Effective Date: August 27, 2026

Owner: CPO, Nicolas Lopez

Review Cycle: Annual

Confidential. Shared under NDA. Do not redistribute without Horizon's written consent.

1. Purpose

This document defines whether and how Horizon support personnel may access customer data, under what approval, and how that access is recorded. It exists because the offshore access map covers engineering access but not support, and customers in regulated industries ask about both.

2. Position

Customer Support can be granted access to customer data where it is necessary to help a customer navigate or interpret their own data. Access is not standing: it is granted for a stated purpose and recorded.

3. Approval

All support access to customer data is approved by the CPO, Nicolas Lopez. This is the single approval authority for support access. No other role can grant it.

4. Logging

Every access is logged. AWS actions are recorded in CloudTrail. Database access is reached only through the bastion host and is logged and monitored per the Database private access process.

5. Controls in force

6. Relationship to engineering access

Engineering access is governed separately and is geographically scoped:

Open item: read-only production CloudWatch access from Buenos Aires and Montevideo needs to be reconciled against the contents of the Bedrock guardrail log group. If that log group stores prompts and responses, it contains conversation content, and the access scope above must be narrowed by IAM accordingly. Pending confirmation from the CTO.

7. Revision History