Data Protection by Design and by Default
AWS Nitro System is the underlying platform for all modern Amazon EC2 instances. It is a combination of purpose-built server designs, data processors, system management components, and specialized firmware which provide the underlying platform for all Amazon EC2 instances launched since the beginning of 2018. By design the Nitro System has no operator access; it means that there is no mechanism for any system or person to log in to Amazon EC2 Nitro hosts, access the memory of Amazon EC2 instances, or access any customer data stored on local encrypted instance storage or remote encrypted Amazon EBS volumes. If any AWS operator, including those with the highest privileges, needs to do maintenance work on an Amazon EC2 server, they can only use a limited set of authenticated, authorized, logged, and audited administrative APIs. None of these APIs provide an operator the ability to access customer data on the Amazon EC2 server. Because these are designed and tested technical restrictions built into the Nitro System itself, no AWS operator can bypass these controls and protections. This is also reflected in the AWS Service Terms clause on AWS Nitro System which includes “There are no technical means or APIs available to AWS personnel to read, copy, extract, modify, or otherwise access Your Content on an AWS Nitro System EC2 instance or encrypted-EBS volume attached to an AWS Nitro System EC2 instance”. You can find additional details about Nitro System's security design and the independent affirmation of these security capabilities from NCC Group, a leading cybersecurity consulting firm, in the public documentation (see AWS Nitro System, The Security Design of the AWS Nitro System, AWS Nitro System gets independent affirmation of its confidential compute capabilities).
Additionally, any time a user or an application tries to use the AWS Management Console, the AWS API, or the AWS CLI, a request is sent to AWS. The AWS service receives the request and executes a set of several steps to determine whether to allow or deny the request, according to a specific policy evaluation logic. Except for root credential requests, all requests on AWS are denied by default (the default deny policy is applied). This means that everything that is not explicitly allowed by the policy is denied. In the definition of policies and as a best practice, AWS suggests that you apply the least privilege principle.
This approach aligns with Article 25 of the GDPR, which states that “the controller shall implement appropriate technical and organizational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed”.
AWS also provides tools to implement infrastructure as code, which is a powerful mechanism for including security from the beginning of the design of an architecture. AWS CloudFormation provides a common language to describe and provision all infrastructure resources, including security policies and processes. With these tools and practices, security becomes part of your code and can be versioned, monitored, and modified (with a versioning system) according to the requirements of your organization. This enables data protection by design, because security processes and policies can be included in the definition of your architecture and can also be continuously monitored by security measures in your organization.
AWS Nitro Enclaves
AWS Nitro Enclaves enhances AWS's data protection by design capabilities by providing an isolated compute environment that helps customers process highly sensitive data with an additional layer of security. Nitro Enclaves are isolated virtual machines that are created from Amazon EC2 instance resources but remain completely isolated from the parent instance, other applications, and the cloud provider itself. This isolation is enforced through the AWS Nitro System's hardware-based security and attestation. When processing personal data under the GDPR, Enclaves provide a trusted execution environment where sensitive operations like encryption, decryption, or data tokenization can be performed in complete isolation. The Enclaves' cryptographic attestation model ensures that only authorized code can run within the Enclave and access sensitive data or cryptographic keys. Integration with AWS KMS allows Enclaves to use special encryption keys that can only be accessed from within a properly attested Enclave, providing an additional control for protecting sensitive data processing operations. This capability is particularly valuable for applications handling special categories of personal data under the GDPR, or for implementing privacy-preserving computing solutions where data must remain encrypted throughout its lifecycle. Nitro Enclaves support the principle of data protection by design by providing a verifiable, isolated environment for sensitive data processing that's built into the infrastructure level.
