Appendix A Compliance and Isolation Requirements.docx

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Attached to
Secure HPC Enclave for Regulated Research Data
Solicitation number
2138979
Issued by
New York

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This is an Appendix A compliance and isolation requirements document for the Empire AI Secure HPC Enclave for Regulated Research Data RFP issued by New York on September 10, 2026. The procurement seeks design, supply, installation, and integration of an isolated high-performance computing enclave to host multiple member institutions as independent tenants on shared physical infrastructure while maintaining compliance with HIPAA Security and Privacy Rules and NIST 800-234 standards. The enclave must support regulated and sensitive research data, including protected health information (PHI). Target readiness for the first regulated workload is January 4, 2027. The RFP deliberately leaves several architectural decisions open to bidder assessment, including storage sourcing and network perimeter approaches, with the expectation that bidders will recommend optimal solutions. Two equally weighted objectives govern the design: establishing a defensible HIPAA and NIST 800-234 compliant baseline with technical controls enforcing isolation, and maintaining high-performance computing capability without material security control-related performance degradation.

Compliance requirements are structured in three categories: CR-1 establishes the NIST 800-234 baseline with mapping to HIPAA administrative, physical, and technical safeguards; CR-2 mandates pass/fail isolation requirements including layered tenant isolation with minimum four independent enforcement layers, per-tenant key separation with external key management, default-deny east-west communication policies, independent control planes, no inherited adjacency to production clusters, validated perimeter enforcement, mediated data ingestion, and end-to-end audit capabilities; and CR-3 performance constraints require that controls minimize HPC performance degradation, with specific prohibitions against GPU-to-GPU traffic inspection, host-based RDMA firewalling, and wholesale kernel audit subsystems. Bidders must address each requirement in a compliance matrix, cite requirement identifiers, and flag any controls that would meaningfully degrade HPC performance while proposing compensating controls. The MWBE contracting goals are 6.00% for Minority Business Enterprises and 6.00% for Women Business Enterprises.

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RFP Secure HPC Enclave MAIN.docx DOCX document
Appendix BTechnical Requirements.docx DOCX document

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Appendix A — Compliance and Isolation Requirements Empire AI RFP: Secure HPC Enclave for Regulated Research Data · Issued: 09/10/2026 This appendix forms part of the above RFP and is incorporated into it by reference. The requirements stated here are binding on any resulting award. CR-2 is pass/fail: a proposal that cannot satisfy every mandatory isolation requirement will not be evaluated further. Bidders must address each requirement in the compliance matrix required under Proposal contents in the main RFP, and must cite requirement identifiers (CR-1, CR-2, CR-3) in their response.

CR-1 Compliance framework The enclave must establish a defensible baseline against NIST 800-234 and satisfy the HIPAA Security and Privacy Rules. Bidders must map the proposal to the administrative, physical, and technical safeguards. Addressable specifications that the bidder proposes not to implement must be identified with the reasoning and the compensating control.

CR-2 Mandatory isolation requirements These are pass/fail and apply regardless of which options are recommended under the design assessments in the main RFP. Bidders must state, for each, the specific technical mechanism that enforces it.

Requirement
What must be demonstrated
Layered tenant isolation
One tenant’s regulated data must be unreachable by any other tenant even if a single enforcement layer is misconfigured or compromised. The proposal must describe a minimum of four independent enforcement layers spanning scheduling, workload namespace, network, storage, and GPU allocation.
Per-tenant key separation
Each tenant’s data at rest must be encrypted under a distinct key held in external key management. Compromise of one tenant’s key must have no effect on any other tenant.
Default-deny east-west
Cross-tenant communication must be blocked by a default-deny policy applied at the platform or fabric level, not by per-workload opt-in rules.
Independent control plane
The enclave management plane, cluster manager, and administrative access path must be independent of the existing shared management domain and existing jump hosts.
No inherited adjacency
The enclave must have no routed adjacency to existing production clusters. The recommended option under Assessment B must satisfy this.
Validated enforcement
Perimeter enforcement must be validated by test at acceptance — a deny-by-default posture with an enumerated allow-list, demonstrated rather than asserted.
Mediated ingestion
Data movement from existing storage platforms into the enclave must traverse a filtered, one-directional path. Live network adjacency between storage systems is not acceptable.
End-to-end audit
Every regulated-data access path — platform API, storage, gateway, and privileged administrative session — must produce tamper-evident, continuous logs sufficient to answer "who accessed what, and when" for any dataset at any time.

CR-3 Performance requirements: controls must minimize HPC performance degradation Empire AI expects bidders to flag, rather than silently accept, any control that would meaningfully degrade HPC performance, and to propose a compensating control instead. The following are explicit constraints.

Constraint
Requirement
Data-plane inspection
GPU-to-GPU collective traffic and RDMA data movement must not traverse any inspection, proxying, or brokering point. Security controls apply at the boundary and the control plane, not in the job data path.
Host firewall on fabric
Host-based firewalling should not be applied to RDMA data-plane interfaces, where it adds overhead on traffic the kernel does not inspect or creates false assurance. State the compensating control — fabric-level partitioning, subnet isolation, or equivalent.
Encryption overhead
State the measured throughput and latency impact of encryption at rest, and of any in-transit encryption on the storage path, at sustained maximum load.
Audit and telemetry overhead
State the measured impact of audit logging and monitoring agents on high-IOPS storage access and on metadata operation rates. Kernel audit subsystems and per-syscall logging on compute nodes must be scoped, not applied wholesale.
Kernel hardening
Identify any hardening measure that conflicts with GPU driver, RDMA, or MPI operation, and propose a scoped alternative rather than an exception granted after deployment.
Session brokering
Any privileged-access or session-recording layer must sit on the interactive access path only. It must not mediate job launch, scheduler communication, or data movement.
Scheduler containment
Interactive sessions on compute nodes must be bound to an active job allocation and terminated on job completion, without imposing a fail-open condition or blocking legitimate access when the containment mechanism is unavailable.
Acceptance benchmarking
Performance must be measured on the delivered system both before and after security controls are applied. Bidders must propose the benchmark suite and acceptance thresholds.

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