Business agility and the demand for quick turnaround to infrastructure and application requirements to service organisational growth have fuelled the rise of cloud services. For organisations that have had their IT system requirements held back by traditional sourcing and project based delivery of information technology, cloud seems to be the answer. Cloud computing is defined by the US National Institute of Standards and Technology (NIST) as a:
“Model for enabling convenient, on-demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction.”
Cloud services include, but are not limited to Infrastructure in the form of (IaaS) Infrastructure as a Service, (SaaS) Software as a Service and (PaaS) Platform as a Service. There are major advantages for organisations big and small to use the cloud service offerings of IaaS, SaaS and PaaS which include, a reduction in the costs of IT operations, virtually unlimited storage, high levels of automation in infrastructure and application provisioning, flexibility in the choice of operating systems, databases and software applications the extent of which is not available through an organisations internal IT departments.
Sir Isaac Newton’s third law of motion states that for every action there is an equal and opposite reaction, advantages and disadvantages, similarly there are challenges with cloud services, more specifically related to an organisations data and their information assets. So following the third law of motion let’s talk about what these challenges might be, well they are in my view about the location of data, the challenge of shared data stores, ownership of data, access management and identity management practices to access the data stores, data record protection and compliance requirements that an organisation is required to adhere to in relation to its data assets.
In addition to the challenges related directly to data asset security there are indirect challenges that are related to the security policy and procedures that the cloud services provider (CSP) has in place in relation to its service offerings, their business due diligence, disaster recovery and business continuity planning. This can be taken a step further by identifying the preventative and detective security technologies in place including penetration testing of its core infrastructure and gateways.
Well, where there are problems there are solutions; let’s talk about some solutions or operating practices that organisations can put into place, in my view amongst many, auditing and reporting of cloud service providers is a primary operating practice that is required to be in place for all cloud services. There is no rocket science to undertaking an audit of a cloud services provider, I do not believe it is distinct from undertaking the audit of any outsourced service provider; the points of note are that as compared to a traditional outsourced services provider data and infrastructure holdings can no longer be physically segregated as such it becomes important that the security, privacy, and other organizational requirements for data security are paramount in selecting a cloud provider.
When choosing a cloud services provider organisations need to ensure it performs a risk assessment to identify and analyse the data security and information privacy controls that the cloud services provider has in place within its environment. The results of this risk assessment is required to be documented the gaps compared with the organisations control requirements. Where the gaps cannot have appropriate mitigation actions implemented by the cloud services provider, the organisation need to ensure that it has compensating procedure and process controls in place and needs to account for it within its decision and costing.
Considering that the organisation has outlined its data and information security requirements and created a statement of controls requirement, following which a risk assessment of the cloud services provider has been undertaken, it is now time to move on to the other audit areas that would evaluate the cloud provider’s ability to deliver required cloud services over the period of the contract in line with the data security and information protection levels specified. This includes the appropriate documentation of security and availability requirements within all contracts and their associated SLA’s signed and agreed by the cloud services provider and the organisation.
Further ensure that there is continuous assessment of a cloud service provider’s performance in line with their contract obligation through contract and services reporting, where there are gaps identified take immediate steps to rectify the issues. There is a lot that can be written but within the time available all I would say is have mechanisms in place that would clearly articulate and document the contractual agreements that are required to be observed upon termination of the contract including, purging of data, revocation of access rights and an understanding of the treatments applied to the backup and storage infrastructure that have been in use for the organisations computing and application requirements.
In summary to audit cloud services ensure an organisation has the following: • Definition of the organisations control requirements • Governance structure for reporting on services being used • Reporting against the organisations compliance requirements • Current state controls posture of the cloud services provider against organisational requirements • Independent verification of detective and preventative technology controls in place to ensure confidentiality, integrity and the availability of data and information assets cloud sourced • Incident management and response procedures in place in the event of a breach • Contracts that outline SLA’s and service provider obligations and organisational responsibilities • Clearly documented roles and responsibilities assisting service establishment and closure
For more information on there are two good papers that have been published by ISACA and NIST available at the following locations.
To further assist on this topic, I am putting together a list of top 25 controls that I think are required at a minimum when auditing cloud services, I call this CloudControl25. More on this in the next instalment.