# Trust & Architecture — 40° South Guard

> How Guard works: architecture, security, and regulatory mapping for CISOs, compliance teams, and IT architects.

Trust & Architecture

# How Guard works. 

Guard is the evidence layer for Australian AI. It captures the AI calls it sees, checks them against the Australian regulations that apply, and signs each record into a 7-year tamper-evident audit trail. 

This page explains how, where it runs, and how it maps to your regulatory obligations. It's written for the people who evaluate Guard before recommending it: CISOs, heads of compliance, IT architects, and security teams. 

Contents 

## Architecture overview

Guard captures the AI calls you give it two ways. It ingests the AI platforms' own compliance feeds, where it reads the real prompts and responses. And it takes a live connection for the AI you build: one base URL, one key, no SDK change. Either path runs only in Australia, on Google Cloud in Sydney (australia-southeast1). 

The AI you build (live proxy)

One base URL, one key, no SDK change. Guard sees each call in-line and signs the record before the response returns. Nothing is reconstructed after the fact.

The AI you buy (ingest)

Claude Enterprise, ChatGPT Enterprise, and Microsoft 365 Copilot publish compliance feeds. Guard ingests them into the same evidence trail. An ingested record is only as complete as the platform's export.

**On every live call**, Guard performs this sequence before the request reaches the AI model: 

1. 1  
PII scan : scans prompt text and attachment content for Australian PII types
2. 2  
Prompt injection scan : checks for known injection patterns in both text and documents
3. 3  
Jurisdiction check : verifies the destination meets your data residency policy
4. 4  
Policy enforcement : applies your configured action (block, mask, flag and allow)
5. 5  
Attestation generation : creates a cryptographically signed record of the call and all check results
6. 6  
Evidence storage : writes the attestation to an immutable, append-only evidence vault with 7-year retention

Every API call is intercepted, scanned, attested, and evidence written to the vault, before the request reaches the AI provider.

## Infrastructure and security

Guard runs on infrastructure designed to meet the security requirements of Australian regulated industries. 

Hosting

Google Cloud Platform, Sydney region (australia-southeast1). IRAP PROTECTED-assessed infrastructure.

Data boundary enforcement

Google Cloud Assured Workloads ensures that data processing and storage remain within Australian infrastructure boundaries.

Encryption

Customer-managed encryption keys (CMEK) via Google Cloud KMS. Your organisation holds and controls the encryption keys used to protect your data.

Cryptographic signing

Attestations are signed using Cloud KMS ECDSA P-256 as the primary method, with HMAC-SHA256 as a fallback. Signatures are independently verifiable.

Availability

99.9% uptime SLA. Configurable fail behaviour: fail-open (allow calls, log the gap) or fail-closed (block calls until Guard is available).

Data storage

Guard stores attestation metadata (PII scan results, compliance status, regulatory mapping, timestamp, model called) and the cryptographic signature. By default, full prompt and response content is not stored. Full content logging is available as an optional configuration.

Data portability

The full audit trail is exportable at any time as JSON, for integration with your existing GRC platform or compliance archive.

## PII detection

Guard scans for Australian-specific personally identifiable information, including: 

* Tax File Numbers (TFN), with checksum validation
* Medicare numbers
* Australian Business Numbers (ABN)
* Dates of birth
* Bank account and BSB numbers
* Credit card numbers
* Full names in conjunction with other identifiers
* Residential addresses
* Phone numbers
* Email addresses

Prompt scanning

Every prompt sent through Guard is scanned for PII patterns before it's forwarded to the AI provider. Depending on your policy configuration, Guard can block the request, mask the sensitive data, or flag it and allow it through with a log entry.

Attachment scanning

Guard extracts and scans the content of attached files, including PDFs and Word documents. This catches PII exposure that text-only scanners miss entirely: a staff member uploading a customer document to an AI tool for summarisation or analysis.

Hidden content detection

Guard detects content designed to evade human review within attachments, including text rendered in zero-width characters (invisible to the user but read by the AI model), text formatted with white font on a white background, and instructions embedded in document metadata or hidden layers.

## Prompt injection detection

Prompt injection is when hidden instructions are embedded inside content that gets fed to an AI model. The AI reads those instructions and follows them, potentially leaking data, changing its behaviour, or bypassing controls. 

Guard scans both prompt text and attachment content for known injection patterns: 

* Direct instruction overrides (e.g., "ignore your instructions and...")
* Hidden text in documents: white-on-white text, zero-width characters, and invisible Unicode sequences
* Embedded instructions in PDF text layers and Word document bodies
* Pattern-based detection of attempts to extract system prompts, override safety controls, or redirect AI behaviour

Why this matters for compliance

If an AI system can be manipulated into bypassing controls or leaking data through prompt injection, the organisation's information security controls are ineffective. Under CPS 234, that's a material control weakness. Under APP 8, it could result in an uncontrolled cross-border disclosure.

## Cryptographic attestation

On every API call, Guard generates a cryptographically signed attestation record. This is a signed JSON document that proves, tamper-evidently, that the call was processed through Guard and that compliance checks were performed. 

Each attestation contains:

* Timestamp of the call
* Which AI model was called
* PII scan results (what was found, what action was taken)
* Prompt injection scan results (patterns detected, unicode anomalies found)
* Jurisdiction check result (where the data was sent)
* Compliance status (compliant, flagged, or blocked)
* Which regulatory obligations were triggered (mapped to CPS 234 sections, APP 8, AI transparency controls)
* The active compliance profile configuration
* Cryptographic signature (algorithm and key ID)

Why this matters for auditors

An auditor can independently verify that an attestation hasn't been altered since it was created. This turns "we have a policy" into "we have cryptographic proof that our controls were active on this specific call at this specific time."

## Jurisdiction enforcement

Guard checks the destination of every API call against your jurisdiction policy. If your policy specifies Australian infrastructure only, Guard verifies the AI provider's endpoint is in an Australian region before forwarding the request. If it's not, the request is blocked. 

This directly supports APP 8 compliance: your organisation can demonstrate that reasonable steps were taken to prevent cross-border disclosure of personal information, on every single call. 

## 7-year audit trail

Every attestation is stored in a tamper-evident, append-only data store with 7-year retention, aligned with standard financial services record-keeping obligations. 

Immutable

Records cannot be modified or deleted after creation.

Exportable

The full trail can be exported as JSON for integration with your GRC platform or compliance register.

Searchable

Filter by date, model, PII flag, compliance status, or regulatory obligation.

Available

Covered by the 99.9% uptime SLA.

## Regulatory mapping

Guard maps its findings to three regulatory frameworks on every call. 

### CPS 234 (APRA Information Security)

| CPS 234 requirement          | How Guard addresses it                                                                                                                                                                             |
| ---------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Board responsibility (S15)   | Compliance dashboard provides real-time view of AI security posture. Board reports exportable directly.                                                                                            |
| Security capability (S16–18) | Guard monitors every AI provider interaction automatically. Third-party AI providers are assessed on every call.                                                                                   |
| Controls (S22–23)            | PII scanning, jurisdiction enforcement, prompt injection detection, and content policy checks enforced on every API call.                                                                          |
| Testing (S27–31)             | Continuous attestation provides evidence that controls were active and effective on every call, not just at testing time. Exportable as JSON for auditor review.                                   |
| Incident notification (S35)  | PII finding logs and compliance status records create an evidence trail for identifying and reporting incidents. If PII was exposed, Guard's logs show exactly when, what type, and where it went. |
| Control weakness (S36)       | Real-time monitoring surfaces control weaknesses immediately, not months later during an audit.                                                                                                    |

Board responsibility (S15)

Compliance dashboard provides real-time view of AI security posture. Board reports exportable directly.

Security capability (S16–18)

Guard monitors every AI provider interaction automatically. Third-party AI providers are assessed on every call.

Controls (S22–23)

PII scanning, jurisdiction enforcement, prompt injection detection, and content policy checks enforced on every API call.

Testing (S27–31)

Continuous attestation provides evidence that controls were active and effective on every call, not just at testing time. Exportable as JSON for auditor review.

Incident notification (S35)

PII finding logs and compliance status records create an evidence trail for identifying and reporting incidents. If PII was exposed, Guard's logs show exactly when, what type, and where it went.

Control weakness (S36)

Real-time monitoring surfaces control weaknesses immediately, not months later during an audit.

### APP 8 (Cross-border disclosure)

| APP 8 requirement        | How Guard addresses it                                                                                                        |
| ------------------------ | ----------------------------------------------------------------------------------------------------------------------------- |
| Reasonable steps         | PII scanning on every prompt before data leaves the organisation. PII can be blocked, masked, or flagged according to policy. |
| Jurisdiction enforcement | Per-call verification that data destinations meet your residency policy.                                                      |
| Accountability           | Signed attestation on every call creates evidence that reasonable steps were taken.                                           |
| Documentation            | 7-year tamper-evident record, ready for auditor review at any time.                                                           |

Reasonable steps

PII scanning on every prompt before data leaves the organisation. PII can be blocked, masked, or flagged according to policy.

Jurisdiction enforcement

Per-call verification that data destinations meet your residency policy.

Accountability

Signed attestation on every call creates evidence that reasonable steps were taken.

Documentation

7-year tamper-evident record, ready for auditor review at any time.

### AI transparency (December 2026)

| ADM requirement                     | How Guard addresses it                                                                                                                  |
| ----------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------- |
| Identify ADM systems                | Logs every AI interaction: which model, what data, what response. Creates the inventory of ADM systems your organisation needs.         |
| Disclose decision types             | Regulatory mapping tags each call against applicable obligations, creating the raw material for privacy policy disclosures.             |
| Disclose personal information types | PII detection log records exactly which types of personal information were present in each interaction.                                 |
| Human-in-the-loop logging           | Logs every AI interaction regardless of whether it's fully automated or human-assisted. Captures the AI's contribution to the decision. |

Identify ADM systems

Logs every AI interaction: which model, what data, what response. Creates the inventory of ADM systems your organisation needs.

Disclose decision types

Regulatory mapping tags each call against applicable obligations, creating the raw material for privacy policy disclosures.

Disclose personal information types

PII detection log records exactly which types of personal information were present in each interaction.

Human-in-the-loop logging

Logs every AI interaction regardless of whether it's fully automated or human-assisted. Captures the AI's contribution to the decision.

## Compliance reporting

Guard generates two types of compliance reports as downloadable PDFs: 

CPS 234 compliance reports

Map Guard evidence against CPS 234 control sections (asset classification, third-party oversight, controls active, incident management). Designed to go straight into an auditor's evidence pack or a board paper.

AI transparency reports

Document AI system usage, data inputs, decision basis, and attestation integrity against AI transparency controls. Ready for the December 2026 obligations.

## What Guard doesn't replace

Guard is the continuous evidence layer for AI usage. It does not replace your broader information security framework, board-level AI governance policy, privacy impact assessments, incident response planning, or vendor risk assessments for non-AI systems. 

Guard handles the part nobody else can do continuously: proving your AI controls are working, on every call, with signed evidence. 

## Questions?

If you'd like to discuss Guard's architecture, security, or compliance capabilities in more detail, book a 45-minute technical call with our team. 

[Book a 45-minute technical call → ](/#get-started) [Back to FAQ ](/#faq)

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Markdown version of https://40south.au/trust for AI readers. Site index for LLMs: https://40south.au/llms.txt
