Risk, resilience and compliance · API security · Tokenisation · Zero trust

Secure third-party integration boundary for regulated data: API gateway, mutual TLS, tokenisation and customer-held keys

A controlled edge for partners, fintech suppliers and SaaS platforms that need regulated data. Each partner is authenticated, authorised per scope, rate limited and logged, sensitive fields are tokenised, and everything is encrypted with keys you hold.

A reference architecture from EITSAA, not a named client system. Service limits, prices and product features change, so confirm current details before you commit to a design.

  • APRA CPS 234 (third-party information assets)
  • APRA CPS 230 (material arrangements)
  • Privacy Act 1988 and APP 8 and 11
  • PCI DSS v4.0.1 (scope reduction)
  • ISO/IEC 27001:2022
  • ACSC Essential Eight
  • SA ISMF

Architecture

Architecture diagram. Tinted boundaries show regions, accounts, networks and trust zones. Numbered arrows match the flow below.
Secure third-party integration boundary for regulated data: API gateway, mutual TLS, tokenisation and customer-held keys architecturePartner system to AWS WAF and Shield: TLS request. AWS WAF and Shield to API Gateway: filtered. API Gateway to Partner identity: authenticate. API Gateway to Integration service: authorised call. Integration service to Tokenisation service: tokenise. Tokenisation service to Token vault: store mapping. Tokenisation service to Regulated data store: minimal data. AWS KMS to Regulated data store: encrypt. Integration service to Event queue: queue updates. Regulated data store to Immutable audit log: log accessPartners and suppliersAWS · Sydney (ap-southeast-2)Integration boundary VPCRegulated data VPC · no internet routePartner systemFintech or SaaS supplierAWS WAF and ShieldRate limits, bot and IP rulesAPI GatewayMutual TLS, OAuth scopes,quotasPartner identityClient credentials,certificatesIntegration serviceValidation, schema,minimisationTokenisation serviceReplace sensitive fieldsToken vaultEncrypted mappingAWS KMSCustomer-managed keysRegulated data storeAurora, encrypted, privateEvent queueAsync partner updatesImmutable audit logCloudTrail, API logs, dataaccess1TLS request2filtered3authenticate4authorised call5tokenise6store mapping7minimal data8encrypt9queue updates10log accessPlatform servicesAWS IAMAmazonCloudWatchAWS CloudTrail
  • Network and edge
  • Security and identity
  • Compute and containers
  • Databases and data
  • Messaging, events and workflow
  • Monitoring, audit and analytics
  • Request or data flow
  • Asynchronous or optional
  • Boundary: region, account, network or trust zone

Request and data flow

  1. A partner calls the API over TLS 1.2 or higher. The public edge applies web application firewall rules, rate limits and DDoS protection before any application code runs.

  2. Filtered traffic reaches the API gateway, the single entry point for partners. There is no direct path to the data store or internal services.

  3. The gateway validates the partner's mutual TLS certificate and OAuth client credentials. Each partner has its own client, scopes, quota and expiry, so access can be revoked without affecting others.

  4. An authorised call reaches an integration service that validates the schema, applies field-level minimisation (only fields the partner is entitled to), and rejects anything unexpected.

  5. Sensitive values, such as card numbers, tax file numbers or account identifiers, are replaced with tokens before they travel to or from the partner. The partner works with the token and never sees the original value.

  6. The mapping between token and original value sits in a token vault inside the regulated data network. Only the tokenisation service, using narrow permissions, can read it.

  7. The regulated data store receives only what it needs. It has no internet route and accepts connections from named services in the core network.

  8. Encryption keys are customer-managed in KMS with separate administrators and users. Rotation and key access are logged, and a key can be disabled during an incident.

  9. Updates to partners are sent asynchronously through a queue, with retries, dead-letter handling and signed webhooks, so the boundary does not depend on partner uptime.

  10. API calls, authorisation decisions and data access are written to an immutable log. This is the evidence for CPS 234 reviews, partner disputes and incident investigations.

Components and why they were chosen

ComponentWhat it doesWhy this choice
AWS WAF and ShieldFilters malicious requests and absorbs volumetric attacks.Protects the single public entry point.
API Gateway with mutual TLS and OAuthAuthenticates partners, applies scopes and quotas, and records every call.One place to enforce policy for every partner.
Integration serviceValidates, minimises and maps data between your model and the partner's.Keeps partner formats out of your core systems.
Tokenisation service and vaultReplaces sensitive values with tokens, with the mapping held in a protected vault.Reduces exposure in the event of partner compromise, and reduces PCI DSS scope where cardholder data is involved.
AWS KMS with customer-managed keysEncrypts data and tokens, with logged use.You control the keys and can revoke access.
Event queueDecouples updates and handles retries.Isolates partner failure from your operations.
Immutable audit logRetains authentication, authorisation and data access records.Supports investigation and assurance.

Design decisions and trade-offs

Partner authentication

Mutual TLS plus OAuth 2.0 client credentials with per-partner scopes. Shared API keys are not used.

Why. Binds a request to a certificate and a scoped identity. Revocation is per partner.

Trade-off. Certificate lifecycle needs automation or it causes outages.

Tokenise or encrypt fields

Tokenise values that partners do not need in clear. Encrypt the rest with field-level keys.

Why. A token carries no value if leaked, and keeps partner systems out of scope.

Trade-off. Tokenisation adds a dependency and latency. Make the service highly available.

Pull or push

Prefer partners calling you through the gateway. Push through signed webhooks and queues for events.

Why. Reduces the number of outbound paths from the core network.

Trade-off. Webhook delivery needs retries and monitoring.

Network exposure

Public gateway where partners need internet access. Private connectivity or allow-listing for high-risk or high-volume partners.

Why. Matches exposure to risk.

Trade-off. Private connectivity takes longer to set up and has its own cost.

Data minimisation

Default deny on fields. Add fields per partner with a recorded purpose.

Why. Limits what a breach at a partner can expose, in line with the Australian Privacy Principles.

Trade-off. More onboarding work for each partner.

Well-architected pillars

Security

Defence in depth: edge filtering, strong partner identity, field minimisation, tokenisation, encryption with customer-held keys, private data networks and immutable logs.

Reliability

Multi-zone gateway and services, retries and dead-letter queues, circuit breakers per partner and clear degradation behaviour.

Performance

Gateway caching for reference data, connection reuse and asynchronous processing for non-urgent updates.

Cost optimisation

Gateway and WAF cost scales with traffic. Use usage plans and caching and avoid chatty polling by partners.

Operational excellence

Partner onboarding checklist, certificate rotation automation, quarterly access review and a documented offboarding path.

Sustainability

Reduce redundant partner calls with event delivery and caching.

Network, identity and data

Networking

Public edge services in the boundary VPC. Core services and data in a separate VPC with no internet route, reached through private endpoints. Egress to partners is by allow-list through an inspected path. Segmentation limits lateral movement.

Identity and least privilege

Each partner is a registered client with named technical and business contacts, scopes, quota and expiry. Staff access to the boundary and the vault is through the workforce identity provider with MFA and just-in-time elevation. Secrets and certificates are stored in a secrets service and rotated.

Data and encryption

Classify each data element, decide whether the partner needs it in clear, tokenised or at all, and record the purpose. Keep all copies in Australian regions unless an offshoring decision is approved and recorded. Define retention, deletion and return of data at end of the arrangement.

Security and compliance mapping

ControlHow this design addresses it
Third-party information assetsAssess the partner's security capability and restrict what they receive. CPS 234.
Material arrangementsFormal agreement terms, monitoring and notification supported by logs and usage reporting. CPS 230.
Protection of personal informationMinimisation, encryption and access control support APP 11, with cross-border disclosure considered under APP 8.
Protect stored account data and transmissionsTokenisation and strong cryptography help reduce PCI DSS scope. Scope still needs assessor confirmation.
Restrict administrative privileges and MFAJust-in-time admin access and MFA for staff. Essential Eight.
Logging and monitoringRetained, tamper-evident logs. ISO/IEC 27001:2022 and CPS 234.

Mappings show how the design supports each control. They are not certifications, and EITSAA does not claim IRAP assessment or compliance for any reference architecture.

Failure modes, targets and scaling

  • Target RTOMinutes for zone loss, with the gateway and tokenisation service deployed across zones. Regional recovery follows the owning operation's tolerance.
  • Target RPONear zero for committed transactions. Token vault is replicated and backed up with the data store.
  • Scaling and limitsGateway autoscaling, with per-partner quotas to protect core systems.
Failure modeMitigation
Partner credentials compromisedPer-partner revocation, certificate pinning to client identity, anomaly alerts on volume and pattern.
Partner sends malformed or malicious dataSchema validation, size limits and WAF rules, with dead-letter handling.
Tokenisation service unavailableMulti-zone deployment, circuit breaker and graceful degradation to reject rather than pass clear data.
Certificate expiryAutomated renewal, expiry alerts at 30, 14 and 7 days, and a tested manual fallback.
Partner outageQueues, retries and visibility of backlog to the business owner.
Over-sharing through scope creepQuarterly scope review and removal of unused scopes.

Observability and runbooks

  • Calls, errors, latency and quota use by partner.
  • Authentication failures and unusual patterns.
  • Tokenisation latency and error rate.
  • Certificate and secret expiry dates.

Cost drivers and levers

Gateway request charges, WAF rules, tokenisation compute, KMS requests and log storage.

  • Cache reference data at the gateway.
  • Use event delivery in place of polling.
  • Tier audit logs.
  • Share the boundary across partners rather than duplicating it.

Implementation and fit

Phased approach

  1. Inventory partners, data flows and data elements, and classify them.
  2. Stand up the gateway, WAF, partner identity and logging for one partner.
  3. Add tokenisation, field minimisation and customer-held keys.
  4. Onboard remaining partners, automate certificate rotation and run quarterly reviews.

Anti-patterns to avoid

  • Shared API keys across partners.
  • Partners with direct database access.
  • Clear sensitive data sent because the partner asked for it.
  • Logs that capture sensitive payloads.
  • No offboarding path for partners.

When to use it

  • Regulated entities and suppliers exchanging sensitive or regulated data with partners.
  • Organisations reducing PCI DSS or privacy exposure through minimisation.

When not to

  • Low-sensitivity integrations where a standard OAuth API and logging is proportionate.

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