only open on login/authentication servers which
immediately redirect communications to a TLS encrypted session on port 443. Periodic penetration testinghelps ensure there are no known vulnerabilities at the application layer of these two services.
Monitoring of network traffic is provided by a combination of AWS Shield, AWS GuardDuty, AWS VPC Flowlogs and a cloud-native Security Information and Event Management (SIEM) solution.

4.2.2 Jump Hosts
Production servers are not directly accessible from external networks for maintenance and support activities.
Technical Operations access is routed through hardened jump hosts that are secured behind a second set of
redundant firewalls. Jump hosts have full console logging and file integrity monitoring.

4.2.3 Log Management
Security relevant logs such as application and operating system event logs from servers hosting customer
data are centrally aggregated to secure S3 log buckets for long term storage, which are then fed to a cloudnative SIEM solution for real-time monitoring and alerting. The S3-based log buckets are only accessible toselect security, engineering, and technical operations team members, with security having a separate copythat is not accessible to any other team. Automated log monitoring alerts designated personnel of security
events via a Security Orchestration and Automated Response (SOAR) solution.

4.3

System Security
4.3.1 Change Management

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Changes to IT facilities and systems are managed using a documented change control process which requires
adequate testing, review, and approval prior to releasing changes to production servers. Servers have file
integrity monitoring to detect unauthorized changes to critical system files.

4.3.2 Vulnerability Management and Penetration Testing
Systems undergo periodic vulnerability and penetration testing by industry-recognized, third-party security
specialists, using multiple overlapping enterprise-class security solutions to ensure that any vulnerability isidentified and mitigated in a timely fashion. See Section 5.2 for additional details.

4.3.3 Third-party Service Delivery Management
Security requirements, ongoing monitoring, and change management clauses are in place for Veeva’s service
level agreements (SLAs) with each data center provider. Third-party suppliers are also assessed and audited
based on risk.

4.3.4 System Planning and AcceptanceTechnical Operations conducts periodic capacity planning and monitoring to ensure adequate system
performance, taking into account planned customer growth. Servers undergo burn-in testing and are qualified for
production use following standard configuration and hardening checklists as well as automated “smoke tests” toensure the SiteVault application functions as designed.
Servers are hardened following a standard build checklist. Unnecessary ports and services are disabled,
password policies are configured, and patches are periodically reviewed and installed. Server hardening
minimizes the attack surface on production servers.

4.3.5 Monitoring
Application, database, and system monitoring are in place using centralized log aggregation and monitoring
solutions (e.g., SIEM) tools. Responsible personnel are notified via email and SMS when alerts are triggeredusing automated log monitoring systems. Logs are secured using centralized syslog servers accessible only to alimited number of Technical Operations personnel. Performance monitoring is conducted using representative
systems in multiple geographic locations throughout the world.

4.4 Veeva Internal Corporate Security
4.4.1 Wireless Security
The wireless network is secured using WPA2-Enterprise encryption, with new wireless deployments supporting
network access control security that enforces malware protection and network monitoring.

4.4.2 Network Access Control (NAC)
Access to customer data on servers and other network services is controlled and requires either physical accessto Veeva offices or an IPsec VPN connection.
SiteVault application production servers, including all servers hosting customer data, are in a separate logicalnetwork domain from the standard Veeva network accessed by Veeva employees. Access to the production
servers requires two-factor authentication through a VPN and all communication is encrypted.
Veeva has a logical network segment for QA and development activities. Application developers and productmanagement cannot access production systems.

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5 Software Security Practices
5.1 Secure Software Development
Veeva performs a combination of automated and manual code reviews and provides training for developers on
secure software development. Veeva maximizes system protection by testing security measures throughout
the software development lifecycle. Veeva also procures software from software vendors (i.e. ISVs and CSPs)
with SLAs or security clauses that specify prompt security patches and updates.

5.1.1 Design Phase
Automated and manual security control requirements are analyzed and documented during the design phase.
This includes cryptographic controls for digital signatures, management of keys, and digital certificates.

5.1.2 Coding Phase
Secure coding practices are defined and reviewed, and access to source code and test data is controlled.
Secure coding practices include session management security, as well as the prevention ofvulnerabilities. Top 10 software vulnerabilities including malformed XML or HTTP requests, XSS, CSRF,
and SQL injection. Automated and manual code reviews are also performed in this phase.

5.1.3 Testing Phase
Application software is tested for security vulnerabilities during this phase. Identified vulnerabilities are
documented – including remediation plans – and monitored to ensure each vulnerability is addressed
appropriately. Full application penetration testing is conducted for each major release.

5.2 Application Change Management
Changes to production systems follow a documented change program which includes clear scope
definition, technical and regulatory impact assessment, requisite approvals prior to implementation,and testing commensurate with criticality of change. Change documentation follows standard
operational procedures, and corresponding quality records are maintained in a validated Electronic
Document Management System (EDMS). The change control program is designed to ensure thatGxP production systems (i.e. Veeva software solutions) are maintained in a validated state uponchanges to software and hardware configuration items (CIs).

5.3 Application Vulnerability Assessments
In any web application, including online banking websites or personal email, unauthorized attackers may findways to access customer data by piggybacking through a user’s computer while he or she is logged in. Veeva
follows industry best practices, such as the guidelines provided by the Open Web Application Security Project(OWASP), to identify such vulnerabilities and defend against them. For example, if another website attempts toaccess SiteVault through a foreign computer using cross-site scripting (XSS) and cross-site request forgery(CSRF), the unauthorized request is recognized, and all attempts are automatically blocked. This isaccomplished by validating user input to prevent cross-site scripting, and CSRF uses HTTP security headers.
Veeva conducts periodic vulnerability assessments on its software using automated and manual methods. These
assessments are performed on production systems testing contemporary attack vectors. Activities include threat
modeling, vulnerability classification using CVSS, and automated scanning to find potential SQL, LDAP, XPATH,
or JQUERY injection paths and prevent against denial of service (DoS) attacks. Testing is performed with a
combination of manual penetration tests and ongoing private bug bounty programs.

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Examples of application vulnerability tests include: spoofing of user identity, tampering, repudiation, information
disclosure (privacy breach or data leak), denial of service, and elevation of privileges.
Veeva uses a variety of third-party services for vulnerability management, private bug bounties, and penetration
testing. Penetration testing is performed once a year and is full coverage and source code assisted.

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6 Compliance
6.1

Legal Requirements
Veeva is committed to complying with applicable legislation including predicate rules, copyright, data protection,
protection of financial data and other vital records, cryptography restrictions, rules of evidence, and otherapplicable laws. This commitment has been codified in an “acceptable use” policy document shared with all
employees.

6.2

Privacy Requirements
Veeva complies with the European Union (EU) Data Protection Directive 95 / 46 / EC and the General Data
Protection Regulation (GDPR) (Regulation (EU) 2016/679) through the EU-US and Swiss-US Privacy Shieldcertifications as set forth by the U.S. Department of Commerce and the EU Commission regarding the collection,use, and retention of personal data from citizens of the European Union and Switzerland. Veeva’s Global Data
Protection Officer (DPO) resides in the EU and reports independently to Veeva’s General Counsel and ultimately,
the Board of Directors. The DPO measures the privacy program using a regular privacy impact assessments(PIAs) against the Generally Accepted Privacy Principles (GAPP), developed by the AICPA, and manages theremediation plan.
The EU Data Protection Directive and General Data Protection Regulation (GDPR) prohibits transfer of European
citizens’ personal data to non-European Union nations that do not meet EU’s “adequacy” standard for dataprotection. The U.S. Department of Commerce, together with the European Commission, developed a “Privacy
Shield” that allows U.S. companies to legally transfer and access personal data if they abide to a set of Privacy
Shield principles. The framework gives abiding companies assurance that the EU and Switzerland will consider
their practices “adequate” for privacy protection of EU and Swiss citizens. For more information about Veeva’s
certifications, please see https://www.veeva.com/privacy/.
Whenever possible, Veeva complies with provincial and statutory data protection and privacy regulations such as
CA SB 24. Veeva is also certified to ISO 27018, which are the privacy controls for cloud providers. An
independent attestation report is available upon request.

6.3

Service Organization Control Reports (SOC 2)
Veeva has developed a set of IT controls that are mapped to an IT Risk Control Matrix, which fulfills therequirements of SOC 2. Veeva initially completed a SOC 2 / Type II Report in Q1 2014 and renews the reportannually. For additional information on the SOC 2 standard, please see www.aicpa.org.

6.4

ISO 27001:2013
Veeva’s information security management program is certified ISO 27001:2013 compliant and provides
an independent attestation report for ISO 27001 compliance as part of its certification. The Information
Security Officer measures the information security program using a gap assessment against ISO 27001,
Annex A, and manages the remediation plan.

6.5

21 CFR Part 11
Veeva has conducted an internal compliance assessment to document compliance with the ERES regulations,such as 21 CFR Part 11 and EU Annex 11. For customer data, Veeva has implemented the required 21 CFRPart 11 controls for open systems, including document encryption at rest.

6.6

EU Annex 11

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Veeva has conducted an internal compliance assessment to document compliance with the EU Annex 11
regulation. For customer data, Veeva has implemented the required EU Annex 11 controls, including security
controls for data, data storage, audit trails, incident management, electronic signatures, and business continuity.

6.7

Sarbanes Oxley (SOX) - Section 404 (IT)
Veeva has developed a set of IT controls that are mapped to an IT Risk Control Matrix, which fulfills therequirements of SOX-IT.

6.8

Governance, Risk, and Compliance (GRC) Framework
As stated, Veeva uses ISO 27001 / 2 as a GRC framework that combines the IT system controls from the various
certifications and attestations mentioned above. Assessments of this framework are scheduled on a periodic
basis and are planned to minimize disruption to operational systems. Remediation plans for findings from theseassessments are monitored by Quality & Compliance.

6.9

Business Continuity / Disaster Recovery
Veeva has implemented a business continuity policy that outlines Veeva’s Business Continuity Plan (BCP).
The validity of Veeva’s BCP is tested on an annual basis.

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7 Information Security Policies
7.1

Policies and Practices (SLAs)
Veeva has implemented numerous policies to deliver the highest quality of service and security to our customers,
including:•Application Security Management Policy•

Business Continuity Policy•

Computer Systems Validation Policy•

Data Privacy Policy•

Information Security Policy•

IT Asset Management Policy•

Risk Management Policy•

Security Incident Management Policy

As new risks are identified, Veeva addresses these using analysis and risk reduction mechanisms. Whenappropriate, new requirements are added to the body of existing policies as updates or entirely new content.
To deliver the highest level of service, Veeva has adopted industry-leading practices for security standards andguidelines using a risk-based approach to assist in the implementation goals stated in our security policies.
This includes the ISO 27001 / 2 and selected NIST SP 800 series standards including NIST SP 800-30, Guide
for Conducting Risk Assessments.

7.2

Security Organization and Management
Veeva has a dedicated security team reporting to the Chief Information Security Officer and a Data
Protection Officer to ensure our products are compliant with security and privacy requirements worldwide.
The Information Security and Data Protection Officers help business managers, users, IT staff, and others
fulfill their information security and privacy responsibilities. Plans, policies, and procedures are in place toensure that there is accountability for the security and use of information assets.

3.5.2 Information Security Officer
Veeva’s Chief Information Security Officer (CISO) function reports directly to the head of Operations. Security
personnel receive ongoing training in all aspects of enterprise security from leading vendors and industry
experts. The Security team reporting to the CISO consists of 3 teams: Security Operations (SecOps), Security
Engineering (SecEng), Security Audit&Compliance.
The Chief Information Security Officer assesses external parties for information security compliance based on
industry standards such as ISO 27001, Trust Service Criteria, or shared assessments.
Veeva maintains relationships with various security related organizations, such as InfraGard, the Northern
California Regional Intelligence Center (NCRIC), NH-ISAC.

3.5.2 Security Operations
The Security Operations team is responsible for monitoring the Veeva Corporate and Veeva customer-facing
solutions for signs of possible mis-use or compromise along with the health of the security solutions used tosecure the environments. Critical security alerts are forwarded immediately, 24/7, to a rotating on-call resource.

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3.5.2 Security Engineering
The Security Engineering team primarily works with Veeva product teams to provide guidance early in the
product development phase (Security by Design). This team is also responsible for the maintenance of thetools such as the code security analysis solutions (SAST/DAST) and internal/external penetration testing.

3.5.2 Data Protection Officer
The Data Protection Officer (DPO) reports directly to Veeva’s general counsel, and ultimately, the Board of
Directors. Certifications include EU DPO Privacy Training and International Association of Privacy
Professionals (IAPP) CIPP/E exam. In addition to overseeing product compliance, the DPO engages directlywith our customers to explain Veeva’s transparent approach to privacy and how we are managing
requirements from governmental authorities.

7.3

Veeva Personnel Security and Training
All Veeva personnel undergo security training, and per Veeva’s logical access policies, employees andcontractors are granted systems access based on the principle of least privilege. Access is added during
onboarding and removed per employee exit procedures. An access review is also triggered whenever personnel
change job functions, and at least once per quarter for privileged accounts. Access is terminated on the last dayof employment or prior for departing personnel.

3.5.2 Security background checks
Where permitted by law, all Veeva employees are subject to criminal background check and identity verification
prior to commencing employment.

3.5.2 Veeva Employee Security and Awareness Training
Veeva has an information classification scheme to ensure such information has adequate protection ofconfidentiality, integrity, and availability. The Information Security & Privacy Procedures policy specifies
security controls including multi-factor authentication, replication, encryption, and monitoring requirements, bycontent category.
All new hires must undergo information security awareness training within their first week of employment.
Subsequent security awareness training is required annually for all active employees and contractors.
Personnel are assigned training on policies and procedures based on job function, and their compliance totraining requirements is monitored.

7.4

Data BreachAll personnel are trained to immediately report security incidents. Such breaches are handled via documented
procedural controls and reporting mechanisms. Timely customer notifications are part of this process.
Security incidents are documented, classified, investigated, escalated, and contained per the Security IncidentManagement Policy, and triaged by the Security Operations (SecOps) team. The investigation and collection ofevidence is managed through the corrective and preventative action (CAPA) system, which includes a continuous
improvement process.
As previously mentioned, Veeva automates the incident management notification process. Customers are
typically notified via email, which is escalated to phone if a reply is not received in a timely manner.

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8 Conclusion
In order to serve customers in highly regulated industries, Veeva adheres to the same rigorous requirements as ourcustomers. This includes the vital need to secure data in an increasingly open and networked environment.
And as an industry-leading cloud software provider, Veeva invests significant time and resources in cutting-edge
security, providing companies of all sizes a safer way to manage and share information both internally and across theirpartner ecosystem.
If you have any unanswered questions about Veeva’s technical and operational security policies and procedures, pleasecontact us at sitevaultsupport@veeva.com.

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About Veeva Systems
Veeva Systems Inc. is a leader in cloud-based software. Committed to innovation, productexcellence, and customer success, Veeva has more than 550 customers, ranging from theworld’s largest companies to small businesses. Veeva is headquartered in the San Francisco
Bay Area, with offices in Europe, Asia, and Latin America. For more information, visit
www.veeva.com.
Veeva Systems
Global Headquarters
Pleasanton, California, USA
4280 Hacienda Drive
Pleasanton, California 94588+1 925 452 6500 | info@veeva.com | veeva.com

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