Controls

Every control, with the page that proves it.

Name: Aeira
Brand: Sparcle

A tick means in place today. Caveats sit next to the tick. This is our self-assessment, not an auditor's attestation. We do not hold a SOC 2 report today.

By category Map to a framework

Independent assurance

Independent assessment of the Google data path (Google CASA)

TAC Security checked 48 requirements. Not a pentest, not SOC 2.

In place ASSURE-01 Evidence SOC2 CC4.1 Verified 2026-10-08
Third-party penetration test

Booked with an external firm, testing in October 2026. Summary published when done.

In progress ASSURE-02 Evidence SOC2 CC4.1 Verified 2026-10-08
SOC 2 Type II report

Not held today. We do not imply otherwise.

Planned ASSURE-03 Evidence SOC2 Verified 2026-10-08
ISO 27001 certification

On the roadmap, no committed date.

Planned ASSURE-04 Evidence ISO 27001 Verified 2026-10-08
Annual penetration test cadence

Follows the first test. On the internal security roadmap.

Planned ASSURE-05 Evidence SOC2 CC4.1 Verified 2026-10-08

Release integrity

macOS builds signed with Apple Developer ID and notarized

Issued to Sparcle Inc., ticket stapled. Verify with spctl.

In place REL-01 Evidence SOC2 CC6.8 Verified 2026-10-08
Windows installer signed with an EV certificate

SSL.com EV, key in a cloud HSM. SmartScreen can still warn.

In place REL-02 Evidence SOC2 CC6.8 Verified 2026-10-08
Signed SHA-256 manifest for every release

Minisign signature over all artifacts. Key rotated 2026-09-30, previous key still published.

In place REL-03 Evidence SOC2 CC6.8 Verified 2026-10-08
CycloneDX SBOM per release

Commit-pinned, published with the release.

In place REL-04 Evidence SOC2 CC7.1 Verified 2026-10-08
Independent malware scan lookup per release

Keyed to each file's hash.

In place REL-05 Evidence SOC2 CC7.1 Verified 2026-10-08
Signed auto-updates

Ed25519 key compiled into the client; unverified bundles refused.

In place REL-06 Evidence SOC2 CC6.8 Verified 2026-10-08
Server images signed (cosign keyless)

Fulcio and Rekor transparency log; admission policy examples.

In place REL-07 Evidence SOC2 CC6.8 Verified 2026-10-08
SLSA build provenance

Not claimed. Builds run on our own machines, which cannot attest to themselves.

Planned REL-08 Evidence SLSA Verified 2026-10-08

Change management

Secret scan on every commit

Sub-second scan of the staged diff.

In place CHG-01 Evidence SOC2 CC8.1 Verified 2026-10-08
Advisory and licence scan at release

Rust and npm advisories, licences, against a frozen build point. Pass, fail or unknown.

In place CHG-02 Evidence SOC2 CC7.1 Verified 2026-10-08
Server image gate on CRITICAL and HIGH findings

Trivy blocks the push; signing runs only after it passes.

In place CHG-03 Evidence SOC2 CC7.1 Verified 2026-10-08
Independent pre-merge review of sensitive changes

Being introduced for auth, crypto, licensing, audit chain and egress. Today automated gates approve.

In progress CHG-04 Evidence SOC2 CC8.1 Verified 2026-10-08
Claims checked in the build

A guard fails the build if a claim we cannot defend reappears.

In place CHG-05 Evidence SOC2 CC2.3 Verified 2026-10-08

Data protection

AES-256-GCM envelope encryption with per-tenant keys

Pluggable KMS. Local backend production-tested.

In place DATA-01 Evidence HIPAA 164.312(a)(1), ISO A.10 Verified 2026-10-08
Desktop data encrypted at rest (SQLCipher)

Caveat: a recovery copy of the device key sits on disk. Enforce FileVault or BitLocker.

In place DATA-02 Evidence ISO A.10 Verified 2026-10-08
TLS for all data in transit

Ingress with HSTS, Postgres, Redis, LLM calls. mTLS optional.

In place DATA-03 Evidence SOC2 CC6.7, HIPAA 164.312(e) Verified 2026-10-08
Cryptographic erasure on request

Per-tenant key destruction with a sealed receipt.

In place DATA-04 Evidence GDPR Art. 17 Verified 2026-10-08
PII masked before any model call

Always-on regex floor; free-text names need the model engine on.

In place DATA-05 Evidence GDPR Art. 25 Verified 2026-10-08
AWS KMS and Vault Transit backends

Reference implementations in integration testing.

In progress DATA-06 Evidence ISO A.10 Verified 2026-10-08
Named-entity PII model on every platform

Bundled on Apple Silicon; a separate scanner elsewhere. Off until an admin turns it on.

In progress DATA-07 Evidence GDPR Art. 25 Verified 2026-10-08
FIPS 140-3 validated crypto module

Algorithms are FIPS-eligible; validation pending.

Planned DATA-08 Evidence FIPS Verified 2026-10-08

Identity and access

SSO with OIDC or SAML

Okta, Entra ID, Google Workspace, Auth0, Zoho, any OIDC.

In place IAM-01 Evidence SOC2 CC6.1, HIPAA 164.312(d) Verified 2026-10-08
SCIM 2.0 provisioning and deprovisioning

Standard /scim/v2 mount; per-org tokens issued and revoked by admins.

In place IAM-02 Evidence SOC2 CC6.2, SOC2 CC6.3 Verified 2026-10-08
MFA enforced at your identity provider

Bolt accepts the IdP's assertion. We recommend MFA for every admin.

In place IAM-03 Evidence SOC2 CC6.1 Verified 2026-10-08
Role-based access at several layers

Session, admin-only, scope checks, per-tenant ACL with no admin bypass.

In place IAM-04 Evidence SOC2 CC6.1, ISO A.9 Verified 2026-10-08
Privileged actions refuse when unaudited

PII reveal and crypto-shred refuse if auditing is off.

In place IAM-05 Evidence SOC2 CC6.1 Verified 2026-10-08

Audit and logging

Tamper-evident audit chain

Merkle-sealed, Ed25519-signed.

In place AUD-01 Evidence SOC2 CC7.3, HIPAA 164.312(b) Verified 2026-10-08
Standalone offline verifier

One binary, no database, no KMS, no network. Sample bundle pre-NDA.

In place AUD-02 Evidence HIPAA 164.312(c) Verified 2026-10-08
Serving region sealed into the audit chain

Editing it breaks the signature.

In place AUD-03 Evidence GDPR Art. 30 Verified 2026-10-08
SIEM forwarder (Splunk, Sentinel, syslog)

Off by default. Best-effort, no retry buffer.

In place AUD-04 Evidence SOC2 CC7.2 Verified 2026-10-08
Audit-seal operation itself sealed

Still writes a log line, not a sealed record.

In progress AUD-05 Evidence SOC2 CC7.3 Verified 2026-10-08

Endpoint and network

No telemetry; every outbound host published

Only an update check leaves on its own.

In place END-01 Evidence SOC2 CC6.6 Verified 2026-10-08
Watch what Bolt sends, on your own machine

Read-only script names each connection against the list.

In place END-02 Evidence SOC2 CC2.3 Verified 2026-10-08
Every local port and process disclosed

Loopback only, mapped to MITRE ATT&CK.

In place END-03 Evidence SOC2 CC2.3 Verified 2026-10-08
Managed deployment with MDM and Group Policy

Force-install extension; settings pinned.

In place END-04 Evidence SOC2 CC5.1 Verified 2026-10-08
Default-deny network policy for self-hosted

Shipped in the Helm chart. Source-IP limits and mTLS are yours to add.

In progress END-05 Evidence SOC2 CC6.6 Verified 2026-10-08

AI agent safety

Agent authority is named, never inferred

Four controls between hostile content and an action.

In place AI-01 Evidence OWASP LLM Verified 2026-10-08
Unknown is never reported as clean

Four places the product says unknown.

In place AI-02 Evidence SOC2 CC7.1 Verified 2026-10-08
Model runs where you choose

On-prem, in-tenant cloud or public API. Minimum privacy tier enforceable.

In place AI-03 Evidence GDPR Art. 28 Verified 2026-10-08

Vulnerability and incident response

Vulnerability disclosure policy with safe harbor

1 business day to acknowledge; security.txt published.

In place VIR-01 Evidence ISO A.16 Verified 2026-10-08
Patch targets: critical 7, high 30, medium 90 days

Signed patch releases.

In place VIR-02 Evidence SOC2 CC7.1 Verified 2026-10-08
Documented incident response, SEV1 to SEV4

Five phases, acknowledgement and patch targets.

In place VIR-03 Evidence SOC2 CC7.4, HIPAA 164.308(a)(6) Verified 2026-10-08
Breach notification clauses

HIPAA 60-day and GDPR 72-hour for vendor-side incidents.

In place VIR-04 Evidence GDPR Art. 33 Verified 2026-10-08

Privacy and subprocessors

Sub-processor disclosure with 30-day notice

Separates customer sub-processors from Sparcle's own.

In place PRIV-01 Evidence GDPR Art. 28, SOC2 CC9.2 Verified 2026-10-08
Customer data never hosted by Sparcle

Every shipping topology keeps data in your perimeter.

In place PRIV-02 Evidence GDPR Art. 28 Verified 2026-10-08

Company

Verified legal entity

Delaware C-corp, verified by Apple and SSL.com.

In place CO-01 Evidence SOC2 CC1.2 Verified 2026-10-08
Confidentiality and IP agreements for all personnel

Condition of engagement.

In place CO-02 Evidence ISO A.7 Verified 2026-10-08
Background checks

Policy and vendor not yet adopted.

Planned CO-03 Evidence SOC2 CC1.4 Verified 2026-10-08
Annual security awareness training

Not yet running.

Planned CO-04 Evidence SOC2 CC2.2, HIPAA 164.308(a)(5) Verified 2026-10-08
Security policy pack

Policies for change, fraud risk and secure SDLC on the internal roadmap.

Planned CO-05 Evidence SOC2 CC1.5, SOC2 CC5.3 Verified 2026-10-08
Independent board oversight

No independent board seated yet.

Planned CO-06 Evidence SOC2 CC1.2 Verified 2026-10-08

Map to a framework

How our controls map to the frameworks your auditor uses.

Each row names a control, the evidence behind it, and its status: In place, In progress or Planned.

SOC 2 HIPAA GDPR ISO 27001

SOC 2 Trust Services Criteria

We do not hold a SOC 2 report today. The rows below are our self-assessment, not an auditor's attestation.

CC1. Control environment

CC1. Control environment
Control	Evidence	Status
CC1.1 Demonstrates commitment to integrity and ethical values	Sparcle Proprietary License; founder code-of-conduct (internal)	In place
CC1.2 Board oversight	Sparcle Inc. is incorporated in Delaware; no independent board seated yet	Planned
CC1.3 Organizational structure	Same as CC1.2	Planned
CC1.4 Personnel competence	Background-check policy on the internal security roadmap	Planned
CC1.5 Accountability for internal controls	Policy pack rollout on the internal security roadmap	Planned

CC2. Communication and information

CC2. Communication and information
Control	Evidence	Status
CC2.1 Quality information for internal control	Operations runbook, PII architecture doc, disaster-recovery doc, SIEM export guide (shared under NDA)	In place
CC2.2 Internal communication of objectives and responsibilities	Annual security awareness training on the internal security roadmap	Planned
CC2.3 External communication	This evidence map; Sub-Processor Disclosure; published compliance README	In place

CC3. Risk assessment

CC3. Risk assessment
Control	Evidence	Status
CC3.1 Specifies suitable objectives	Internal production-readiness audit (available under NDA)	In place
CC3.2 Identifies and analyzes risk	Internal risk register (available under NDA); 30+ classified S1-S4 risks	In place
CC3.3 Considers potential for fraud	Policy pack on the internal security roadmap	Planned
CC3.4 Identifies and assesses changes	Change-management policy on the internal security roadmap	Planned

CC4. Monitoring activities

CC4. Monitoring activities
Control	Evidence	Status
CC4.1 Ongoing and separate evaluations	Prometheus and curated alerts in the Helm chart; a third-party penetration test is booked and not yet performed, and annual cadence thereafter is on the internal security roadmap	In progress
CC4.2 Internal communication of deficiencies	Incident response framework published at /trust/incident-response: five phases, named intake at [email protected] via /.well-known/security.txt, acknowledgement and patch targets stated per severity	In place

CC5. Control activities

CC5. Control activities
Control	Evidence	Status
CC5.1 Selects and develops control activities	Helm chart with hardened defaults	In place
CC5.2 Selects and develops technology controls	Operations runbook, Production Hardening Checklist (shared under NDA)	In place
CC5.3 Deploys through policies and procedures	Policy pack rollout on the internal security roadmap	Planned

CC6. Logical and physical access

CC6. Logical and physical access
Control	Evidence	Status
CC6.1 Logical access security	Session middleware, admin-only middleware, per-handler OAuth scope checks, identity module, authorization module. Source-IP restriction and mTLS on admin endpoints are ingress-layer controls you configure; the chart does not ship them.	In place
CC6.2 Authorization and authentication of users	Authorization enforcement module, CSRF middleware (enforcing by default), SCIM 2.0 server at the standard /scim/v2/* mount point: full Users CRUD, with group membership set through the Users PATCH surface rather than a separate /Groups endpoint	In place
CC6.3 Modification or removal of access	SCIM token issue / list / revoke via an authenticated admin endpoint	In place
CC6.4 Restricts physical access	Not applicable. Sparcle does not operate physical infrastructure; customer-owned cloud.	In place
CC6.5 Discontinues access	Per-person GDPR erasure (revokes OAuth grants, deletes sessions and credentials); per-org KMS crypto-shred via an authenticated admin endpoint	In place
CC6.6 Restricts external access	Helm chart NetworkPolicy template, default-deny with explicit allow, enabled in the production values file. Source-IP restriction and mTLS are yours to add at the ingress; we do not ship them and do not claim them.	In progress
CC6.7 Transmission of data	TLS at ingress (cert-manager); HSTS and security headers; session cookies Secure and SameSite	In place
CC6.8 Prevention and detection of unauthorized software	Cosign keyless signing and admission policies (Sigstore Policy Controller, Kyverno examples)	In place

CC7. System operations

CC7. System operations
Control	Evidence	Status
CC7.1 Detection of vulnerabilities	Server (container) path: the Trivy gate blocks CRITICAL and HIGH against the pushed image digest with a non-zero exit, and cosign keyless signing runs only after it passes. The SBOM attached in that pipeline is the builder's SPDX attestation; the CycloneDX SBOM is produced by a separate step, not by that workflow. Desktop path: a two-tier gate runs a secret scan on every commit and a full secrets, advisory and licence scan at release against a frozen build point.	In progress
CC7.2 Monitoring of system performance	Prometheus metrics; 8 alert groups plus audit hardening alerts in the chart	In place
CC7.3 Evaluation of security events	Merkle-sealed audit chain covering authorization decisions, retrieval access, tool invocations, model calls, agent decisions, admin policy changes, the security-relevant identity transitions (sign-in, sign-out, session delegation and revocation, session attach) and the privileged key and identity operations (KMS rotation and crypto-shred, PII reveal, SCIM token issue and revoke). It does NOT yet cover the audit-seal operation itself, which still emits a log line rather than a sealed record; OAuth token refresh and the read-only SCIM token list are excluded on purpose and pinned by tests. SIEM forwarder with Splunk, Sentinel and syslog backends, off by default.	In progress
CC7.4 Incident response	Operations runbook, Incident Workflow (shared under NDA; summarized publicly on /trust/incident-response)	In place
CC7.5 Recovery from incidents	Disaster-recovery documentation (shared under NDA)	In place

CC8. Change management

CC8. Change management
Control	Evidence	Status
CC8.1 Authorizes, designs, develops, configures changes	Develop and configure: CI workflow (push and PR triggers), deploy workflow with Trivy gate, signed release artifacts. Authorize: independent pre-merge review is being introduced for changes to authentication, cryptography, licensing, the audit chain, and egress paths; today automated gates approve the merge. Until that review control is operating, we do not claim this criterion in full.	In progress

CC9. Risk mitigation

CC9. Risk mitigation
Control	Evidence	Status
CC9.1 Identifies, selects, develops risk mitigation	Backup CronJob in chart with fail-closed S3 destination guard	In place
CC9.2 Assesses and manages risks of business partners	Sub-Processor Disclosure	In place

HIPAA Security Rule

Sparcle ships HIPAA-deployable software that customers run in their own infrastructure. Deployable, not certified. A Business Associate Agreement is executable per customer. Controls on the customer side stay with the customer, per the deployment topology.

Standard	Implementation specification	Evidence	Status
164.308(a)(1)(i) Security Management Process	Required risk analysis	Internal risk register	In place
164.308(a)(3) Workforce Security	Authorization / supervision / termination	Pending on the internal security roadmap	Planned
164.308(a)(5) Security Awareness and Training	Required	Pending on the internal security roadmap	Planned
164.308(a)(6) Security Incident Procedures	Required response	Operations runbook, Incident Workflow	In place
164.308(a)(7) Contingency Plan	Required backup and DR	Disaster-recovery documentation; backup CronJob	In place
164.312(a)(1) Access Control	Unique user id, automatic logoff, encryption	Session middleware; per-tenant CMK envelope encryption of stored secrets; conversation content sealed at rest	In place
164.312(b) Audit Controls	Required	Merkle-sealed audit chain	In place
164.312(c) Integrity	Required	Audit-chain Merkle root and Ed25519 signing	In place
164.312(d) Person or Entity Authentication	Required	OIDC, SAML, SCIM via identity module	In place
164.312(e) Transmission Security	Required encryption	TLS ingress and DB TLS (SSL_MODE=require)	In place
164.314(a) Business Associate Contracts	Required	Customer BAA template; Anthropic BAA in progress	Planned

GDPR, article by article

Article	Requirement	Evidence	Status
Art. 5(1)(f) Integrity and confidentiality	Appropriate security	Aggregate of CC6 and CC7 above	In place
Art. 17 Right to erasure	Erasure on request	Per-person erasure (self-service or admin DSAR) with a receipt; sealed audit records are retained. Per-org crypto-shred via an authenticated admin endpoint; tenant-scoped KMS shred at the trait layer (LocalKms production-tested; AwsKms, VaultKms reference impls in integration testing)	In place
Art. 25 Data protection by design	Pseudonymization and encryption by default	PII pseudonymization at LLM boundary and at tool-result to history boundary; per-tenant CMK envelope encryption of stored secrets; conversation content sealed at rest	In place
Art. 28 Processor obligations	Sub-processor disclosure and DPA	Sub-Processor Disclosure	In place
Art. 30 Records of processing activities	Required logging	Audit chain and customer-side SIEM forwarder	In place
Art. 32 Security of processing	Pseudonymization, encryption, resilience, testing	Aggregate of above	In place
Art. 33 Notification of personal-data breach	72-hour notification	Incident response framework published at /trust/incident-response, with contractual notification in the executed DPA. Sparcle holds no customer personal data, so the controller notification duty sits with the customer; we supply what they need to meet it	In place
Art. 35 DPIA	Required for high-risk processing	Customer-driven (Sparcle is the processor; controller does the DPIA)	Planned

ISO 27001, selected Annex A controls

We do not hold ISO 27001 certification. These rows are alignment evidence. Certification is a separate engagement.

Annex A	Control	Evidence	Status
A.5 Information security policies	Policies in place	Pending on the internal security roadmap	Planned
A.8 Asset management	Asset register	Internal asset register	Planned
A.9 Access control	Authorisation, removal	Same as CC6	In place
A.10 Cryptography	Key management	Pluggable KMS via aeira-traits Kms trait (Local production-tested; AWS, Vault reference impls in integration testing); cosign signing for releases	In place
A.12 Operations security	Logging, monitoring, vulnerability management	Same as CC7	In place
A.13 Communications security	Network security	Helm NetworkPolicy; TLS	In place
A.14 System acquisition, development, maintenance	Secure development	Secure SDLC policy pending on the internal security roadmap	Planned
A.16 Information security incident management	Incident response	Operations runbook, Incident Workflow	In place
A.17 Business continuity	Plan and tests	Disaster-recovery documentation	In place
A.18 Compliance	Regulatory compliance	This map	In place

Status key

What the labels mean.

In place. Implemented, and evidence exists in the codebase, runbook or shipped artifacts.
In progress. Partly implemented. The gap is named in the row.
Planned. Not yet implemented. It stays on this page until it is.

This map is refreshed by hand when the thing it describes changes. If you find a row that has gone stale, tell us and we will treat it as a finding.

Need to map a control we have not listed?

Email us and we will add it for the next reviewer.

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