Air-Gap Readiness Checklist for State Data Centres

The SDC director in a large state had been told to air-gap the new beneficiary assistant before the next assembly session. The hall already had a VLAN named AG. Someone had removed the default route on a whiteboard and not on the router. NTP still pointed at the internet. The identity broker still sat in a connected forest. A vendor engineer still had a standing AnyConnect profile from commissioning.

They were not ready. They were labelled. Readiness is a set of habits that still work when the WAN cable is on the table in front of the auditor. This checklist is the set we walk before anyone is allowed to call an SDC estate air-gapped.

Print it. Mark each row ready, gap, or not applicable with a reason. Not applicable without a reason is a gap. This is a field list, not a notified standard.

Network and name resolution

• No default route from the air-gapped VLAN to any untrusted network, including the SDC management internet breakout.
• No dual-homed jump hosts. If a transfer host exists, it has a documented one-way procedure and is not a general laptop.
• DNS is internal only. No recursive forwarding to the public internet. No DoH from nodes.
• NTP is internal. Nodes do not chase public pool servers.
• Certificate revocation and OCSP do not require a live public path, or you have an offline plan.
• IPv6 is as tightly controlled as IPv4. Forgotten IPv6 is a path.
• A packet capture during soak shows no unanswered or answered attempts to unlisted destinations.

Identity, keys and people

• Identity for the estate is local or a replica that does not need a live cloud IdP to authenticate.
• No vendor tenant accounts remain from commissioning.
• Break-glass accounts are printed or stored offline, tested, and monitored when used.
• Signing keys for artefacts live in a two-person procedure or an HSM, not on the build laptop.
• Staff who enter the hall do not bring personal hotspots as a joke. This is written and enforced.
• Support is scheduled, escorted, and recorded. No standing tunnel.

Artefacts and updates

• An internal registry holds images and models. Nodes cannot pull from a public registry even if someone adds a route.
• A signed promotion path exists and has been used at least once in anger.
• Licences are offline files. No seat-check daemon.
• Time from known-bad artefact to rollback is measured, not hoped.
• Tokenizer, safety classifier and prompt packs travel in the same signed bundle discipline as the model.

Data, logs and SIEM

• Production personal data never lives on the connected build estate.
• Logs stay inside the estate for at least the CERT-In 180-day window for specified types, or you have a documented inward-only copy to an Indian SIEM that does not open a return path.
• Crash dumps do not upload. They sit in a folder an officer reviews.
• A write-set list exists so erasure and exit are possible.
• Backups are inside the estate or follow the same media discipline inward and never outward with content.

Five fails. Any one of them stops the air-gap claim.

Automatic fail	Why	What to do instead this quarter
Default route or dual-homed engineer laptop	You do not have a gap	Fix routing; confiscate the laptop procedure
Standing vendor tunnel	A foreign or vendor admin plane exists	Revoke; move to escorted sessions
Live licence or telemetry daemon	Content or metadata leaves on a clock	Offline licence; local metrics
No local log retention	You will fail the first incident clock	Stand up local SIEM or a retained log store first
No promotion path	Someone will cheat within a month	Build the signed path before go-live

Physical and organisational rows the network team forgets

An SDC air-gap is also a room. Visitor logs, cage badges, cameras that actually retain, and a rule about personal radios belong on the same list as DNS. A perfect VLAN with a contractor who photographs a screen into a personal phone is not an air-gap. Write the phone rule and practise it once, awkwardly.

Staffing is a readiness row. If the only person who can promote an artefact is on leave, the next emergency will be a dual-homed laptop. Name a deputy. Run the dummy promotion with the deputy in the room. If you cannot staff a deputy, you are not ready, and an on-prem fail-closed estate is the adult posture until you are.

Document the exception process. There will be an assembly question and a demand to add a feed. The process should make adding a live path harder than adding an inward bundle. If exceptions are a WhatsApp to the SDC head, the checklist was theatre.

Objections

This is more than the last firewall audit. Yes. An agent creates new stores and new daemons. A firewall audit that never looked at a licence ping will bless a leak.

We will never pass, so we will stay on a public API. Then stay on a public API for public data, and do not call it air-gapped. The checklist is a gate, not a moral judgement.

The SI says they have done this in another state. Ask for that state’s soak capture, not their slide. If they cannot share it, run yours.

A six-week readiness sprint

1. Week 1: mark every row. Do not implement yet.
2. Week 2: kill automatic fails.
3. Week 3: identity and offline licence.
4. Week 4: signed promotion of a dummy artefact.
5. Week 5: local logs and a soak capture.
6. Week 6: tabletop a vendor visit and a failed promotion. Sign the list only if both work.

What goes in the file

The marked checklist with names and dates, the soak capture summary, the promotion record, the identity diagram, and the four signatures. If the assembly note must go out before those exist, the note should say disconnected VLAN in progress, not air-gapped.

Use this list on a Prcept deployment the same day you use it on anyone else. If we ask you to skip a fail row to hit a date, refuse.

How to prove this on a rack, not on a slide

“Air-Gap Readiness Checklist for State Data Centres” only matters if a CISO can fail it. A P1 CIO/CTO should be able to point at a cable, a registry, a licence file, a PDU reading or a SIEM index and say: this is the control. If the only evidence is a brochure that mentions “air gap readiness checklist”, you do not have the control.

An SDC is ready to air-gap an agent when media, identity, updates and people already work disconnected. If those are hopes, you are building a museum or a leak. Air-gap and on-prem programmes die in the second month, when the first update, the first crash, or the first GPU lead-time slip arrives. Budget the boring path — media, offline licence, local registry, local traces — in the same note as the model name.

On-prem is not air-gapped. An India region is not either. Write the forbidden path (outbound HTTPS, licence phone-home, crash reporter, hidden model API) as a numbered list and test it with the internet off. Whatever still dies was a dependency you did not draw.

1. Draw the data path for one user-visible answer under “air gap readiness checklist”.
2. Disable outbound internet on staging and run the demo script.
3. List every remaining hop: update, licence, registry, NTP, DNS, SIEM.
4. Give each hop an owner inside the department, not only the SI.
5. Minute the restore or the media-transfer once before go-live.

Close this loop before the next CAB

Put “Air-Gap Readiness Checklist for State Data Centres” on the next change-advisory or bid-opening agenda as a single line item with an owner. If it cannot earn a line item, it will not earn a control. The owner should be a P1 CIO/CTO, not “the vendor.”

Revisit the item when the model, the GeM term, the region, or the SI changes. “air gap readiness checklist” is not a one-time workshop. It is a watch item. Date the last check. Unsigned watch items are souvenirs.

What the next noting must contain

“Air-Gap Readiness Checklist for State Data Centres” belongs in a file, not only in a search result. A P1 CIO/CTO should be able to point at one artefact that proves “air gap readiness checklist”: a packet capture, a processing schedule, a scored evaluation row, a dated notice, or a refusal rule. If the only evidence is a slide, you have a heading.

An SDC is ready to air-gap an agent when media, identity, updates and people already work disconnected. If those are hopes, you are building a museum or a leak. DPDP 2023 does not define sovereign AI and does not write a blanket localisation rule for every model hop. CERT-In’s 28 April 2022 directions still set specified incident clocks and 180-day log retention in India for in-scope events. The November 2025 AI governance text is guidance, not a statute. A Proprietary Article Certificate, when it is lawful, lives in GFR Rule 166 — not Rule 161.

Write three dated sentences under C2 Air-Gapped & On-Prem: what was decided, which designation owns it after the next posting order, and when it will be re-checked. Unsigned sentences are souvenirs. Dated sentences are controls.

• Name the designation that owns “air gap readiness checklist”, plus a deputy.
• Attach one artefact a stranger can open next year.
• Name the instrument you are actually using — Act, direction, GFR clause, GeM term, or guideline paragraph.
• Leave unsourced percentages, GMV slides and house forecasts out of the noting.
• Revisit when the model, the SI, the notice, the region or the posting changes.