That is a different question, and most evidence buckets fail it quietly. Versioning is on, the bucket is encrypted, access logging is enabled, and there is still an admin role in the account that can call DeleteObjectVersion on every object in it. Nothing is wrong until someone asks you to prove a negative.

An audit evidence repository on AWS is not a bucket with a good name. It is a write path, a retention decision you cannot take back, and a set of guardrails that survive the person who built them leaving the company. This post covers how to build one with S3 Object Lock and AWS Backup Vault Lock, and more usefully, the five ways I have seen the design go wrong in ways nobody notices until the evidence is needed or the bill arrives.

What “immutable” actually buys you on AWS

Three separate mechanisms get called immutability, and they protect different things.

• S3 Object Lock stops an object version from being overwritten or deleted for a defined period. It works only on versioned buckets, and once you enable it on a bucket you cannot disable it or suspend versioning again.
• AWS Backup Vault Lock does the same job for recovery points in a backup vault, with its own retention floor and ceiling enforced at the vault level.
• Integrity validation, such as CloudTrail’s digest files, proves a file has not changed since delivery. That is a separate property from being undeletable, and auditors increasingly ask for both.

Object Lock is the core of an audit evidence repository on AWS because evidence usually arrives as files: exported reports, signed approvals, config snapshots, log archives. Vault Lock matters when the evidence is a backup of a database or an EBS volume. Integrity validation is what turns “we kept it” into “we kept it and here is the hash chain”.

Failure one: picking the retention mode you cannot walk back

Object Lock has two retention modes and the difference is not cosmetic. In governance mode, a caller who holds the s3:BypassGovernanceRetention permission can shorten or remove retention and delete the version. In compliance mode, nobody can, including the account root user, and the retention period cannot be shortened or downgraded to governance.

Read that second sentence again with a typo in mind. Set seven years where you meant seven days, in compliance mode, and the only exit AWS documents is closing the account. That is not a bug. It is the entire point of the mode. But it means the mode is a business decision wearing a technical costume.

How I decide: compliance mode only where an external rule names a retention period and an external party will inspect it. Everything else starts in governance mode, with the bypass permission granted to nobody by default and denied outright in a service control policy. Governance mode with no principal holding the bypass right is functionally immutable for day-to-day purposes, and it leaves you a documented, auditable escape hatch that requires an explicit policy change to use.

The bypass is not silent, either. Overriding governance retention requires the x-amz-bypass-governance-retention:true header on the request, which means the action shows up in CloudTrail as a distinctly shaped call. That is a good alarm to build.

# Create the bucket with Object Lock on. Versioning is enabled automatically
# and cannot be suspended afterwards.
aws s3api create-bucket 
  --bucket my-evidence-archive 
  --object-lock-enabled-for-bucket 
  --region eu-west-1 
  --create-bucket-configuration LocationConstraint=eu-west-1

# Default retention for NEW objects written to the bucket.
aws s3api put-object-lock-configuration 
  --bucket my-evidence-archive 
  --object-lock-configuration 
  '{"ObjectLockEnabled":"Enabled","Rule":{"DefaultRetention":{"Mode":"GOVERNANCE","Days":365}}}'

Start there. Run it for a quarter. Watch what actually lands in the bucket and how big it gets. Then decide whether compliance mode is worth its permanence.

Failure two: retention that was never applied to the objects that matter

This is the invisible one, and it is the reason to read the rest of this post.

Object Lock is enabled at the bucket level, but retention lives on the individual object version. A default retention rule applies to objects written after the rule exists. It does not reach backwards. Enable Object Lock on an existing bucket holding three years of evidence and you get a bucket that reports Object Lock as enabled while every object already in it carries no retention at all.

The bucket console looks correct. The compliance checklist gets ticked. The old evidence is still deletable by anyone with delete permissions.

Two things to do about it. First, backfill retention on existing versions, either object by object with put-object-retention or, for anything above a few thousand keys, with S3 Batch Operations, which exists precisely for applying retention at scale. Second, verify per object rather than per bucket.

# Check what protection a specific version actually carries.
# Look for ObjectLockMode, ObjectLockRetainUntilDate, ObjectLockLegalHoldStatus.
aws s3api head-object 
  --bucket my-evidence-archive 
  --key 2024/q3/access-review-export.csv 
  --version-id "SOME_VERSION_ID"

The stronger fix is to stop trusting the writer to set retention correctly and enforce a floor in the bucket policy. S3 exposes the s3:object-lock-remaining-retention-days condition key for exactly this, so you can reject writes that ask for too short a lock.

{
  "Version": "2012-10-17",
  "Statement": [
    {
      "Sid": "RejectShortRetention",
      "Effect": "Deny",
      "Principal": "*",
      "Action": "s3:PutObject",
      "Resource": "arn:aws:s3:::my-evidence-archive/*",
      "Condition": {
        "NumericLessThan": {
          "s3:object-lock-remaining-retention-days": "365"
        }
      }
    }
  ]
}

The write path now fails loudly when someone gets it wrong, which is what you want. A rejected upload gets noticed. A silently unprotected object does not.

Failure three: the delete that looks like a delete

Object Lock protects object versions. It does not stop new versions being created, and it does not stop delete markers being placed on top of a protected object.

So a user with ordinary delete permissions can issue a delete against a locked object, get a success response, and make it vanish from every normal listing. The protected version is still there. Nothing was destroyed. But an auditor browsing the bucket sees nothing, and the person who ran the command believes the file is gone.

Three practical consequences:

• Deny s3:DeleteObject on the evidence prefix for everyone except a break-glass role. Immutability is not a substitute for permissions, it is a backstop under them.
• Any retrieval tooling you hand to an auditor must list object versions, not objects. list-object-versions, not list-objects-v2.
• Lifecycle rules interact with this in a way that surprises people. An expiration rule on a versioned bucket adds a delete marker rather than removing data, and a rule that tries to permanently expire a noncurrent version will not remove a version still under retention. Your cleanup policy and your retention policy are two different clocks, and the lock always wins.

Failure four: evidence that arrives already unprovable

Immutability starts when the object lands. Everything before that is chain of custody, and it is where most repositories are weakest.

If the evidence is CloudTrail, use the integrity validation CloudTrail already ships. With log file validation enabled, CloudTrail writes an hourly digest file containing hashes of the log files delivered in that hour, signs each digest with a per-region private key, and puts the digests in a separate folder in the same bucket. You can then verify the chain later.

# Turn on digest files for an existing trail.
aws cloudtrail update-trail 
  --name org-audit-trail 
  --enable-log-file-validation

# Verify a time range later. Files must still be in the location
# CloudTrail delivered them to, or validation cannot run.
aws cloudtrail validate-logs 
  --trail-arn arn:aws:cloudtrail:eu-west-1:111122223333:trail/org-audit-trail 
  --start-time 2020-01-01T00:00:00Z

Two details worth knowing before you design around it. Validation only covers log files referenced by digest files, so a gap in digest coverage is a gap in your proof. And the files must stay where CloudTrail put them, which means copying logs into a tidier prefix breaks the built-in verification and hands you the job of writing your own checker.

For evidence that is not CloudTrail, the equivalent is doing the work yourself: hash the artifact at the point of generation, record the hash somewhere separate from the artifact, and write both. A manifest per collection run, checksummed and locked alongside the files, is unglamorous and holds up.

One constraint that catches people mid-build: a bucket with Object Lock enabled cannot be used as the destination for S3 server access logs. If your design had one bucket receiving both the evidence and its own access logs, it needs splitting.

Failure five: the bill you cannot switch off

Compliance mode plus a long retention period plus archival storage classes is where cost surprises live, because every lever you would normally pull to reduce spend has been deliberately disabled.

The mechanics that drive it, none of which are secret but all of which get discovered late:

• Minimum storage durations. S3 Glacier Flexible Retrieval carries a 90 day minimum and S3 Glacier Deep Archive carries 180 days. Transition earlier than that and you are billed for the remainder of the minimum anyway.
• Per-object overhead in Glacier classes. AWS documents 40 KB of metadata overhead per object for Glacier Flexible Retrieval and Deep Archive, of which 8 KB is billed at S3 Standard rates and 32 KB at the destination rate. For a repository full of 2 KB JSON approvals, the overhead is the bill.
• Billing starts when the rule is satisfied. Lifecycle transitions to Glacier classes happen asynchronously, but you are charged at the destination rate, and the minimum duration clock starts, from the date the rule matched rather than the date the bytes physically moved.
• You cannot delete your way out. Under compliance mode, oversized or mistakenly retained objects stay until their retain-until date passes, whatever the finance conversation says.

The design response is to aggregate before you lock. Batch small artifacts into per-day or per-collection archives, checksum the archive, and lock the archive rather than thousands of tiny files. It costs you a little retrieval convenience and saves you a per-object overhead multiplier you cannot renegotiate later.

Also pick the retrieval tier against the real deadline. Deep Archive is the cheapest place to keep evidence and one of the slowest to get it back. If a regulator or a legal team may need files at short notice, that trade is a bad one regardless of the storage line item.

Putting the repository together

With the failure families in view, the build order is fairly short.

1. Separate the account. Evidence lives in its own AWS account, not a prefix in the production log bucket. The blast radius of a compromised production admin should not include the record of what they did.
2. Write the service control policies first. At the organisation level, deny s3:BypassGovernanceRetention, deny s3:PutBucketPolicy and s3:DeleteBucketPolicy on the evidence bucket, and deny disabling the trail. SCPs apply to the account root too, which is the point.
3. Create the bucket with Object Lock and a default governance retention. Block public access, enforce TLS with an aws:SecureTransport condition, and encrypt with a customer managed KMS key whose policy is written for this bucket alone.
4. Enforce the retention floor in the bucket policy using the remaining-retention-days condition, so a misconfigured collector fails rather than writes something unprotected.
5. Replicate to a second account or region. Object Lock works with S3 Replication, and the destination bucket must also have Object Lock enabled. This is your answer to region-level loss and to an account-level mistake.
6. Add Vault Lock for backup-shaped evidence. Snapshots and database backups belong in a locked backup vault rather than being exported to S3 by hand.
7. Alarm on the write path. A day with no new evidence objects is the failure that never pages anyone. Alert on absence, not just on errors.

Vault Lock deserves its own note because its compliance mode has a grace period that Object Lock does not. You choose a cooling-off window, which AWS requires to be at least three days, during which the lock can still be removed. After that the vault and its lock are immutable and cannot be changed or deleted by anyone, including AWS.

# Compliance mode: the presence of --changeable-for-days is what makes it
# compliance rather than governance. Minimum value is 3 (72 hours).
aws backup put-backup-vault-lock-configuration 
  --backup-vault-name evidence-vault 
  --min-retention-days 365 
  --max-retention-days 2555 
  --changeable-for-days 3

Use that window. Run a backup job through the vault, confirm the retention arithmetic against what the policy document actually requires, and only then let the clock run out.

One more design question worth asking out loud: does every copy need to be inside AWS? A second, offline-ish copy on independent infrastructure answers a different threat than cross-region replication does, because it survives an account-level compromise. Providers like InterServer, Contabo and Hetzner sell cheap storage that can hold an encrypted archive, and several S3-compatible services implement Object Lock semantics of their own. Confirm the provider actually supports Object Lock rather than assuming an S3-compatible API implies it, because that varies.

Troubleshooting

AccessDenied when deleting a version you are allowed to delete

Usually governance retention plus a missing bypass. The IAM permission s3:BypassGovernanceRetention and the explicit bypass on the request are both required. If the object is in compliance mode, there is no combination of permissions that will work, and the error is telling you the truth.

# Only valid for governance mode, and only with the matching IAM permission.
aws s3api delete-object 
  --bucket my-evidence-archive 
  --key path/to/object 
  --version-id "SOME_VERSION_ID" 
  --bypass-governance-retention

Replication fails on an Object Lock bucket

The destination needs Object Lock enabled too. Replicated objects take the lock configuration of the source, so a destination without Object Lock cannot accept them. Check the destination bucket first, then the replication role’s permissions.

Lifecycle rule appears to do nothing

Two likely causes. The versions it targets are still under retention, so expiration cannot remove them. Or the rule targets current versions on a versioned bucket, in which case it is adding delete markers and the data is still there as noncurrent versions, still being billed.

validate-logs reports invalid or missing files

Confirm nothing moved the objects. Validation requires the log and digest files to be in the location CloudTrail delivered them to, and the command runs per region. A copy job that reorganised the prefix layout is the usual culprit.

Object Lock cannot be enabled on the bucket

Versioning has to be enabled first, and Object Lock cannot be turned off later. If the bucket is currently a server access log destination, that has to move before Object Lock will work for you at all.

Common mistakes

• Enabling Object Lock on an existing bucket and assuming the objects already in it are now protected. They are not, until retention is applied to each version.
• Choosing compliance mode on day one to look thorough, then discovering the retention period was wrong.
• Treating Object Lock as an access control. It is a floor under your permissions, not a replacement for them.
• Leaving the bypass permission attached to a general administrator role because it was needed once during testing.
• Locking millions of tiny objects into Glacier classes and paying per-object overhead on all of them.
• Storing evidence in the same account as the systems it describes, which makes the evidence only as trustworthy as that account’s admins.
• Never testing retrieval, so the first restore attempt happens under audit pressure with an unfamiliar Glacier restore workflow.

Best practices for an audit evidence repository on AWS

• Governance mode by default, compliance mode only where an external requirement names the period. Write down which rule drove the choice, in the same repository.
• Enforce the retention floor in the bucket policy so the write path fails loudly instead of writing unprotected objects.
• Use legal hold, not extended retention, for investigations. Legal holds have no expiry and are removed explicitly, which is the right shape for something that ends on an unknown date.
• Aggregate small artifacts into archives with a checksummed manifest before locking them.
• Replicate to a second account with Object Lock enabled, and check replication metrics rather than assuming.
• Rehearse retrieval quarterly, including the Glacier restore step, and keep the output as evidence of the rehearsal.
• Monitor for absence of writes. Tools like Amazon CloudWatch, Grafana or Datadog are all fine here. The alert that matters is “no evidence arrived today”.

Frequently asked questions

Can I enable S3 Object Lock on a bucket that already exists?

Yes. S3 supports enabling Object Lock on existing buckets, and versioning must be enabled. The important caveat is that enabling it does not retroactively protect the objects already stored. You apply retention to those separately, per object or with S3 Batch Operations.

What is the difference between governance mode and compliance mode?

Governance mode can be overridden by a principal holding s3:BypassGovernanceRetention who sends the bypass header. Compliance mode cannot be overridden by anyone, including the root user, and the retention period cannot be shortened or the mode downgraded.

Does S3 Object Lock stop someone deleting the file?

It stops the protected version being destroyed. It does not stop a delete marker being placed on top, which hides the object from ordinary listings while the version remains. Keep delete permissions tight and list versions when you audit.

Do I need Object Lock if I already have versioning and MFA delete?

They solve different problems. Versioning preserves history but a sufficiently privileged caller can still remove versions. Object Lock removes that possibility for the duration of the retention period, which is the property an auditor is asking about.

How do I prove the evidence has not been modified?

For CloudTrail, enable log file integrity validation and keep the signed digest files with the logs, then run aws cloudtrail validate-logs for the period in question. For other artifacts, hash at generation time, store the manifest separately, and lock both.

Can a lifecycle rule delete objects that are still locked?

No. Retention wins over lifecycle expiration. Plan the two together, because a cleanup rule that quietly does nothing for years is a cost problem you will not see until you look at storage growth.

Is Vault Lock compliance mode reversible?

Only during the cooling-off window you set at creation, which must be at least three days. After the lock date, the vault and its lock cannot be changed or deleted by anyone, including AWS.

The one thing worth remembering

An audit evidence repository on AWS fails in a specific, quiet way: the bucket says Object Lock is enabled, and the objects inside carry no retention. Everything else in this post is downstream of that gap. Check protection at the object version, not at the bucket, and enforce the floor in the write path so the system tells you when it is wrong.

Then pick the mode like the one-way door it is. Governance mode with a locked-down bypass gets you almost all of the protection and keeps a documented way back. Compliance mode is worth its permanence when a real external rule demands it, and expensive theatre when it does not.

Need help building or reviewing one of these?

Immutable retention is easy to enable and easy to get subtly wrong, and the mistakes are the kind you find out about at the worst moment. This is work I take on directly:

• Designing an evidence account with Object Lock, KMS, service control policies and a locked-down write path
• Auditing an existing bucket to find object versions that carry no retention despite Object Lock being enabled
• Backfilling retention across existing objects with S3 Batch Operations without locking in the wrong period
• Modelling the long-run cost of a retention decision before compliance mode makes it permanent
• Setting up cross-account replication, AWS Backup Vault Lock and CloudTrail integrity validation as one coherent design
• Writing the retrieval runbook and rehearsing it, so the first restore is not during an audit

If you want a second opinion on what you already have, send me the bucket policy, the Object Lock configuration and the output of a head-object call on one old evidence file. That is usually enough to tell you where the gap is.

The post Building an Audit Evidence Repository on AWS: Immutable Retention Without Regret appeared first on John Nessime.

So you open the audit table. And you find it records who requested a link to the document. Not who opened it. The actual downloads never touched your application at all, because you handed out a signed storage URL and the browser went straight to the bucket. Your log is a record of intentions.

That gap is typical of how property SaaS document storage goes wrong. The failures are rarely dramatic. Nobody dumps a bucket publicly. The guarantees you thought you had just turn out to be enforced in application code that ran once, long before the file was actually read. What follows is five failure families worth designing against when a platform stores tenant ID scans, signed leases, deposit certificates, right-to-rent evidence and referencing packs.

What’s actually in the pile

Before architecture, be honest about the contents. A property platform’s document store is at least four risk classes wearing the same file extension:

• Identity evidence. Passport and driving licence scans, visa documents, sometimes a selfie held next to the document. Highest blast radius, lowest genuine need for long retention.
• Contracts. Tenancy agreements, addenda, guarantor deeds, signed inventories. Legally driven retention, plus an integrity requirement: proving the file hasn’t changed matters more than hiding it.
• Financial and referencing material. Bank statements, payslips, credit reference reports. Sensitive, third-party sourced, and often covered by contractual restrictions from the referencing provider.
• Operational clutter. Inspection photos, safety certificates, maintenance invoices. Low sensitivity, high volume, and the thing that dominates your storage bill.

These want different retention clocks, different access rules and arguably different buckets. Treating them as one “documents” table is where most of the later pain originates.

Failure one: the access check and the access happen at different times

Presigned URLs are the right pattern. They keep the bucket private, take the transfer off your servers, and mean you never hand storage credentials to a browser. I reach for them first.

The problem is what a presigned URL is. It’s a request you already authorised, signed, and then gave away. Anyone holding it can replay it until it expires. Your permission logic ran once and never runs again. Which means all of these keep working after the fact:

• A letting agent who left the company yesterday and whose account you disabled this morning.
• A link forwarded into a WhatsApp group, pasted into a support ticket, or sitting in browser history on a shared office machine.
• A document the tenant asked you to delete, if the object is still there behind a delete marker.

Make the URL die when the session does

Amazon’s own guidance is clearer on this than most people realise. A presigned URL created with temporary credentials expires when those credentials expire, even if you asked for a longer expiry. It also stops working if the signing credential is revoked, deleted or deactivated.

That’s a lever, not a footnote. Sign with a long-lived IAM user key and the seven day maximum the SDK allows is a real seven days. Sign inside a short-lived assumed-role session and the URL cannot outlive that session, whatever number you passed in. So: never sign document URLs with static credentials. Assume a role per request, tag the session with the tenant, sign inside it.

import boto3

sts = boto3.client("sts")

# The tag key here must match the principal tag key used in the role's policy.
session = sts.assume_role(
    RoleArn="arn:aws:iam::111122223333:role/TenantDocumentAccess",
    RoleSessionName="doc-download",
    Tags=[{"Key": "TenantID", "Value": tenant_id}],
    DurationSeconds=900,
)["Credentials"]

s3 = boto3.client(
    "s3",
    aws_access_key_id=session["AccessKeyId"],
    aws_secret_access_key=session["SecretAccessKey"],
    aws_session_token=session["SessionToken"],
)

url = s3.generate_presigned_url(
    "get_object",
    Params={
        "Bucket": "prop-docs",
        "Key": f"tenants/{tenant_id}/identity/{doc_id}.pdf",
        "ResponseContentDisposition": 'attachment; filename="id-document.pdf"',
        "ResponseContentType": "application/octet-stream",
    },
    ExpiresIn=120,
)

Two things are doing work. DurationSeconds caps the real lifetime of the link regardless of ExpiresIn. And ResponseContentDisposition overrides how the object is served on this request, which matters for the serving problem further down.

The trade-off is real: an STS call per download adds latency, adds a dependency, and STS has request limits you can hit at volume. AWS’s prescriptive guidance says as much. For identity documents I’d pay that cost. For inspection photos I wouldn’t.

Log where the read actually happens

Your application log records issuance. To record retrieval you need logging at the storage layer: CloudTrail data events for object-level operations, or S3 server access logging. Data events are billed per event, so scope them to the identity and contract prefixes rather than the bucket holding thousands of inspection photos.

Failure two: isolation that lives in your ORM instead of your IAM policy

Ask most teams how tenant isolation works and you get a description of a WHERE clause. The key is built as tenants/{tenant_id}/... and the tenant ID comes from the session. Fine until one code path takes it from a request parameter, or a background job iterates without scoping, or someone writes an admin endpoint in a hurry.

Move the boundary below your code. With attribute-based access control the tenant becomes a session tag and the IAM policy interpolates it into the resource ARN. One role serves every tenant, and the policy count doesn’t grow as you onboard.

{
  "Version": "2012-10-17",
  "Statement": [
    {
      "Sid": "ReadWriteOwnTenantPrefix",
      "Effect": "Allow",
      "Action": ["s3:GetObject", "s3:PutObject"],
      "Resource": "arn:aws:s3:::prop-docs/tenants/${aws:PrincipalTag/TenantID}/*"
    },
    {
      "Sid": "ListOnlyOwnTenantPrefix",
      "Effect": "Allow",
      "Action": "s3:ListBucket",
      "Resource": "arn:aws:s3:::prop-docs",
      "Condition": {
        "StringLike": {
          "s3:prefix": "tenants/${aws:PrincipalTag/TenantID}/*"
        }
      }
    }
  ]
}

Two statements because S3 splits the problem. The first governs the object, where the tenant prefix is part of the resource ARN. The second governs listing, a bucket-level action, so the prefix has to be constrained through a condition instead. Skip it and a tenant can enumerate every key in the bucket even though they can’t read any of them, and key names in this domain leak plenty on their own.

The failure mode worth internalising: if a code path forgets the session tag, ${aws:PrincipalTag/TenantID} resolves to nothing and the statement doesn’t match. That’s a deny, which is what you want. But it only holds if the role has no broader fallback statement. One well-meaning s3:GetObject on the whole bucket, added to unblock a migration script, quietly turns the scheme into decoration.

When to use a bucket per tenant instead

A bucket or an account per tenant is a genuinely harder boundary and I wouldn’t dismiss it. With a few dozen large agency customers it’s defensible and makes offboarding trivially provable. It stops being defensible once you onboard self-serve landlords, because bucket and account counts run into service quotas and the operational surface grows with every signup. Pick on tenant count, not on which sounds more secure. And note that ABAC is only as trustworthy as the tenant claim: if the caller can influence the value reaching the tagging call, you’ve built an elegant no-op.

Failure three: the upload and serve path

Uploads here come from people you have no relationship with yet. Prospective tenants, guarantors, contractors. That’s an untrusted channel by definition, and it produces two separate problems.

Constrain the upload itself

A presigned PUT URL lets the holder write whatever they like to that key, at whatever size. Presigned POST is the better tool for public-facing uploads: the signature covers a policy document, and the policy carries conditions the browser cannot alter.

post = s3.generate_presigned_post(
    Bucket="prop-docs",
    Key=f"tenants/{tenant_id}/inbox/{upload_id}",
    Fields={"Content-Type": "application/pdf"},
    Conditions=[
        {"Content-Type": "application/pdf"},
        ["content-length-range", 1, 15728640],
    ],
    ExpiresIn=600,
)

The content-length-range condition is the one people skip, and it’s the one that stops a stranger using your referencing portal as free storage for a 40 GB file. A declared Content-Type is a claim, not a fact, so land uploads in a quarantine prefix, verify the actual bytes, and only then move them to the tenant prefix.

Scan on that path too. ClamAV in a container is the zero-cost option and covers known malware; GuardDuty Malware Protection for S3 and hosted APIs such as Cloudmersive trade money for not maintaining it. What you’re protecting is mostly the letting agent who opens the attachment on a Windows machine, so this is a control for your customers rather than your servers.

Never serve tenant documents from your application origin

This is the one that turns a document store into an account takeover. SVG and HTML are formats browsers execute. If a file uploaded by a prospective tenant is served inline from the same origin as your app, any script inside it runs with your application’s cookies and session context. A long stream of real advisories follows exactly this shape, particularly in self-hosted deployments where the object store sits on the app’s own domain.

Three controls, and they stack rather than substitute:

1. Force download. Serve with Content-Disposition: attachment and X-Content-Type-Options: nosniff. Set these as object metadata at upload time and override them per request. The override protects links you mint; the stored metadata protects anything that bypasses your minting path.
2. Use a separate origin. Put user content on a distinct domain, not a subdomain of the app. GitHub’s separate apex for user content is the reference implementation. Same-origin policy then contains the blast radius if control one is missed somewhere.
3. Normalise where you can. Rendering an uploaded ID to a flattened image server side removes the executable content entirely. It costs CPU and fidelity. For identity documents, where you rarely need the original bytes back, it’s the right trade.

Failure four: deleting the document doesn’t delete the document

A tenant asks you to erase their passport scan. Your app sets a flag, the file disappears from the UI, and you reply confirming deletion. Then count the copies that still exist.

• The previous object versions, if versioning is on. A delete without a version ID just writes a delete marker.
• Cross-region replicas with their own versioning and lifecycle rules, plus any backup or snapshot taken before the deletion.
• Derivatives you generated and forgot: thumbnails, page previews, OCR text in a search index. Run a passport through Amazon Textract and the extracted fields are a copy of the sensitive data in a different shape.
• Copies that left the platform. A document attached to a CRM record in something like GoHighLevel, forwarded by email, or downloaded to a letting agent’s laptop.

The ICO’s position is that a valid erasure request extends to backups as well as live systems, and that where backup data cannot be immediately overwritten it must be put beyond use: isolated, unused for anything else, deleted when that backup cycles. Workable, but only if you know which backup sets contain documents and how long they cycle. If you can’t answer that, you can’t answer the request.

Crypto-shredding, and what it actually costs

The one technique that makes deletion provable across copies you can’t reach is a per-tenant KMS key. Encrypt that tenant’s objects under their own customer managed key; when they offboard, schedule the key for deletion. Every ciphertext copy anywhere, backups included, becomes undecryptable. You delete the data by deleting the ability to read it. The honest costs:

• KMS bills per key per month plus per request, so per-tenant keys are a real line item. Check current rates and quotas first: there’s an account limit on customer managed keys that a self-serve signup flow will eventually meet.
• Key deletion has a mandatory waiting period. Crypto-shredding is not instant, and your erasure response has to say so.
• It’s all-or-nothing per key. If a tenant asks you to erase one document rather than offboard, the key doesn’t help.

Object Lock fights erasure, on purpose

S3 Object Lock is tempting for signed tenancy agreements, because write-once storage is a strong integrity story. But compliance mode means nobody, root included, can delete the object until retention lapses. That is the feature. It is also a direct collision with an erasure request, and you cannot engineer your way out of it afterwards.

My line: Object Lock on executed contracts, where a statutory retention basis overrides erasure, and never on identity documents or referencing material. Different buckets, different rules, decided before anything is written. For per-document erasure elsewhere, lifecycle rules that expire noncurrent versions on the sensitive prefixes are worth setting up before you need them.

Failure five: storing what you never needed to store

The cheapest control on this list is not storing the file. The ICO is clear that UK GDPR sets no fixed retention periods and puts the burden on you to justify how long you keep personal data in identifiable form. That’s a design instruction, not a legal footnote.

For identity documents, ask what your platform needs once the check is done. Usually it’s the result, not the evidence: document type, issuing country, expiry date, a check reference, who performed it and when. If your customer’s regulator requires the image itself, that’s a retention rule with a stated basis, which is a different conversation from keeping it because deleting felt risky.

Practical version: give every document class a retention clock wired to a business event rather than upload date, and let lifecycle rules do the deleting. Tenancy end plus a defined period. Check completion plus a defined period. Not “whenever someone remembers.”

Troubleshooting the breakages you’ll actually hit

Everything broke after someone enabled S3 Bucket Keys

This one catches teams who did the sophisticated thing. If your IAM or KMS key policies use the object ARN as the encryption context to scope access, enabling an S3 Bucket Key changes that context to the bucket ARN and those policies stop matching. AWS documents it explicitly as something to fix before flipping the setting.

The quieter side effect: KMS CloudTrail events then log the bucket ARN instead of the object ARN, and there are far fewer of them because S3 caches the bucket-level key. If you were treating KMS CloudTrail volume as a proxy for document access, that signal degrades without anything appearing to break. Bucket Keys are still worth enabling for the request cost reduction. Move the conditions first, then re-check what your dashboards count.

The presigned URL expires far sooner than requested

Almost always the signing credential is a role session shorter than the expiry you asked for. This is documented behaviour, not a bug. Either raise the session duration within the role’s maximum, or accept the shorter window as the security property it is.

Listing works, reading returns Access Denied

Classic split between the bucket-level and object-level statements. Check both exist and reference the same tag key spelling. Session tag keys are case sensitive, and a tenantId in the code against a TenantID in the policy fails silently as a non-match.

Access denied only for encrypted objects

An SSE-KMS object needs two grants, not one. The S3 action on the object, and kms:Decrypt on the key it was encrypted under. In a per-tenant key setup that second grant is usually also tag-conditioned, so a missing or mismatched tag on the key itself produces a denial that looks like an S3 problem and isn’t.

Common mistakes

• Signing document URLs with a long-lived IAM user access key, which makes every link independently long-lived.
• Granting the tenant role a broad bucket-wide read statement alongside the tag-scoped one, usually to unblock a one-off script that then stayed.
• Serving user uploads from a subdomain of the application and assuming that counts as origin separation. It doesn’t for cookie scope.
• Enabling versioning for safety and never adding a noncurrent version expiry rule, so every deletion is reversible forever.
• Building deletion that handles the object but not the OCR output, the thumbnail, or the search index entry.
• Putting Object Lock on the bucket that also holds identity documents.

Design rules worth holding to

1. Separate buckets by risk class, not by feature. Identity, contracts, financial, operational. Different encryption, retention, logging and lock settings follow naturally from that split.
2. Enforce isolation in IAM, with application checks as defence in depth rather than the boundary itself.
3. Sign short, sign from a session. Minutes, not days, and always from assumed-role credentials so revocation actually revokes.
4. Deny unencrypted writes at the bucket policy, using the server-side encryption request headers as conditions, so a misconfigured client fails loudly instead of writing plaintext.
5. Give every document class an expiry clock tied to a business event, implemented in lifecycle rules rather than a cron job someone maintains.
6. Write the deletion runbook before launch, listing every place a copy lands. If you can’t enumerate them, that’s the finding.
7. Test cross-tenant access in CI. A negative test that asserts tenant A’s session cannot read tenant B’s key is worth more than any amount of policy review.

Frequently asked questions

How long should a presigned URL for a tenant ID document last?

Short enough that the user clicks it immediately. A couple of minutes covers a click-to-download flow. If the UI needs longer, re-mint on demand rather than extend. And remember the ceiling is set by the signing credential, so a short assumed-role session enforces the limit even if a later code change passes a bigger number.

Do I need AWS, or will Backblaze B2 or Cloudflare R2 do?

They all speak the S3 API and presigned URLs work on all of them, so the core patterns transfer. Wasabi, Backblaze B2, Cloudflare R2 and DigitalOcean Spaces are reasonable for the operational tier, and R2’s egress model is attractive if agents download a lot. They differ in the depth of the IAM story: session-tag ABAC and per-tenant KMS keys are AWS-specific. If isolation and crypto-shredding are hard requirements, keep the sensitive prefixes on S3 even when the bulk photos live somewhere cheaper.

Can I store scanned passports on a normal VPS instead?

You can, and plenty of platforms run the app tier on a VPS from Contabo or InterServer while keeping documents in object storage. What you lose on local disk is the deletion story and the access log. Proving an image is gone from a filesystem, its backups and its snapshots is far harder than scheduling a KMS key for deletion. If documents stay local, budget real effort for secure disposal, including on staff machines where tools like O&O SafeErase have a place.

What about e-signed tenancy agreements?

With a provider like DocuSign, the executed document and its audit trail live there as well as in your platform. That’s a second copy under a second retention regime, and it belongs in your deletion runbook and data map. It also strengthens your integrity story, which is a fair reason to skip Object Lock on contracts you retrieve from the provider.

Should the CDN cache tenant documents?

Not the sensitive classes. A CDN in front of private documents adds a cache that can serve content after your access decision changed, and header handling at the edge is a common source of the inline-rendering bug. CloudFront with origin access control and signed URLs is legitimate if you need the performance, but for identity documents I’d go straight to the bucket. For inspection photos, cache away.

How do I prove any of this to a prospect’s security team?

Artefacts, not assertions. The bucket policy, the ABAC policy, CI output showing cross-tenant denial, a sample of storage-layer access logs, and a retention schedule with a clock per document class. That set answers most questionnaires without a call.

The one thing worth remembering

Good property SaaS document storage is mostly about closing the gap between when you check access and when access happens. Every failure family above is a version of that gap: the presigned link that outlives the permission, the isolation enforced once in code and never at the storage layer, the deletion that updates a flag while the bytes sit behind a delete marker.

Close it by pushing the decision down: into IAM policies that evaluate on every request, into credentials short enough that revocation is real, into lifecycle rules that delete without anyone remembering to. Then the answer to “show us who read this tenant’s ID document” is a query, not a project.

Need a second pair of eyes on your document storage?

Most of what I do on property and lettings platforms is this exact work. Things I’d help with here:

• Reviewing bucket and IAM policies for cross-tenant read paths, including the ones added to unblock a migration and never removed.
• Moving tenant isolation from application code into session-tag ABAC, with a CI test that fails the build on cross-tenant access.
• Rebuilding the upload path with presigned POST conditions, quarantine, content verification and scanning before anything lands in a tenant prefix.
• Fixing the serving path so uploaded files can’t execute against your origin, including header handling through a CDN.
• Designing retention clocks and lifecycle rules per document class, plus a deletion runbook that names every copy including derivatives and third-party systems.
• Setting up storage-layer access logging scoped to the sensitive prefixes so you can actually answer an access request.

If it’s useful, send me your bucket policy and the IAM policy attached to your document role, with the account IDs redacted, and I’ll tell you what a determined tenant could reach.

The post Property SaaS Document Storage: The Five Failures That Show Up in an Audit appeared first on John Nessime.