ETERSHIELD | THE COMPLETE GUIDE | ETER GROWTH
v1.9 · 9 October 2026 | PUBLIC
Eter Growth — Product Document

EterShield — The Complete Guide

Organisational Security Knowledge Platform for European Businesses
Version
1.9 — 9 October 2026
Author
Eter Growth
Target Audience
European SMEs
Contact
geral@etergrowth.com
"Compliance is not a destination. It is the by-product of an organisation that knows exactly what it has, what is at risk, and what it has decided to do." — Eter Growth
Table of Contents
PART I Context and Vision
01 The Regulatory Landscape in 2026
The Regulatory Storm That Reached SMEs

For years, cybersecurity and privacy regulation was seen as a problem for large organisations. GDPR, in 2018, was the first sign that this was changing: all organisations that process personal data of European citizens were covered, regardless of size. But it was between 2022 and 2025 that regulatory pressure became truly democratised.

NIS2 extended cybersecurity obligations to many more sectors. DORA imposed stringent requirements on the financial sector, including IT suppliers. The EU AI Act introduced obligations for organisations using high-risk AI systems. CSRD made sustainability reporting mandatory for a growing number of companies. In Portugal, Decree-Law 125/2025 transposed NIS2 with CNCS as the national authority — and it is the resulting Cybersecurity Legal Regime (RJC), not the directive, that Portuguese organisations must demonstrate. It is joined by the General Regime for the Prevention of Corruption (RGPC, DL 109-E/2021), which requires a compliance programme from every entity with 50 or more employees, and by the Data Act (Regulation (EU) 2023/2854), applicable since 12 September 2025 to manufacturers of connected products and providers of cloud and data-processing services.

The Cost of Non-Compliance
RegulationMaximum FineApplication Condition
GDPR€20M or 4% global turnoverPersonal data breach, lack of legal basis
NIS2€10M or 2% global turnoverInadequate measures, notification failure
DORAPer national authorityInsufficient operational resilience
EU AI Act€35M or 7% global turnoverHigh-risk AI systems without compliance
Data ActPer national authority (effective, proportionate, dissuasive)Refusal of data access, unfair contract terms, obstacles to switching provider
RGPC (PT)€2,000 to €44,891.81 per infringementNo risk prevention plan, code of conduct or whistleblowing channel
The Problem of Institutional Memory

Many organisations respond to regulatory pressure in the most obvious way: they hire a consultant, conduct an assessment, produce documentation, and pass an audit. A year later, the consultant is gone, the person who coordinated the process has moved to another company, and the organisation starts from scratch.

This is the problem EterShield was designed to solve. It is not a problem of lacking tools — it is a problem of knowledge that disappears. Every decision taken, every risk assessed, every policy approved should be a growing asset of the organisation.

The Market Gap

The market has responded with solutions at the extremes: Enterprise GRC (OneTrust, IBM OpenPages) with prices of €50,000–€500,000 annually and implementations taking months; or isolated tools (Eramba, spreadsheets) with no integration or AI. The gap is clear: no affordable solution preserves organisational knowledge, integrates multiple European frameworks in Portuguese, and uses contextual AI — all in a single product for SMEs.

02 What Is a vCISO Platform and Why It Matters
Definition

A vCISO (Virtual Chief Information Security Officer) externalises the function of strategic security leadership. A vCISO platform is the technological evolution: software that structures, automates, and systematises the functions of a CISO in an interface that any IT or compliance manager can operate — without being a security specialist.

EterShield is a vCISO platform, but goes further: it is an organisational security knowledge management system that collects and structures everything the organisation knows about its own security, uses AI to transform that knowledge into actionable assessments and policies, and accumulates value over time.

Core Functions
KNOWLEDGE COMPLIANCE RISK OPERATIONS ─────────── ──────────── ───── ────────── Entity profile Assessments Risk register Incidents Knowledge Base Gap analysis Monte Carlo/FAIR Audits AI Policies Evidences Treatment CAPA History Cross-framework Vendors Calendar
Implementation Models
ModelDescriptionSuitable for
Self-managedOrganisation uses the platform directlySME with a dedicated IT manager
AssistedEter Growth operates the platform with the organisationSME without internal technical capacity
Full vCISOEter Growth assumes the vCISO roleOrganisations with no security resources whatsoever
MSP / partnerConsultancy uses EterShield for multiple clientsMSSPs, compliance consultancies
03 EterShield — Vision, Mission and Value Proposition
Value Proposition
For the CEO / Board
NIS2, GDPR, and ISO 27001 compliance documented and demonstrable, without hiring a CISO. Always know what is at risk and how much it costs in euros.
For the IT / Compliance Manager
Replaces spreadsheets and emails to consultants. AI generates assessments, analyses vendors, and quantifies risks — in minutes, not weeks.
For the External Auditor
Documented, traceable, and exportable evidence. Immutable Audit Trail. Cross-framework mapping an ISO 27001 control to the corresponding NIS2 requirement.
For the vCISO Consultancy
Multi-client dashboard to manage 10 organisations with the effort of one — automatic PDF reports, per-client audit portals, AI that accelerates analysis.
Five Design Principles
  • Knowledge that stays — unlike an external consultant, when the person who led the certification leaves the company, the knowledge remains in the platform with all its justification.
  • AI that reads the real context — before suggesting a policy or analysing a gap, the AI reads the organisation's Knowledge Base. A logistics company receives different suggestions from a health clinic.
  • European regulatory by design — NIS2, DORA, GDPR, EU AI Act were designed for the European context. EterShield was built from the start in Portuguese, with data in the EU, with ANACOM and CNCS as references.
  • Single scope for a complete IMS — ISO 27001, ISO 9001, ISO 45001, GDPR, CSRD integrated in a single platform, eliminating silos and data duplication.
  • Progressive modularity — pay for what you use — not every organisation needs everything at once. The base plan includes the GRC core (compliance frameworks, risk, TPRM, audits); the operational modules (ISO 9001, OH&S, HR Security, ESG/CSRD, BCM, Fleet, Facilities, NetworkAlerts) and additional frameworks are activated individually, as the organisation grows or when a specific regulatory requirement arises. There is no need to upgrade the plan to access a single additional module.
PART II Features
04 GRC and Compliance — The Platform Core
Chapters 4 to 10 describe all features available on the platform. Access depends on the contracted composition: the base platform (€149/month, SSO included) provides the GRC core; frameworks and operational modules are added à la carte — modules individually (€19–€39/month) or in the Operations Bundle (€149/month).
Supported Frameworks 40 Frameworks · 1771 Controls
FrameworkScopeControls
RJC (DL 125/2025)Portuguese Cybersecurity Legal Regime — NIS2 transposition (Portugal — CNCS)126
ISO/IEC 27001:2022Information Security (complete Annex A + clauses)120
QNRCSNational Cybersecurity Reference Framework (Portugal — CNCS)107
NIST CSF 2.0Cybersecurity (US framework)106
IFS Food v8Food Safety (European retail)96
FSSC 22000 v7Food Safety (GFSI)74
CIS Controls v8 (IG1)Essential Security Controls72
HIPAA Security RuleHealth Data65
HACCP (Codex CXC 1-1969)Food Safety60
ISO/IEC 42001:2023AI Management57
TISAX (VDA ISA 6.0)Information Security — automotive sector55
ITSM — Modern PracticesIT Service Management (maturity)54
FSSC 22000 v6Food Safety (previous version, transition)49
ISO 26000:2010Social Responsibility40
NP 4469:2019Social Responsibility (Portugal — IPQ)39
SOC 2 (AICPA)Security and Availability38
MITRE ATT&CKAttack Tactics and Techniques38
EU AI Act (2024/1689)High-Risk AI Systems38
ISO/IEC 20000-1:2018IT Service Management37
GDPR (2016/679)Data Protection36
Data Act (2023/2854)Connected-product data and cloud services35
ISO 22301:2019Business Continuity31
RGPC (DL 109-E/2021)Corruption Prevention (Portugal — MENAC)31
ISO 9001:2015Quality30
PCI DSS v4.0Payments29
Cyber Resilience Act (2024/2847)Products with Digital Elements29
ISO 31000:2018Risk Management28
ISO 56001:2024Innovation Management28
DORA (2022/2554)Digital Resilience — financial sector24
ISO 55001:2024Asset Management24
NIS2 (2022/2555)Cybersecurity (directive — use RJC in Portugal)23
AMLD6 / Lei 83/2017Anti-Money Laundering23
FEDIAFPet food — nutrition and labelling22
ISO/IEC 23894:2023AI Risk Management22
IT n.º 01/2026 (CNCS)Coordinated Vulnerability Disclosure21
MITRE CTID FraudFraud and Abuse16
ISO 45001:2018Occupational Health and Safety13
MyCiber (CNCS)Cybersecurity Registration and Qualification (Portugal)13
ISO 14001Environmental Management12
OWASP Top 10Application Security10
40 frameworks in the catalogue, 1771 controls in total (database count, September 2026). Mutually exclusive frameworks — such as NIS2 and RJC — are never active at the same time for the same client. Each framework can be contracted for the whole group or only for some entities, and is added to the base platform à la carte, at €13, €20 or €27/month depending on its tier (open frameworks included). New add-on frameworks, July 2026: NIST CSF 2.0, CIS Controls v8 (IG1) and HIPAA Security Rule, with 89 crosswalks already established between them and ISO 27001. New framework, July 2026: Cyber Resilience Act (Regulation (EU) 2024/2847), 29 controls, with 18 crosswalks to ISO 27001 and 22 to NIS2. New in August/September 2026: RJC (DL 125/2025, 126 controls — the framework that replaces NIS2 for Portuguese organisations), CNCS Technical Instruction 01/2026 and MyCiber, RGPC (31 controls, €29/month) and Data Act (35 controls, €39/month), plus the food-safety frameworks (IFS Food, FSSC 22000, HACCP, FEDIAF) and TISAX.
AI Gap Analysis and Automatic Score

Instead of going through 93 ISO 27001 controls manually, the user activates the AI Gap Analysis. Based on the organisation's profile and accumulated Knowledge Base, the AI automatically identifies the most likely gaps, suggests remediation priority, and proposes response texts for each control. The compliance score (0–100%) updates in real time by category and by framework.

Control exceptions with expiry: when a gap cannot be closed immediately, the organisation can record a control exception — a temporary risk acceptance with justification and an expiry date. When an approved exception expires without renewal, the platform automatically reopens the underlying gap and notifies the requester, so a stale risk acceptance never becomes permanent by omission. The expiry sweep runs daily inside the platform's in-process scheduler.

Cross-Framework — Work Without Duplication

An ISO 27001 control can simultaneously satisfy NIS2 and DORA requirements. An organisation working ISO 27001 in parallel with NIS2 and DORA can have 60–70% of DORA controls already answered by the work done on ISO 27001. No duplicate questions, no redundant effort.

AI-Generated Policies

The policy repository generates contextualised drafts — not generic templates. Based on the organisation's profile, sector of activity, and active frameworks, the AI creates a policy that references the specific reality of the company. Full versioning with revision history, approvals, and next scheduled review.

Frameworks per Entity — Groups with Several Companies

A group with several companies does not always need the same framework in all of them: RJC may apply to three companies and TISAX to just one. Each framework can be contracted for the whole group or per entity. A framework contracted per entity only appears in the companies that contracted it — in assessments, in maturity-index coverage, in dashboard alerts and in the context used by the AI — and its price is agreed entity by entity.

RGPC — Anti-Corruption Compliance Programme

The RGPC framework (Portuguese DL 109-E/2021) was built from the text of the law: 31 controls, one per independently sanctioned duty, with priority derived from the fine bracket. It comes with the code of conduct as a dedicated policy type and 16 corruption risks in the risk library, anchored in the offences listed in Art. 3. Management of the Risk Prevention Plan, the Compliance Officer and conflict-of-interest declarations is under development.

The Portuguese Framework — RJC and MyCiber

In Portugal, the obligation does not arise directly from NIS2. It arises from the Cybersecurity Legal Regime (RJC) — Decree-Law 125/2025 of 4 December, which transposes Directive (EU) 2022/2555 into Portuguese law. This is the instrument the competent authority enforces, and the one against which an organisation is assessed. Anyone who has already worked through NIS2 has part of the road behind them, not all of it: the RJC adds obligations of its own, deadlines of its own, and a registration cycle the directive never describes.

EterShield treats the RJC as a first-class framework, not as an alias for NIS2. It carries 126 control objectives derived from the statute — governance duties (art. 25), cybersecurity risk management (arts. 26 to 29) and the minimum measures of art. 27 read together with Annex III of Regulation 756/2026 — applicable to the essential and important entities in the critical and highly critical sectors listed in Annexes I and II to the decree-law.

MyCiber — the registration and qualification cycle. Meeting the technical measures is not enough: the entity must exist in the regulator's eyes. MyCiber is the electronic platform of the Portuguese National Cybersecurity Centre (CNCS) where that cycle takes place, and EterShield tracks it with 13 control objectives under Chapter II (arts. 6 to 19) of Regulation 756/2026 and arts. 8 and 35 of the RJC: initial self-identification, follow-up of the qualification, definitive registration, permanent updating of the data, and notification of the security officer.

This is the part of the RJC most often overlooked — and the easiest to fail through simple forgetfulness, because the duty to keep the data current is permanent and has no audit milestone to prompt it. Recorded as a control, it acquires an owner and a deadline like any other.
FrameworkLegal basisControl objectives
RJCDecree-Law 125/2025 of 4 December (transposes Directive (EU) 2022/2555)126
MyCiberRegulation 756/2026, Ch. II (arts. 6–19); RJC arts. 8 and 3513
NIS2Directive (EU) 2022/255523
QNRCSNational Cybersecurity Reference Framework (CNCS)107

The frameworks cover the same ground in layers: cross-mapping means a piece of evidence uploaded once answers the RJC control and the QNRCS control at the same time. In Portugal the working framework is the RJC; NIS2 remains as the European reference and, because the two are mutually exclusive, is not active at the same time as the RJC for the same client. The work is done once; the demonstration is made several times.

Coordinated Vulnerability Disclosure (IT 01/2026)

Technical Instruction 01/2026 of the Portuguese National Cybersecurity Centre, approved on 24 June 2026 under art. 20(1)(h) and art. 38 of the RJC, sets the requirements for identifying vulnerabilities and disclosing them in a coordinated manner. It defines what is expected of each of the three parties: whoever identifies the vulnerability, the manufacturer or supplier of the vulnerable technology, and the CNCS as coordinator.

EterShield has a dedicated framework with 21 control objectives covering the full cycle: publication of the disclosure policy and point of contact, intake and triage of reports, response and remediation deadlines, communication with the reporter, and an auditable record of every step — which is, in practice, what you present if compliance is ever questioned.

Why a separate framework rather than a chapter of NIS2: IT 01/2026 imposes obligations on entities that are not necessarily essential or important entities — manufacturers and technology suppliers in particular. Treating it as a sub-section of the RJC would leave out precisely those it most affects. Its controls are cross-mapped to the RJC and to ISO/IEC 27001 for organisations subject to both, so evidence is not duplicated.
05 Risk Management with Financial Quantification
Monte Carlo / FAIR — Risk in Euros

Most risk tools stop at coloured matrices. EterShield quantifies risks financially using the FAIR model (Factor Analysis of Information Risk) with Monte Carlo simulation: 10,000 simulations produce an annual expected loss (ALE) distribution with P10, P50, and P90 percentiles in euros.

Risk (example)Median ALE (P50)ALE P90
Ransomware on a Windows endpoint€78,000€310,000
Unauthorised access to customer database€45,000€180,000
Critical cloud vendor failure€25,000€95,000
AI Parameter Estimation

FAIR quantification requires parameters that few IT managers know how to estimate. The AI proposes frequency and magnitude parameters with justification based on benchmarks from DBIR (Verizon), ENISA, and CNCS, presenting a TransparencyBadge with the complete reasoning and sources used.

Control ROI

For each implemented security control, EterShield automatically calculates the risk reduction in euros — allowing investments to be prioritised by financial return, not intuition. Each risk enters a formal treatment plan with milestones, owners, approval, and linkage to the compliance calendar.

Complete Risk Chain
Asset → Threat (MONARC/ISO 27005 catalogue) → Vulnerability → Risk → Treatment → Plan Integrated MONARC catalogue: ├── 50 threats in 9 categories (physical, technical, social engineering, malware…) └── 41 vulnerabilities in 6 categories (hardware, software, network, human…)
KRIs — Key Risk Indicators

A dedicated KRIs (Key Risk Indicators) page complements the risk register: each indicator carries a warning threshold, a critical threshold, a configurable direction (higher-is-worse or lower-is-worse), and either a manual or an automatic source. The automatic source L3_CONTROL_TESTS feeds directly off continuous control monitoring: the indicator is the failure rate of automated control tests (FAIL=1, PARTIAL=0.5), recalculated at the end of every hourly monitoring cycle. State transitions — into warning, into critical, or back to normal — trigger deduplicated notifications, with no noise while an indicator sits steady.

Version History of Risks

Every change to a risk automatically stores a complete snapshot of the previous version — likelihood, impact, treatment, owner, FAIR parameters. The record can be browsed version by version and restored to any point; restoring creates a new version and never deletes history. It answers a common auditor question: "how was this risk assessed in March?"

Loss Events

A loss events register grounds risk management in actual financial outcomes rather than opinion: events categorised as cyber, operational, fraud, legal/compliance, or reputational, with direct, indirect, and recovered loss values, root cause, and lessons learned. Optional links to an existing risk, incident, or CAPA avoid duplicate data entry; a running summary of total and per-category net loss gives management a factual baseline to calibrate FAIR parameters.

06 Third-Party Management (TPRM)
Adaptive Questionnaire

EterShield uses an adaptive TPRM questionnaire with 33 questions distributed across 5 modules, activated automatically based on the vendor's profile. An office supplies vendor answers 8 questions. A personal data processor with direct CRM access answers all 33.

ModuleActivated whenQuestions
Information SecurityAlways8
Data ProtectionVendor processes personal data7
Business ContinuityVendor critical to operations6
Technical SecurityVendor with access to systems7
ComplianceVendor in a regulated sector5
Public Portal with Unique Token

The vendor does not need to create an account. They receive an email with a unique token link, access a secure public page, respond, and submit. The token expires after submission or deadline. All interaction is tracked and audited.

AI Analysis and Decision Workflow

After submission, the AI analyses each response: score 0–100, red flags identified with reasoning, and overall recommendation (Approve / Conditional / Reject / Defer). The responsible party records the formal decision with a justification note — direct evidence for ISO 27001 and NIS2 auditors.

07 Personnel Security (HR Security)
People — A Single Directory

Employees with or without an account, users and invitees live in a single directory, with one record per person (department, job title, certifications, training). Invitations have their own lifecycle and an entity scope — someone invited to a company joins that company. With SAML or OIDC single sign-on, automatic provisioning on first login creates the account for employees of the organisation's domain, with the role chosen by the administrator.

JML Lifecycle — Joiners, Movers, Leavers

The access lifecycle tracks Joiners (new employees with a provisioning checklist), Movers (role changes with access review), and Leavers (departures with a revocation checklist). Each event generates an assigned task with a deadline and completion confirmation. JML and access reviews have real effect: a completed departure or an approved revocation deactivates the account on the platform, and a reduction lowers the role — with the change recorded as evidence.

Access Reviews, Background Checks and Disciplinary

Automated periodic access reviews: a cron job schedules the review, the responsible party receives the access list, approves or revokes each entry, all recorded with a timestamp. Background checks with status and validity. Disciplinary process with PII fields encrypted in AES-256-GCM (GDPR Art. 9).

Data Subject Requests (DSR)

GDPR Art. 15–20 requests with entry date registration, 30-day legal countdown, status tracking (Received → Under review → Responded), and complete history for compliance demonstration.

08 Quality (ISO 9001)
Six ISO 9001 Modules
ModuleDescription
Document ControlQMS with version, revision date, approval owner, and automatic alert
Customer ComplaintsFull cycle: reception, root cause analysis, action plan, effectiveness verification
Equipment CalibrationRecords with calibration dates and automatic alert before recalibration deadline
Supplier AuditsISO 9001 checklists by category, non-conformance records
SPC Control ChartsX-bar, R and p charts for statistical process monitoring
CAPA 8DStructured resolution following 8 Disciplines (D1–D8) with evidence chain
ISO 9001 + ISO 27001 integrated: audits, CAPA, evidence, and documentary records share the same infrastructure on the platform — no separate tools, no data duplication.
09 Health, Safety, Fleet and Facilities
OH&S / ISO 45001

Accident records with root cause analysis and automatic ACT report; hazard register with risk assessment and controls; PPE management per employee; documented worker consultation (clause 5.4 ISO 45001 requirement). Dedicated per-role permissions: users who can only view cannot create or delete hazards, PPE records or consultations.

Facilities Management

Critical physical systems (HVAC, CCTV, alarms, sprinklers, UPS) registered as assets with preventive maintenance plans, inspection history, and imminent maintenance alerts. Direct linkage to ISO 27001 physical and environmental security controls.

Fleet Management

Vehicle and driver records, fuel tracking, maintenance history, and document expiry calendar (inspection, insurance, service). Fuel data feeds directly into the GHG Scope 1 emissions module.

10 Sustainability and ESG (CSRD)
Three ESRS Pillars
PillarStandardContent
GHG EmissionsESRS E1Scope 1/2/3 with IPCC factors; sync from fleet records; tCO₂e dashboard
Social IndicatorsESRS S1Workforce, gender, accidents, training, absenteeism, pay gap
GovernanceESRS G1Anti-corruption policy, whistleblower (AES-256), vendor assessment, fines

The CSRD report editorial cycle follows a Draft → Under Review → Approved → Published flow. The report is generated from records already existing on the platform — no manual re-entry of data.

11 Artificial Intelligence — Transparent Trust and AI Security
The Transparency Package

All AI in EterShield is auditable. Every generated result includes a TransparencyBadge visible to the user — relevant for organisations subject to the EU AI Act.

FieldContent
ModelLanguage model (version and provider identified)
Tokens consumedInput + Output
Estimated costIn euros (cost control)
LatencyResponse time in ms
OperationE.g.: "Gap Analysis ISO 27001 Annex A.8"
ReasoningExposed model reasoning
SourcesBenchmarks or frameworks referenced
AI Components
ComponentUsage
Internal AI GatewaySecurity and authentication layer that intermediates all requests to the language API — ensures isolation and cost control
State-of-the-art language modelGap Analysis, TPRM, Monte Carlo, EtherFlow, Cook, Sparks, response suggestions, profile prefill
Proprietary semantic search engineKnowledge Base — context retrieval by entity optimised for European Portuguese
GRC knowledge graphVera's structured context injected into prompts — at no additional cost per call
Knowledge Base — The AI That Knows the Organisation

EterShield's deepest differentiator: a per-entity Knowledge Base system with contextual semantic search in four phases.

Phase A
Entity Profile

6-step wizard (identification, business, systems, regulation, team, maturity). Completeness score 0–100%. AI suggests frameworks and identifies the competent NIS2 authority (ANACOM, BdP, CNCS) based on the sector.

Phase B
CISO Validation Queue

Any free text (meeting minutes, email, report) is processed by the AI, which extracts structured knowledge in 7 categories. The CISO approves, edits, or rejects each item before it enters the database.

Phase C
Active Semantic Search

Approved items are indexed and made available for semantic search optimised for European Portuguese. At each AI call, the most relevant Knowledge Base items are retrieved and injected into the prompt. The AI responds with the organisation's real context.

Phase D
Document Upload

PDFs, DOCX, and TXT files up to 20MB are processed, fragmented into chunks, and integrated into the Knowledge Base. Existing policies, audit reports, contracts — all enrich the AI context.

EtherFlow — Meetings That Feed the System

The meeting ingestion pipeline: the transcript is sent via API or uploaded manually; the AI extracts risks, gaps, tasks, and decisions; items appear in an approval inbox; approved items go directly into the corresponding modules and the Knowledge Base. A 2-hour meeting produces 15 structured entries in 10 minutes.

AI Security — Agentic Risk Assessment ARIA

With the proliferation of AI systems in business processes, AI risk management has become a formal requirement (EU AI Act, ISO 42001). EterShield includes a set of specialised modules for organisations that develop or use AI systems.

The ARIA Framework (Agentic Risk Intelligence Assessment) is a proprietary agentic AI risk assessment methodology structured in 7 phases, aligned with NIST AI RMF, MITRE ATLAS, MAESTRO, OWASP AIUC-1, and AIVSS. It covers 15 risk vectors: A1–A8 (agentic system risks: objective manipulation, planning hallucination, privilege escalation, context exfiltration, reasoning loop, tool abuse, irreversible impact, malicious coordination) and D Series D1–D7 (development phase threats, OWASP AI Exchange: data poisoning, backdoors, model attacks, inversion, extraction, adversarial evasion, dependency injection).

ModuleDescription
ARIA AssessmentComplete 7-phase assessment — score per phase, A1–A8 risks + D Series, assessment history, and mitigation plan
AI IncidentsAI behavioural incidents — 7 types (hallucination, bias, prompt injection, data leak, jailbreak, misuse, unexpected behaviour); EU AI Act Art. 72 flag
Model CardsEU AI Act Art. 13 technical fact sheet — intended use, training data, limitations, bias, ethics, human oversight; formal approval with record
Red Team SchedulerRed teaming campaigns on AI systems — pre-defined OWASP AIUC-1 tests by category (prompt injection, jailbreak, data exfiltration)
EU AI Act AssessmentCompliance assessment with 33 EU AI Act obligations per AI system; risk classification (UNACCEPTABLE / HIGH / LIMITED / MINIMAL); automatic seed of applicable obligations
AI Assisted in Forms

AI suggestions live inside the form the person is already working in, on one principle: AI proposes, the human decides. The "Suggest with AI" button is available in more than 60 create and edit forms — risks, policies, incidents, assessment answers, statement of applicability, tasks, suppliers, gaps, assets, GDPR records (DPIA, RoPA, breaches, data-subject requests, TIA), quality, business continuity, OH&S, contracts, minutes, objectives, KRIs, loss events, SWOT and ESG.

  • Field-by-field review — the person sees what would change and accepts or rejects each field; they can fill only the empty ones, rewrite, or ask for a single field, and choose tone, length and language. Nothing is saved until the form is submitted.
  • Only what the person could already do — anyone without permission to save the record cannot ask for suggestions; the AI respects each user's entity scope, and personal data (names, emails, tax IDs) is never sent to the model.
  • Reasoning on record — each suggestion is stored with its transparency package (confidence, sources, limits) and its outcome — accepted, edited or rejected — for audit. Suggestions are kept for 12 months.
  • Own quota — form suggestions have a monthly quota separate from other AI calls, set by the plan.
  • History and restore — every editable record gets a timeline showing the origin of each change (person, AI, integration, import), comparison between versions and restore. Risks gain a risk matrix over time, and editing an approved policy sends it back for approval.
  • Explain, Challenge, Ask Vera — on calculated values and suggestions, the person can ask for an explanation, ask Vera, or challenge; a challenge goes to a review queue and never changes the value by itself.
AI Agent Governance Phase 1

AI agents — systems that act with autonomy, use tools and access data — get a register and a governance record on the AI Agents page ("AI Security" group).

  • One record per agent — owner, purpose, model and provider, data and privacy, tools (with impact and human approval), autonomy level (suggests only, acts with approval, acts alone), human oversight, and links to the model card, the AI Act, AI incidents and ARIA assessments.
  • Credentials as metadata only — type, scope, who manages them and rotation. The value of a key or password is never stored, and the form rejects text that looks like a secret.
  • What is missing and why — a completeness percentage and a list of missing fields, each with the reason and the framework that requires it (ISO/IEC 42001, AI Act, GDPR, OWASP for agents), plus alerts — suggested DPIA, high-impact tools without approval, transparency duty (AI Act Art. 50).
  • Actions — generate one task per group of missing fields, assigned to the owner; prepare the agent's ARIA assessment with the context already filled in; periodic review on the calendar (6 months for high risk, 12 for the rest). A DPIA is only suggested, never created automatically.
  • Registering with Vera, with human confirmation — Vera can lead the registration by conversation, but only creates drafts; a person always confirms, edits or rejects on the card. Drafts expire after 7 days.
  • Dedicated AI permissions — administrators have full access, managers read, create and update; auditors and viewers can only view.

This is the first phase: the register is declarative, filled in and confirmed by people. It does not include automatic discovery of agents or runtime monitoring.

12 Governance, Audits and Operations
Incident Management with NIS2/GDPR Countdowns
ObligationDeadlineTrigger
CNCS notification (NIS2)24 hoursIncident with significant impact
DPA notification (GDPR)72 hoursPersonal data breach
BdP/ANACOM notification (DORA)4 hoursMajor ICT incident

ANACOM routing automatically identifies the competent authority based on the sector and Decree-Law 125/2025 — eliminating manual research during a crisis.

Internal Audits, CAPA, and Evidence Management

Formal internal audit planning with audit team, agenda, findings, and non-conformance classification (Major / Minor / Observation). CAPAs with structured root cause, owner, deadline, status, and effectiveness verification. Evidence with automatic OCR — text extracted from any PDF or image, searchable and linked to the control it supports.

Evidence Automation — Freshness, Coverage and Google Drive Livesync

Automated evidence (e.g. a connector-collected screenshot or an OCR-extracted document) carries a freshness / TTL flag: once validity expires, the evidence is marked stale and the control it supports drops out of the "fresh" bucket until re-collected. A continuous coverage view shows, per framework, the split between fresh, stale, and manual evidence — giving the CISO a single screen to answer "what still needs a human this week." Google Drive Livesync links a Drive folder directly to a control: files added to that folder are picked up automatically and attached as evidence, with no manual upload step. Evidence by link records an external URL (Drive, intranet, ERP) without downloading and re-uploading the file. Verifiable integrity: the SHA-256 hash of every evidence file is stored at upload and checked periodically, and the audit log is hash-chained — any later change or removal becomes detectable. Recurring obligations in the compliance calendar generate their next occurrence on their own, on the last day of the month when the original day does not exist.

Auditor Portal

Dedicated portal for external auditors with controlled access to assessments, evidence, and reports — without access to platform configuration or data from other modules. Revocable access, with all queries recorded in the audit trail.

Automated Regulatory Watch

A weekly job polls RSS feeds from EU regulatory sources — the European Data Protection Board (EDPB) and the European Commission's Digital Strategy publications — and runs each new item through AI classification: which framework it affects, likely impact, and any inferable compliance deadline. Classified items land in a human review queue, where a CISO or compliance officer publishes or rejects each one before it reaches end users. Published items are pushed straight into the tenant's regulatory calendar, alongside internal read-time deadlines, so a new EDPB guideline or Commission proposal shows up next to the organisation's own compliance milestones — no manual trawling of regulatory websites.

Per-tenant regulatory impact: each update in the regulatory calendar now shows its concrete impact on the tenant — a badge with the number of active frameworks affected and the total control count, plus an expandable panel listing them (code, name, control count, active or not). Matching between an update's free-text framework name and the catalogue code is fuzzy — alphanumeric normalisation, cross-matching by code and by name, and known aliases — and codes with no match are declared as such rather than silently dropped.

Issues — Cross-Cutting Aggregate View

The /dashboard/issues page pulls everything in the organisation that needs attention into a single per-tenant feed: open gaps, integration findings (Wazuh, EterScan, Prowler), audit findings, CAPAs, failed control tests — both manual and from continuous L3 monitoring — and unresolved incidents. Exact count cards per source, filters by source and normalised severity, drill-down into the originating module. Read-only in v1, with a 100-item-per-source cap and a clear truncation indicator. The GET /api/v1/issues route returns an {data, meta:{total, counts}} envelope.

Transfer Impact Assessment (TIA) & DPF Watch

The TIA module addresses the GDPR obligation to assess the impact of international personal-data transfers, as established in GDPR Art. 44–49, grounded in the Schrems II judgment (CJEU C-311/18) and EDPB Recommendations 01/2020 on supplementary measures.

Regulatory trigger: Following the collapse of the EU–US Data Privacy Framework (DPF) on 29 June 2026 (Trump v. Slaughter), transfers based on that adequacy decision lost their legal basis. Organisations relying on the DPF must now use an alternative mechanism — Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or Art. 49 derogations — and, in any case, conduct a formal Transfer Impact Assessment whenever there is a risk of access by authorities in third countries.

  • TIA register: creation and management of assessments by destination country and legal mechanism (Adequacy Decision | SCCs | BCRs | DPF | Art. 49 Derogations)
  • Lifecycle: DRAFT → UNDER_REVIEW → APPROVED / REJECTED / NEEDS_REVISION, with a mandatory periodic review date
  • Assessment fields: analysis of the surveillance risk in the destination country; supplementary measures adopted; residual risk (LOW / MEDIUM / HIGH / CRITICAL); decision and rationale
  • Optional links: Data Flow, RoPA entry, Vendor or DPA already on the platform — no data duplication
  • Access control: ADMIN, MANAGER, AUDITOR and SUPER_ADMIN roles; fully multi-tenant
  • Route: /dashboard/transfer-impact-assessments
StateDescriptionTransition
DRAFTTIA being prepared→ UNDER_REVIEW
UNDER_REVIEWUnder assessment by the CISO / DPO→ APPROVED · REJECTED · NEEDS_REVISION
APPROVEDTransfer authorised, with rationale→ NEEDS_REVISION
REJECTEDTransfer not authorised→ DRAFT (revision)
NEEDS_REVISIONApproval expired or conditions changed→ UNDER_REVIEW

DPF Watch is a dashboard card that auto-derives — with no manual data entry — all Data Flows and DPAs in the tenant that involve a DPF-based or adequacy-based transfer to the US and have no approved TIA associated. When uncovered flows exist, the card displays a red alert listing the affected transfers, ensuring that no high-risk transfer goes undetected after a legal-framework change such as the collapse of the DPF in June 2026.

Legal basis: GDPR Art. 44–49; Schrems II (CJEU C-311/18); EDPB Recommendations 01/2020; GDPR Art. 46.

Roadmap — Wave 2 FUTURE: AI scoring of transfer risk by destination country (automatic analysis of local legislation, data-sharing agreements and case law); exposure of approved TIAs in the public Trust Center for proactive demonstration of compliance. These items are not active in the current version of the platform.
Digital Minute Book with Hash Chain

The organisation's governing bodies — board of directors, security committee, ethics committee or any body defined by the client — each have their own minute book: sequential page numbering, a hash chain that makes any later alteration detectable, approval and signature by those present. Historical minutes in PDF can be imported for consultation and search; they are marked as imported and kept outside the hash chain — history comes into the platform without pretending it was born there.

Contracts with a Data Act Checklist

The Contracts module checks every agreement with cloud and data-processing providers against a 16-item Data Act checklist (Regulation (EU) 2023/2854): mandatory switching clauses (Art. 25), the black and grey lists of unfair B2B terms (Art. 13), transition and erasure. Score per contract, a dedicated panel, and AI pre-filling. It applies to all new contracts since 12 September 2025.

Case-by-Case Access — Per-User Exceptions

The role (Admin, Manager, Viewer, Auditor or a custom role) remains the baseline. On top of it, the administrator defines person by person what each one can do (73 permissions, grant or deny), which menus and pages they see (hiding a page also closes its URL) and which entities' data they see. Simple, auditable precedence: deny > grant > role. Two safeguards come with it: an escalation ceiling (nobody grants a role above their own) and last-administrator protection. Page and entity restrictions are rolled out gradually in each organisation: first they record what they would block, and only after review do they start blocking.

Several Organisations per Account — Consultants and External Members

One person can belong to several organisations with the same account — the typical case is the consultant or vCISO who looks after several clients. Anyone who belongs to more than one organisation sees an organisation switcher in the status bar, with the active organisation always visible; switching organisation takes one click, with no new sign-up. Within the same organisation, a person can also work across several entities.

The client stays in control. External members join by invitation from the organisation's administrator, are labelled «External» (with their home organisation) in People → Access, and can be deactivated in that organisation only without affecting the account or the other organisations. Each organisation can, in its security settings, refuse external members. A second factor is always mandatory to sign in as an external member, and a client organisation's SSO only accepts accounts from that organisation — the client's identity provider never authenticates the consultant in the other clients. An external member coming from a partner does not count towards the plan the client has contracted.

Security Policy per Organisation

Each organisation sets its own policy in Settings → Security: mandatory MFA for nobody, administrators only or all users; whether to accept the email code as an alternative to the authenticator app; a maximum idle time (5 minutes to 8 hours) and a maximum session duration (1 hour to 7 days). Expiry is enforced on the server, not just in the browser, and is recorded in the audit log. The organisation's policy can only tighten the platform's minimum requirements, never loosen them.

SCIM 2.0 Provisioning and SSO per Organisation

SSO (SAML 2.0 and OIDC) is configured per organisation, with each one's own email domains: a domain can belong to only one organisation. From the settings, the administrator generates a SCIM token for the identity provider — Microsoft Entra ID, Okta or compatible — which then creates, updates and deactivates accounts and groups (departments) automatically; the mapped groups set the role of the people it creates. The SCIM token works for SCIM only, has an expiry date and can be revoked. Deactivating an account in the identity provider ends its sessions in under a minute, and the last administrator is never deactivated.

Approvals with Segregation of Duties

Whoever submits, creates or owns a record should not be the one who approves it — the «four eyes» control that a due diligence (DORA Art. 28, ISO 27001 A.5.3) looks for. Each organisation chooses the mode in Settings → Security: off, log only (the default — the conflict is flagged and recorded, but the approval goes through) or mandatory (the approval is refused). The choice belongs to the organisation because many SMEs have a single administrator. It applies to policies, control exceptions, minutes, quality documents, management review, vendor assessments and access reviews.

Entity Groups — Hierarchy and Consolidated View

The entities of an organisation can be arranged in a tree: the parent entity (the holding) has its subsidiaries beneath it. Anyone with access to the parent entity sees the consolidated group view — dashboard, assets, contracts and the other records of the parent and of all its subsidiaries —, with the role inherited from the nearest entity. Contracts inherit the vendor's entity. Only administrators can change the parent entity, so that a manager with a restricted scope cannot widen their own access.

Cybersecurity Investment

How much is being spent on security today, on what, and how much of that spend already works for each framework. The Cybersecurity Investment page records annual spend lines — tools, licences, services, audits and certifications, training, insurance —, with CSV import, renewals in the next 90 days and CAPEX amortisation. Each line can be allocated to controls, risks or assets; the spend on a control is split across the active frameworks it covers (including mapped ones), so the total per framework does not double-count, and the screen also shows what is still unallocated and what is shared between frameworks. People costs are recorded by role, never by person, and are hidden from anyone without the specific permission. In this version the currency is the euro.

Reliable Automatic Tasks

The platform's periodic tasks — reminders and notifications, access reviews, integrity checks, synchronisations, watches and reports — run on a persistent queue with automatic retry on failure, and the same task never runs twice at the same time (no duplicate emails). A final failure raises an alert to the operations team, and super-administrators have a task status view.

Portability and Switching Providers (Data Act)

EterShield applies Chapter VI of the Data Act to itself: full export of the organisation's data as a ZIP (records and evidence files), available to the administrator and via API; a public /trust-center/data-act page with the structures, formats and switching procedure; and Terms of Service that guarantee switching, portability and erasure with no switching charges.

Language, Modules and Content per Entity

Each organisation sets its default language (PT or EN) and each user their own. The interface, notifications, the vendor portal, the Statement of Applicability and the control catalogue are available in European Portuguese and English. In a group with a subsidiary in another country, the foreign entity can work in English and see the group's shared records — AI Act, SoA, CAPA, objectives, management review, Trust Center — in its own language, with the same login and no duplicated data. Features that only make sense for some clients are modules per organisation: they appear when the matching framework or integration is active, or when the administrator turns them on — vulnerability watch, for example, only appears to organisations with technical monitoring connected.

PART III Architecture
13 Full Technical Stack
┌─────────────────────────────────────────────────────────────────────────┐ │ USERS │ │ Browser / PWA Mobile (iOS / Android) │ └──────────────────────────────┬──────────────────────────────────────────┘ │ ┌──────────────────────────────▼──────────────────────────────────────────┐ │ CLOUDFLARE (WAF + CDN + DNS) │ └──────────────────────────────┬──────────────────────────────────────────┘ │ ┌──────────────────────────────▼──────────────────────────────────────────┐ │ DEDICATED HOSTING IN THE EUROPEAN UNION │ │ │ │ Web Application · Next.js 15 · React 18 · REST API + Server Actions │ │ Authentication · MFA · SSO (Google / Entra ID / OIDC / SAML 2.0) │ │ │ │ GRC · Risk · TPRM · HR Security · ISO 9001 · OH&S │ │ ESG · BCM · Audits · CAPA · Evidence · Knowledge Base │ │ Network Alerts (EterSOC) · Fleet · Facilities │ └──────────────────────────────┬──────────────────────────────────────────┘ │ ┌──────────────────────────────▼──────────────────────────────────────────┐ │ DATA AND SERVICES (EU) │ │ │ │ PostgreSQL 16 (pgvector) Redis 7 MinIO (S3-compatible) │ │ (PT/EN semantic search) (cache/queues) (evidence, PDFs) │ │ │ │ AI: Claude via internal gateway | pgvector semantic search │ │ Integrations: EterSOC (Wazuh/Suricata) · GitHub · M365 · GCP · GWS │ └─────────────────────────────────────────────────────────────────────────┘
ComponentTechnologyDetail
Frontend + BackendNext.js 15 (App Router) + React 18Hybrid rendering, Server Actions, SSR
DatabasePostgreSQL 16 (pgvector) + PrismaExtensions vector (pgvector), pg_trgm, uuid-ossp — semantic search for European Portuguese active
RuntimeNode.js 20pnpm monorepo, standalone build
Cache / QueuesRedis 7 (alpine)Rate limiting, asynchronous AI processing
FilesMinIO (S3-compatible storage)Evidence, PDFs, documents
AuthenticationNextAuth v4 + SAML 2.0Credentials + MFA (TOTP), Google OAuth, Microsoft Entra ID (bound to the organisation's directory), OIDC, SAML with automatic provisioning — no demo mode
i18nNative internationalisationPT-PT + EN across the interface and the control catalogue; language per organisation, per user and per entity
AI GatewayInternal gatewaySingle LLM backend = Claude; never exposed to the internet
HostingDedicated server in the EU (France)Docker containers behind nginx + Let's Encrypt — data never leaves the EEA. Security monitoring (EterSOC) runs on separate infrastructure, linked by an encrypted channel
Transactional emailOwn mail server (EU)Authenticated SMTP over TLS — no email sub-processor
CDN / WAFCloudflareDDoS protection, bot filtering, DNS
BillingStripeBase-platform subscription, 14-day trials; frameworks, modules and extras contracted per organisation. Online checkout is being activated
14 Integrations and Data Flows
Wazuh SIEM Integration — Bidirectional

Wazuh → EterShield: Security alerts and findings automatically imported as incidents or evidence. A critical intrusion alert in Wazuh automatically generates an incident in EterShield with NIS2 countdown.

EterShield → Wazuh: All mutations on the platform are recorded in the audit log and forwarded to the Wazuh SIEM in real time — immutable audit trail outside the platform for external auditors.

Managed agents: for clients with EterSOC monitoring, the Wazuh agent installer (Linux and Windows) is generated per organisation, with an enrolment token of limited validity and number of uses; the connection to the Wazuh API validates the certificate by pinned fingerprint.

NIDS Integration — Network Alerts (NetworkAlerts)

EterShield integrates with a host-level Suricata NIDS sensor running the ET Open ruleset for real-time network alert ingestion. Alerts reach the NetworkAlerts module through an authenticated ingest channel; severity is mapped automatically (CRITICAL / HIGH / MEDIUM / LOW), and CRITICAL alerts automatically generate an Incident with the NIS2 countdown active. The Network Alerts dashboard centralises events with filters by severity, outcome, protocol and source IP, and allows manual escalation for any alert.

Less noise, more signal: a full ruleset fires constantly against any server exposed to the internet. Before it can open an incident, every alert goes through five layers of automatic triage — the observed outcome of the attack (a blocked attempt is never CRITICAL), a service that does not exist on the target, correlation of attack families by source, archiving of scans and reputation hits with no evidence of success, and exclusion of responses to requests made by Eter Growth's own crawlers. A CRITICAL still means something.

Posture and Identity Connectors

EterShield also ships integration services for cloud and identity posture: GitHub, Microsoft 365 / Entra ID (via Microsoft Graph), Google Cloud Platform, and Google Workspace (Admin SDK) — feeding findings and posture data into the same Gaps/Risks pipeline as manual assessments.

Vulnerability Watch

Vulnerability feed from the EUVD (ENISA) and the NVD, enriched with EPSS and the CISA KEV catalogue, with risk-based prioritisation and time-to-patch metrics. It is a module that switches on for organisations with technical monitoring (Wazuh, EterScan or OpenCTI) and records each CVE only once, whichever source it comes from.

GLPI Integration — Inventory and Tickets

Bidirectional synchronisation: GLPI assets appear automatically in EterShield. When a gap is approved, a remediation ticket is automatically created in GLPI with priority and deadline.

Remediation Sync — Jira and ServiceNow

Remediation tasks can push automatically to external ITSM systems, with the sync toggled per integration so a tenant can enable Jira, ServiceNow, both, or neither. The Jira webhook was hardened with HMAC signature verification on inbound calls, rejecting any request that cannot be authenticated as originating from the configured Jira instance. A new ServiceNow connector joins Jira and GLPI as a supported ticketing target for remediation tasks generated from gaps, findings, and CAPAs.

API EtherFlow
POST /api/v1/etherflow/ingest Authorization: Bearer <api-key> { "transcription": "...", "meetingType": "REVIEW | INCIDENT | DIAGNOSTIC | BOARD | OTHER", "entityId": "optional", "recordedAt": "2026-06-08T14:00:00Z" }

Integration with any automatic transcription system (Teams, Zoom, Google Meet) via webhook or direct call.

15 Platform Security
ControlDetail
Multi-tenancyIsolation per organisation across all queries, reinforced with layered isolation controls: validation that the session belongs to the active organisation, an automatic guard that detects queries without an organisation filter (in an observation period before it starts blocking) and an application connection to the database without administrator privileges. A person can belong to several organisations, with a switcher and mandatory MFA for external members
AuthenticationNextAuth v4 — credentials + MFA (TOTP), mandatory for administrators (policy by domain and by role, enforced since 15 September 2026); Google OAuth, OIDC and SAML 2.0 with domain validation and automatic provisioning per organisation; Microsoft Entra ID login bound to the client's directory; no demo/bypass login mode; security policy per organisation (MFA for nobody, administrators or all; session expiry on inactivity and on maximum duration, enforced on the server); SCIM 2.0 provisioning (Entra ID, Okta)
AuthorisationRBAC — Admin / Manager / Viewer / Auditor — per module and operation; custom roles and per-user access exceptions (grant/deny actions, pages and entity scope, person by person; deny always wins); escalation ceiling — nobody grants more than they have; segregation of duties in approvals (configurable per organisation)
Rate LimitingAutomatic protection on all sensitive endpoints (authentication, AI, API)
CSPDynamic nonce-based Content Security Policy — mitigates XSS
Soft DeleteDeleted records marked, never destroyed — recoverability and audit trail
Audit TrailAll operations — user, timestamp, operation — hash-chained and verified daily; immutable log — the database refuses any change to or removal of an audit record; forwarded to external SIEM
Evidence integritySHA-256 hash stored at upload and checked periodically
PII EncryptionAES-256-GCM for disciplinary and sensitive personnel data
Data in the EUDedicated server in the EU (France) + Cloudflare EU — no transfers outside the EEA
Transactional emailSent from Eter Growth's own mail server in the EU — no email sub-processor
Federated SSOAuthentication tokens between Eter products validate audience and issuer — isolation guaranteed by design
Isolated AI GatewayAll requests to Claude pass through an internal authenticated gateway that is never exposed to the internet — no direct calls to external APIs from application code
External SIEMAudit trail forwarded to the EterSOC stack (Wazuh) — immutability guaranteed outside the platform
BackupsDaily encrypted backup (AES-256), automatic upload to external storage in the EU, configurable retention. End-to-end restore tested and timed on 18 September 2026: critical path back in 1 h 48 min (RTO target: 8 h)
Vulnerability disclosurePublic coordinated vulnerability disclosure policy and /.well-known/security.txt (RFC 9116) — contact security@etershield.com
Portability (Data Act)Full export of the organisation's data as a ZIP via API; public Art. 26 register at /trust-center/data-act; switching with no switching charges (Terms of Service)
NIDSHost-level network intrusion detection — Suricata with the ET Open ruleset and five-layer automatic false-positive triage; CRITICAL alerts automatically generate Incidents in EterShield
Data in Europe — no exceptions: all EterShield data resides in Europe — application, security monitoring, backups and email on servers in the EU. When using EterShield, there is no sub-processor outside the EU processing the organisation's compliance data — relevant for clients' GDPR.
Trust in the Service — How to Verify It

A compliance platform holds what an organisation keeps most closely about its own security posture: what remains undone, where the gaps are, which incidents occurred. The client's legitimate question is not whether the platform is secure — it is how they verify that it is. What follows is the answer in verifiable terms.

Isolation and access profiles. Isolation by organisation is enforced on every data operation, not as a coding convention but as a condition of each query — there is no path by which one organisation's data surfaces in another. That isolation is reinforced by layered controls: the session's membership of the organisation is validated on every request, an automatic guard flags any query without an organisation filter (in an observation period) and the application connects to the database with a role without administrator privileges. On top of that, granular access profiles (RBAC) per entity and per module let an organisation with several companies or business units give each team exactly what belongs to it.

Second factor mandatory on administrative accounts. Accounts with administrative privileges require a second factor — an authenticator application (TOTP) or an email code as the alternative method. It is neither optional nor deferrable by client configuration: an administrative account without a second factor can no longer complete sign-in.

Privileged access, visible to the client. There are moments when the Eter Growth team needs to enter a client's organisation to diagnose a problem. That access is not a standing administrator privilege: it is a temporary grant, with a recorded reason, a defined term and an automatic end. While it lasts, the client sees that we are there — a persistent notice in the interface states that the session is running under a grant and how much time remains. Every visit is recorded to the second in the organisation's own audit log, which they can consult without asking us for anything.

The difference from common industry practice is this: instead of the vendor being able to enter without leaving a visible trace, here the entry is visible to the party being visited, must be justified, and expires on its own. It is the same principle we require of our clients in their privileged access controls — applied to ourselves.

Artificial intelligence and exit. Requests to the AI pass through our own intermediary service, with usage logging; content is not used to train models. The organisation can export all of its data at any time — as a ZIP with the records and the evidence files, or as JSON — with no request, no waiting period and no retention used as commercial leverage. The ability to leave is part of the offer: a compliance platform that holds a client's data hostage becomes, itself, a continuity risk to record in that client's risk register.

PART IV Market Comparison
16 GRC / vCISO Solutions Landscape
GRC/vCISO SOLUTIONS ON THE MARKET ┌──────────────────────────────────────────────────────────────┐ │ ENTERPRISE GRC │ │ OneTrust · IBM OpenPages · ServiceNow GRC · RSA Archer │ ├──────────────────────────────────────────────────────────────┤ │ COMPLIANCE AUTOMATION (SaaS) │ │ Drata · Vanta · Sprinto · Tugboat Logic │ ├──────────────────────────────────────────────────────────────┤ │ vCISO / MSSP PLATFORMS │ │ Cynomi · Defendify · Balbix · Kaseya 365 Security │ ├──────────────────────────────────────────────────────────────┤ │ OPEN SOURCE GRC │ │ Eramba · OpenGRC · Heimdall │ ├──────────────────────────────────────────────────────────────┤ │ ETERSHIELD │ │ European SME · Integrated IMS · Contextual AI · Native PT │ └──────────────────────────────────────────────────────────────┘ COST: ████████████████████████████████░░ LOW OneTrust (€100k+) EterShield (From €149/month + frameworks )
17 EterShield vs. Eramba
CriterionErambaEterShield
ModelSelf-hosted (free) or SaaS (€800+/month)Managed SaaS — immediate access
Installation4–8 hours for self-hostedZero — trial in 5 minutes
Native AINoneContextual AI with RAG per entity
NIS2 / DORAManual (customisation)Native PT-PT frameworks
TPRMBasic moduleAdaptive questionnaire + AI + public portal
HR SecurityNoneJML, Access Reviews, Disciplinary (AES-256)
ISO 9001 / ISO 45001NoneComplete modules
ESG / CSRDNoneNative ESRS E1/S1/G1
Monte Carlo / FAIRNone10,000 simulations, ALE in euros
LanguageEnglishNative PT-PT + EN
DataDepends on client's deploymentEU always
When to choose Eramba: senior GRC technical team that wants full infrastructure control, zero budget, no need for AI or modules beyond the GRC core. When to choose EterShield: SME without an internal CISO, NIS2/DORA is a requirement, wants value within days, needs an integrated IMS.
18 EterShield vs. OneTrust
CriterionOneTrustEterShield
Target audienceLarge companies (500+ employees) with a dedicated DPOSMEs and mid-sized companies (10–500 employees)
Price€50,000 – €200,000+/yearFrom €149/month + frameworks
Implementation3–6 months with consultantsDays (trial → production)
GDPR / RoPAMarket referenceComplete module
NIS2 / DORAConfigurable with effortNative, PT-PT
Generative AILimited to some modulesIntegrated across the whole platform
Data in the EUConfigurableAlways
ISO 9001 / OH&SNoneNative modules
ESG / CSRDEnterprise onlyÀ la carte module (€39/month)

OneTrust is irreplaceable for multinationals operating across multiple jurisdictions. For the Portuguese SME market, the cost is prohibitive and the complexity excessive.

19 EterShield vs. Drata / Vanta
CriterionDrata / VantaEterShield
Target marketUSA / UK, SaaS startupsEurope (PT, ES, EU), traditional SMEs
FrameworksSOC 2, ISO 27001, HIPAA, PCI DSS40 frameworks incl. RJC, NIS2, DORA, GDPR, RGPC, Data Act, ISO 9001, ISO 45001, CSRD, NIST CSF 2.0, CIS Controls v8, HIPAA Security Rule, Cyber Resilience Act, TISAX, QNRCS, HACCP, NP 4469, ISO 55001, ISO 56001
GDPR / NIS2 / DORANo real supportNative
NIDS / Network AlertsNoneSuricata NIDS (ET Open) with automatic triage; CRITICAL → automatic Incident
Integrations100+ (GitHub, AWS, GCP, Slack)Wazuh, GLPI, EterScan, Gophish, webhooks
AIBasic automationContextual AI with RAG per entity
Price$1,000 – $5,000+/monthFrom €149/month + frameworks
DataUSAEU
LanguageEnglishPT-PT + EN

Drata/Vanta are excellent for English-speaking startups focused on SOC 2. For a European SME that needs NIS2, DORA, ISO 27001, and ISO 9001 in Portuguese with data in the EU — EterShield is the natural choice.

20 EterShield vs. Cynomi
CriterionCynomiEterShield
Sales modelExclusively MSPs (B2B2B)Direct to SME + MSP/vCISO channel
PriceCustom, ~$500–$2,000+/monthFrom €149/month + frameworks
AIAI CISO (automatic reports)Generative AI + RAG per entity
Frameworks~8 (ISO 27001, SOC 2, NIS2, HIPAA)40 frameworks
OH&S / Fleet / FacilitiesNoneIntegrated modules
NIDS / Network AlertsNoneSuricata NIDS (ET Open) with automatic triage; CRITICAL → automatic Incident
HR SecurityNoneJML, disciplinary, Access Reviews, DSR
Audit Trail → SIEMNoneAutomatic Wazuh forward
WhistleblowerNoneNative (AES-256-GCM)
Knowledge Base / FTSNoneComplete system per entity
PT marketNoneNative PT-PT + CNCS + ANACOM routing
21 Cost-Benefit Analysis
Comparison Table
Eramba SaaSOneTrustDrata/VantaCynomiEterShield
Annual SME cost€9,600+€50,000+€12,000–60,000€6,000–24,000€2,508–8,388 ¹
Integrated IMS✗✗✗✗✓
Native NIS2/DORA PT✗✗✗Partial✓
Contextual AI (RAG)✗PartialPartialPartial✓
HR Security✗Partial✗✗✓ ²
ISO 9001 / Quality✗✗✗✗✓ ²
ESG / CSRD✗Enterprise✗✗✓ ²
NetworkAlerts (NIDS)✗✗✗✗✓ ²
Monte Carlo / FAIR✗✗✗✗✓
Whistleblower✗Enterprise✗✗✓
Portuguese language✗✗✗✗✓
Guaranteed EU dataDependsConfigurable✗Partial✓
¹ Base platform €149/month with SSO included + frameworks à la carte (€13/€20/€27) + operational modules — see pricing.  ² À la carte operational module (€19–€39/month) or in the Operations Bundle (€149/month).
Total Cost of Ownership (5 years, 50-employee SME)
SolutionYear 1Years 2–5 (average)5-year Total
OneTrust€60,000€55,000/year€280,000+
Drata (Professional)€20,000€18,000/year€92,000
Cynomi (MSP)€15,000€12,000/year€63,000
Eramba SaaS€10,000€9,600/year€48,400
EterShield (base + ISO 27001 + NIS2 + GDPR + Operations Bundle)€4,786€4,296/year€21,970
EterShield (base + ISO 27001 + NIS2 + GDPR)€2,998€2,508/year€13,030

Base + 3 frameworks + Operations Bundle = €149 + €60 + €149 = €358/month — all operational modules without changing platform.

ROI — Three Scenarios
  • NIS2 Compliance: typical SME fine for non-compliance: €100,000. EterShield provides technical and documentary evidence of compliance. Positive ROI from the first avoided compliance event.
  • ISO 27001 Certification: external consultants cost €15,000–50,000 and take 6–18 months. With EterShield, the process is accelerated by AI and already-structured evidence. Consultancy cost reduction: €10,000–30,000 per cycle.
  • Knowledge that stays: an SME that depends on an external consultant pays €2,000–5,000/month. When the consultant leaves, the knowledge disappears. EterShield preserves that knowledge — the next person in charge starts where the previous one left off.
PART V Implementation
22 Requirements and Prerequisites
Access Requirements

EterShield is SaaS — no software installation, no servers to configure. A modern browser (Chrome 120+, Firefox 120+, Safari 17+), an internet connection, and an email address.

For Advanced Features
FeaturePrerequisite
SSO SAML 2.0 / OIDCConfiguration on the IdP (Okta, Entra ID, Google Workspace); optional automatic provisioning per organisation
SCIM 2.0 provisioningSCIM token generated in the settings and configured on the IdP (Entra ID, Okta)
Microsoft Entra ID loginThe organisation's Entra directory ID registered on the platform
Wazuh SIEM IntegrationNetwork connectivity between the Wazuh Manager and EterShield infrastructure
GLPI IntegrationGLPI API active with access token
API EtherFlowAPI key generated on the platform; accessible endpoint
Pricing (September 2026)
ComponentPriceIncludes
TrialFree (14 days)Full access, no card
Base platform€149/month1 entity · 25 users · 50 GB · 300 AI calls/month · SAML SSO and MFA · 99.0% SLA
Frameworks€13 / €20 / €27 per monthBy regulatory tier; open frameworks included
Operational modules€19 – €39/monthOperations Bundle (7 modules): €149/month
OptionsREST API €49/monthEntity +€79/month · user +€9/month

Single price list; outside Portugal a market multiplier applies. Full price list available on request. Online payment through Stripe checkout is being activated; until then, subscriptions are arranged directly with Eter Growth.

23 The Onboarding Model
Phase 1
Activation
Day 1
  • Account created (14-day trial, no card required)
  • Entity profile wizard (6 steps, ~15 min)
  • Active frameworks selected
  • AI suggests NIS2 authority and high-priority gaps
Phase 2
First Assessments
Week 1
  • Start assessment of the main framework
  • Activate AI Gap Analysis
  • Create risk register with the first 10–15 risks
  • Add critical assets to the inventory
Phase 3
Data and Knowledge
Weeks 2–4
  • Upload existing documentation to the Knowledge Base
  • Use EtherFlow in compliance meetings
  • Add first vendors and launch TPRM
  • Configure Wazuh integration (if applicable)
Phase 4
Operationalisation
Month 2+
  • Launch first internal audit cycle
  • Activate compliance calendar
  • HR Security module for JML and Access Reviews
  • Prepare evidence for external audit
24 Evolution Roadmap
Current State — September 2026
40
Frameworks and methodologies
1771
Controls mapped
18
Operational modules
Live
www.etershield.com
The platform is live with: GRC core, Risk (Monte Carlo/FAIR, with version history), TPRM, People and HR Security, ISO 9001, OH&S, ESG/CSRD, BCM, Fleet, Facilities, Audits, Evidence (freshness/TTL, continuous coverage view, Google Drive Livesync, evidence by link, verifiable integrity), Network Alerts (EterSOC) — Suricata with the ET Open ruleset and five-layer automatic triage, real-time network alerts, automatic escalation to Incidents — AI Security: ARIA Assessment, AI Incidents, Model Cards/AI Register, Red Team Scheduler and EU AI Act Assessment — TIA / DPF Watch and Automated Regulatory Watch (weekly EDPB / European Commission RSS feed + AI classification + human review queue). Add-on model active: frameworks and operational modules individually activatable on any composition; Operations Bundle available on any composition. Remediation Sync: automatic push of tasks to Jira (HMAC-verified webhook) and ServiceNow, alongside GLPI. Since July: public institutional Trust Center and /about disclosure; 7 crisis playbooks with 83 steps and a RACI matrix; cross-cutting Issues view, automatic KRIs on continuous monitoring and a loss-event register; the RJC (DL 125/2025), RGPC and Data Act frameworks (40 frameworks, 1771 controls); full data export and a public portability page; Data Act checklist for contracts; minute book with history import; risk version history; Microsoft Entra ID login bound to the organisation's directory; per-user access exceptions; language and modules per organisation. September 2026: frameworks contracted per entity; a single people directory with automatic provisioning through SSO; mandatory MFA for administrators; interface, notifications and control catalogue in European Portuguese and English, with content in each entity's language; evidence integrity and a hash-chained audit log; vulnerability watch per organisation; transactional email from Eter Growth's own mail server. October 2026: several organisations per account, with a switcher and external members controlled by the client (MFA always mandatory); security policy per organisation (MFA, session); SCIM 2.0 provisioning; segregation of duties in approvals; entity hierarchy with a consolidated group view; immutable audit log; automatic tasks on a persistent queue; Cybersecurity Investment. Infrastructure: new production infrastructure in the EU since 18 September 2026, with a full restore timed at 1 h 48 min; security monitoring segregated from the application.
Planned Developments
PriorityFeatureImpact
HighMaturity Benchmarks by sectorAnonymous comparison with organisations in the same sector
HighDORA RTS for financial entitiesDORA report templates for BdP
HighRGPC — management of the Risk Prevention Plan, the Compliance Officer and conflicts of interestIn development (lots 2 and 3 of the RGPC framework)
HighIsolation between organisations also enforced at database level, and the isolation guard in blocking modePrepared; activation follows an observation period with no warnings — not yet active
MediumImmutable evidence with locked retention (Object Lock)Evidence storage that cannot be altered or deleted during the retention period
MediumOpenCTI IntegrationSector-contextualised threat intelligence
MediumMulti-language (ES, FR)Expansion to Iberian and Francophone markets
FutureNative Mobile App (iOS / Android)Push notifications, full mobile access
FutureAutonomous AI AgentAgent that proposes and executes remediations with human approval
PART VI Use Cases and Playbooks
25 Real-World Compliance Scenarios
SCENARIO 01 Logistics SME Pursuing ISO 27001 Certification

Situation: a logistics company with 120 employees needs ISO 27001 certification as a requirement from a customer in the automotive sector. No CISO. The IT Manager has other responsibilities.

  • Profile wizard automatically identifies 34 high-priority controls for the logistics sector
  • Knowledge Base loaded with existing policy (outdated Word document) — AI extracts already-implemented controls
  • AI Gap Analysis identifies 27 gaps ordered by impact; generates policy draft for 20 of them in <2 hours
  • Evidence uploaded with OCR; auditor accesses the Auditor Portal
  • Result: certification cycle reduced from 12 to 6 months; consultancy cost reduced by 40%
SCENARIO 02 Ransomware Incident with NIS2 Obligation

Situation: a health clinic (NIS2 PT) detects ransomware on 3 servers. It is 14:30 on a Friday.

  • Incident created → countdowns activated: 23h30 for CNCS and 71h30 for DPA (CNPD)
  • ANACOM routing identifies: CNCS + DPA/CNPD (health personal data affected)
  • Wazuh SIEM imports technical alerts as incident evidence
  • At 22:30: notification to CNCS sent within 24 hours; record on the platform with timestamp
  • Result: legal compliance demonstrated with evidence; GDPR fine avoided
SCENARIO 03 vCISO Consultancy Managing 8 Clients

Situation: a cybersecurity consultancy manages 8 SME clients with different maturity levels and frameworks.

  • Multi-client dashboard: 8 entities in a single panel with compliance scores
  • AI uses each organisation's specific Knowledge Base — contextualised suggestions per client
  • Automatic PDF reports per client generated monthly for management
  • Auditor Portal: when a client needs an audit, the auditor accesses without seeing the other 7
  • Result: consultancy manages 8 clients with the quality of a dedicated internal CISO, at 30% of the cost
SCENARIO 04 Financial Company under DORA

Situation: an asset management company with 200 employees, subject to DORA, in a remediation process.

  • Cross-framework: 14 of the 24 DORA controls already have a partial response from existing ISO 27001 work
  • DORA critical functions: mapping of business functions and contracts with ICT vendors
  • ICT incidents: automatic countdown (4 hours for major DORA incidents)
  • Result: DORA compliance documented in 8 weeks instead of the expected 6 months
26 Operation Playbooks
PB-01 Monthly Compliance Cycle 2–4 hours / month
  • Review dashboard — compliance score and trend
  • Check compliance calendar — events for the next month
  • Review overdue tasks — reassign or renegotiate deadlines
  • Process EtherFlow inbox — approve/reject items from the monthly meeting
  • Review vendor alerts — assessments expiring in the next 60 days
  • Review pending access reviews — approve or revoke access
  • Check for missing evidence for critical controls
  • Update risks with new developments (new systems, new vendors)
PB-02 Onboarding a New Critical Vendor 3–5 days
  • Create vendor record in EterShield with risk profile
  • Launch TPRM questionnaire — send link to vendor (deadline: 5 business days)
  • Review AI analysis: score, red flags, recommendation
  • If red flags: request additional clarifications
  • Record CISO decision: Approve / Conditional / Reject
  • If Conditional: create CAPA with remediation deadline
  • Schedule next reassessment (6 or 12 months)
  • Associate with ISO 27001 control A.5.19 (supplier relationships)
PB-03 Preparation for External Audit 4–6 weeks prior
Weeks -6 to -4
  • Run AI Gap Analysis for the framework under audit
  • Create remediation tasks for each gap; prioritise by criticality
Weeks -4 to -2
  • Upload missing evidence — screenshots, logs, approvals
  • Check policy versioning — all approved and within validity?
  • Document non-conformances with associated CAPAs
Week -1 and audit day
  • Create access for external auditor in the Auditor Portal
  • For each control questioned: show linked evidence in EterShield
  • Immediately record identified non-conformances as CAPAs
PB-04 Response to a GDPR Data Breach 72 hours + follow-up
First 24 hours
  • Create incident — type: "Personal Data Breach"; DPA/CNPD countdowns (72h) activated
  • Identify: affected data, categories, volume, data subjects
  • Activate immediate containment: revoke access, isolate systems
Hours 24–72
  • Assess risk to data subjects (low / medium / high)
  • Draft and submit notification to the DPA (CNPD) within 72 hours
  • Record submission with reference number
Post-incident
  • CAPA: root cause, corrective measures, deadline
  • Review relevant ISO 27001 / GDPR controls — update evidence
  • Incident report for the board (automatic Board Report PDF)
CONCLUSION EterShield as a Strategic Asset
✦ Conclusion

Security compliance has moved from a peripheral concern to a strategic factor in competitiveness. Organisations that build real security management capability — not just pass audits — gain access to larger clients, public contracts, cyber insurance with lower premiums, and partnerships that require certifications.

EterShield was built for a specific reality: the European SME facing growing regulation without resources for an internal CISO, without budget for enterprise platforms, and without patience for tools that don't speak their language.

40
Frameworks and methodologies
1771
Controls in the database
€149
Base platform / month
What EterShield is not: it is not a solution that guarantees certification; it does not replace human judgement in critical decisions; it does not eliminate the need for external auditors.

What EterShield is: the difference between starting each certification cycle from scratch or with two years of structured knowledge. The difference between discovering a NIS2 incident at 15:00 on a Friday not knowing what to do, or having a workflow that counts the hours and tells you exactly who to notify. The difference between a consultant who takes the knowledge when they leave, and an organisational asset that stays.
G Glossary
TermDefinition
vCISOVirtual Chief Information Security Officer — the CISO function outsourced to a partner or platform
GRCGovernance, Risk and Compliance — set of processes for managing governance, risk, and compliance
IMSIntegrated Management System — a management system that combines multiple standards (ISO 27001, ISO 9001, ISO 45001…)
RAGRetrieval-Augmented Generation — AI technique that injects relevant context into prompts for precise and contextualised responses
FAIRFactor Analysis of Information Risk — financial quantification methodology for cyber risk
ALEAnnualised Loss Expectancy — expected annual financial loss, the output of the FAIR/Monte Carlo model
TPRMThird-Party Risk Management — management of risks associated with vendors and third parties
JMLJoiners, Movers, Leavers — the access lifecycle of employees
DSRData Subject Request — a request by a data subject under GDPR (access, rectification, erasure…)
CAPACorrective and Preventive Action — plan of corrective and preventive actions for non-conformances
NIS2Network and Information Security Directive 2 — European cybersecurity directive (2022/2555)
DORADigital Operational Resilience Act — European digital resilience regulation for the financial sector (2022/2554)
CSRDCorporate Sustainability Reporting Directive — European sustainability reporting directive (2022/2464)
ESRSEuropean Sustainability Reporting Standards — CSRD sustainability reporting standards
CNCSCentro Nacional de Cibersegurança (Portuguese National Cybersecurity Centre) — national cybersecurity authority in Portugal
CNPDComissão Nacional de Protecção de Dados (Portuguese Data Protection Authority, DPA) — data protection authority in Portugal
ANACOMAutoridade Nacional de Comunicações (Portuguese National Communications Authority) — NIS2 competent authority for specific sectors in Portugal
MONARCMethod for an Optimised aNAlysis of Risks — ISO 27005 threat catalogue under CC0 licence
AI SparksIntelligent form prefill — automatic AI content suggestion based on gap or entity context
SPCStatistical Process Control — statistical process control (ISO 9001)
RBACRole-Based Access Control — access control by user role
RoPARecord of Processing Activities — Register of Processing Activities (GDPR Article 30)
BIABusiness Impact Analysis — business impact analysis (ISO 22301)
ARIAAgentic Risk Intelligence Assessment — proprietary agentic AI risk assessment methodology in 7 phases
AIVSSAI Vulnerability Scoring System — vulnerability scoring system for AI systems, analogous to CVSS
TIATransfer Impact Assessment — formal assessment of the impact of international personal-data transfers required by GDPR Art. 44–49 and Schrems II
DPFData Privacy Framework — EU–US adequacy decision (invalidated 29 June 2026, Trump v. Slaughter); replaced by SCCs, BCRs, or Art. 49 derogations
DPAData Processing Agreement — contract required under GDPR for sub-processors handling personal data on behalf of a controller
SCCsStandard Contractual Clauses — pre-approved GDPR transfer mechanism for transfers to countries without an adequacy decision
RJCRegime Jurídico da Cibersegurança — Portugal's Cybersecurity Legal Regime, the national transposition of NIS2 (DL 125/2025)
RGPCRegime Geral da Prevenção da Corrupção — Portugal's General Regime for the Prevention of Corruption (DL 109-E/2021), a compliance programme for entities with 50 or more employees
Data ActRegulation (EU) 2023/2854 — access to and sharing of connected-product data, and switching between data-processing services
SCIMSystem for Cross-domain Identity Management — the protocol through which the identity provider (Entra ID, Okta) automatically creates, updates and deactivates accounts and groups
SoDSegregation of Duties — whoever submits a record does not approve it
SSO / JITSingle Sign-On and Just-in-Time provisioning — the account is created automatically at first login through the organisation's identity provider