Compliance is about 11% of the exam and the smallest section, but its questions lean on ideas from every other domain. A typical question names a regulation (PCI DSS, HIPAA, FedRAMP, GDPR, data sovereignty) and asks which combination of Google Cloud controls meets a stated requirement. The key skill is translating a requirement into a mechanism: where data may live (resource locations), who may touch it (IAM, Access Approval), whose keys protect it (CMEK, EKM), what leaves the boundary (VPC Service Controls) and what evidence you keep (audit logs).
Shared responsibility and shared fate
Google secures the infrastructure: facilities, hardware, the hypervisor, the global network and the managed service platforms. The customer secures what they configure and put on it: identities and IAM, data classification, network rules, encryption choices, guest OS and application code for IaaS, and logging.
| Service model | Google owns | Customer owns |
|---|---|---|
| IaaS (Compute Engine) | Hardware, hypervisor, physical and network infrastructure | Guest OS and patching, apps, data, network config, IAM, keys |
| PaaS (Cloud Run, App Engine, GKE Autopilot control plane) | Plus the runtime and platform | App code, data, IAM, service configuration |
| SaaS (Workspace) | Almost everything | Users, data sharing settings, access, devices |
- Google’s compliance certifications cover Google’s part. They do not make your workload compliant. You still must configure controls and keep your own evidence.
- Shared fate is Google’s term for going beyond division of tasks: secure-by-default settings, blueprints (the security foundations blueprint), landing-zone guidance, and the Risk Protection Program (cyber insurance backed by the posture data you share). Don’t confuse it with shared responsibility: it describes Google’s help, not a transfer of your duties.
- Customers remain the data controller under privacy laws. Google acts as processor under the Cloud Data Processing Addendum.
Scoping and technical needs
Start every compliance design by deciding what is in scope.
- Identify regulated data and systems: the cardholder data environment for PCI DSS, protected health information for HIPAA, controlled data for government regimes, personal data of EU residents for GDPR.
- Draw the boundary in the resource hierarchy: put regulated workloads in their own folder and projects (or an Assured Workloads folder), their own VPC, and their own logging and key projects. A smaller, well-segmented scope means a smaller audit.
- Check product coverage. Only certain services are covered by a given attestation or by a Business Associate Agreement. Use the Compliance Resource Center and the list of covered products, and block others with an organization policy (
gcp.restrictServiceUsage) or Assured Workloads restrictions. - Translate to technical needs by layer:
| Layer | Typical regulated requirements | Controls |
|---|---|---|
| Compute | Approved regions, hardened and patched images, tenant isolation, protection of data in use | Resource location policy, Shielded VMs, Confidential VMs, sole-tenant nodes, OS patching |
| Data | Encryption with customer-controlled keys, residency, classification, retention, deletion | CMEK or EKM, SDP discovery, resource locations, retention locks, lifecycle rules |
| Network | Segmentation, no public exposure, controlled egress, encrypted links | Separate VPCs and firewall policies, VPC Service Controls, Private Service Connect, HA VPN or MACsec, Cloud Armor, Secure Web Proxy |
| Storage | Immutable records, backups in region, access limits | Bucket Lock, uniform bucket-level access, CMEK, regional buckets |
| Access | Least privilege, MFA, separation of duties, periodic review | IAM groups, 2SV, PAM, Policy Intelligence recommendations, deny policies |
| Monitoring | Audit trails, retention, tamper-proofing, alerting | Audit logs including Data Access, locked log buckets, SCC, alerts |
Assured Workloads
Assured Workloads creates a workload (a folder with enforced controls) for a compliance regime, so you don’t have to hand-build guardrails.
- Regimes include FedRAMP Moderate and High, CJIS, IL2, IL4 and IL5 for US government, ITAR, HIPAA and HITRUST, plus regional and sovereignty packages (for example EU data boundary and sovereign controls, Canada, Australia, Japan, Israel, Saudi Arabia). Availability varies, so check the current list.
- What it configures: resource location restrictions, a restricted set of allowed services for the regime, CMEK/key requirements, personnel and support controls (for instance support only from US persons or EU staff), and enablement of Access Approval and Access Transparency where applicable.
- It applies the controls through organization policies on the folder, so projects inside inherit them. It does not create VPC Service Controls or network rules for you. Design those yourself.
- Monitoring: Assured Workloads reports compliance violations when a policy or setting drifts (a resource in a disallowed location, a changed organization policy) and suggests fixes. You can acknowledge or restore.
- Choose Assured Workloads when a regulation names a Google-supported regime or requires personnel controls, and a plain folder with org policies when only data location or CMEK is needed.
Access Transparency, Access Approval and key justification
By default Google staff cannot read your content, except limited cases. These controls give you visibility and control over the exceptions.
| Control | What it does |
|---|---|
| Access Transparency | Logs actions by Google staff on your content (who, when, why, which resource) into Cloud Logging as near-real-time entries, with a justification. Needs an eligible support package or Assured Workloads. Roles: accesstransparency.admin, accesstransparency.viewer |
| Access Approval | You approve or dismiss access requests from Google support or engineering before access happens. Requests have an expiry (an approval lasts a fixed window and unanswered requests expire). Notify by email or Pub/Sub. Approvals are signed with a key. Requires Access Transparency. Enroll per service. Role: accessapproval.approver. Some automatic or legally required access isn’t covered |
| Key Access Justifications (KAJ) | With Cloud EKM, every request to your external key manager carries a justification reason (customer-initiated, Google-initiated review, response to an alert, legal request). Your key manager policy can allow or deny based on the reason, so you can refuse Google-initiated access. Needs an EKM key and a supported partner |
| Cloud KMS key revocation | Disabling or destroying a CMEK makes data unreadable even to Google systems |
Rule of thumb: Transparency = see it, Approval = allow it, KAJ and EKM = control the key behind it.
Data residency and regionalisation
- The
gcp.resourceLocationsorganization policy restricts where supported resources can be created. Use value groups such asin:eu-locationsorin:us-locations, or specific regions. It applies at organization, folder or project level, doesn’t move existing resources, and covers only supported services (check the list). Resources can be regional, dual-region, multi-region or global, and multi-region location names in your policy must match the intended geography. - Pick regional services and buckets for tight residency, and avoid global resources for regulated data. Note that some metadata stays global (IAM policies, project metadata).
- Data residency is not the same as sovereignty. Sovereignty adds control over who accesses data (personnel controls, Access Approval, EKM held in-country, Assured Workloads sovereign controls, and partner-operated clouds).
- Cross-border transfers (GDPR): use the data processing terms and standard contractual clauses, restrict locations, keep logs and backups in the same region too, and watch default multi-region choices (BigQuery datasets, Cloud Storage buckets, log buckets).
- Make backups, log buckets, key rings (KMS location must match), and Pub/Sub message storage policies follow the same location rule. Pub/Sub has a message storage policy that restricts where messages are stored.
Mapping regulations to controls
| Requirement (paraphrased) | Google Cloud approach |
|---|---|
| Restrict access to cardholder data (PCI) | Dedicated projects and VPC, firewall rules by service account, VPC-SC perimeter, IAM groups with least privilege, PAM for admin |
| Network segmentation to reduce scope | Separate VPCs or Shared VPC service projects, no peering to out-of-scope networks, hierarchical firewall policies, private connectivity only |
| Strong cryptography and key management | CMEK (Cloud HSM for hardware-backed), documented rotation, key admin versus user separation, TLS policies with minimum 1.2 |
| Log and monitor all access (PCI, HIPAA, ISO) | Admin Activity and Data Access logs enabled on in-scope projects, aggregated sink, locked retention bucket, SCC alerts, time-synchronised logs |
| Retain records for years (HIPAA six years, others vary) | Log buckets with long retention and lock, Cloud Storage with Bucket Lock and retention policy, backups |
| Sign a BAA, use only covered services | Execute the BAA, restrict allowed services with org policy or Assured Workloads |
| Data stays in the EU / a country | gcp.resourceLocations, regional resources, Assured Workloads, EKM in-country |
| Customer controls encryption keys | CMEK / EKM, gcp.restrictNonCmekServices |
| Remove personal data on request or after a period | SDP discovery to locate, lifecycle rules to delete, de-identify for analytics |
| Prove who at the provider accessed data | Access Transparency + Access Approval |
| Prevent data leaving the environment | VPC Service Controls, org policies, DLP |
| Vulnerability management | Artifact Analysis, VM Manager vulnerability reports, SCC, patch deployments |
| Periodic access review | IAM Recommender, Policy Analyzer, group reviews |
Network and access segmentation in detail
For regulated segments: place the regulated VPC in its own host project, allow traffic only through firewall policy rules that name approved sources, deny everything else, and use VPC-SC so even valid credentials cannot move data to a project outside the perimeter. Use separate Cloud Identity groups for in-scope admins, PAM for elevation, and Context-Aware Access to require managed devices. Verify with Network Intelligence Center connectivity tests and Firewall Insights.
Audit log coverage
Compliance auditors want a complete, tamper-resistant, retained trail.
- Turn on Data Access logs for all in-scope services (they are off by default), cover ADMIN_READ, DATA_READ and DATA_WRITE, and exempt only noisy non-human accounts.
- Export through an organization-level aggregated sink to a locked log bucket or a Cloud Storage bucket with retention lock, so neither project owners nor attackers can erase it.
- Retain for the longest period any regulation in scope requires. Admin Activity in
_Requiredis kept 400 days only, so export if you need longer. - Keep Access Transparency logs, VPC Flow Logs (if segmentation evidence is needed), DNS logs, and SCC findings for incident evidence.
- Restrict who reads and deletes them, with separation of duties between those who run the platform and those who manage logs.
Evidence, reports and assurance tools
| Tool | Purpose |
|---|---|
| Compliance Resource Center | Lists certifications, covered products, whitepapers and mappings per regulation |
| Compliance Reports Manager | Download Google’s audit reports and certificates (ISO 27001, SOC 1/2/3, PCI DSS Attestation of Compliance, FedRAMP) for your own auditors |
| Audit Manager | Assess workloads against a chosen framework, see which controls pass, and generate audit reports with evidence (to Cloud Storage), with remediation guidance |
| Security Command Center compliance | Continuous monitoring of findings mapped to CIS, PCI DSS, NIST 800-53 and ISO 27001 |
| Posture Management | Define a posture, deploy and detect drift against it |
| Assured Workloads monitoring | Detects violations of the regime’s controls |
| CIS Google Cloud Foundations Benchmark | Hardening checklist that SCC and many tools implement |
| Organization Policy | The enforcement side, preventing non-compliant configuration |
| Cloud Asset Inventory | Point-in-time and historical inventory for scoping and evidence |
Choosing the control
| Scenario | Answer |
|---|---|
| Government agency needing FedRAMP High and US-person support | Assured Workloads with the matching regime |
| Must approve every time Google engineers touch data | Access Approval (plus Access Transparency) |
| Must refuse access to keys if the reason isn’t acceptable | Cloud EKM with Key Access Justifications |
| Keep all resources in the EU | gcp.resourceLocations with in:eu-locations (or Assured Workloads EU) |
| Show an auditor Google’s ISO and SOC reports | Compliance Reports Manager |
| Automated evidence for a framework | Audit Manager |
| Reduce PCI audit scope | Segment the cardholder environment into dedicated projects and VPC |
| Records must survive deletion attempts | Bucket Lock, locked log bucket |
Common traps
- A Google certification does not make your application compliant.
- Resource-location policy stops new resources only, and not every service honours it.
- Assured Workloads doesn’t configure VPC-SC or firewall rules.
- Access Approval requires Access Transparency, and approval is not unlimited, because it expires.
- Data Access logs must be on before you need them.
- A regional bucket with a multi-region KMS key (or the reverse) can break residency.
- Residency (where data sits) is not sovereignty (who can reach it).
Exam checklist
- Explain shared responsibility across IaaS, PaaS and SaaS, and shared fate.
- Determine which projects, data, networks and services are in regulatory scope.
- Configure Assured Workloads, org policies, Access Transparency, Access Approval and KAJ.
- Enforce regionalisation with resource locations and regional services.
- Map PCI, HIPAA, GDPR, FedRAMP-style requirements to network, access, key and logging controls.
- Build complete audit log coverage with long, locked retention.
- Use Compliance Reports Manager, Audit Manager and SCC for evidence.