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Cartoon: Cloud Conundrum
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Marilyn Cohodas
Marilyn Cohodas,
 User Rank: Strategist
7/8/2014 | 10:52:07 AM
SOC v CSP: Chicken or the egg?
The chicken or the egg metaphor is a great analogy for the cloud security debate. So I ask you all, when it comes to cloud security, who's bears the greatest resposible? the CSP or the SOC team? 
aws0513
aws0513,
 User Rank: Ninja
7/8/2014 | 12:45:09 PM
Re: SOC v CSP: Chicken or the egg?
In my experiences, the following rule always applies:

"The data owner is responsible for protecting the data they manage and use for their business operations."

This means that no matter where the data is stored, the data owner must ensure that necessary security controls are in place to help protect the data.  If the choice is to use cloud services of any kind, they data owner must validate (accredit) and audit the cloud services that will be utilized... on a consistent and continuous basis.

The hard part is that cloud services often tout their product as a secure environment without providing security control implementation specifics.  I have yet to see any cloud service provide a security control "mapping" to NIST (or other framework) controls in detail that was sufficient.  They will brush some sales lines on a few common security controls, but I am still waiting on that "comprehensive" security control implementation documentation.

I am currently working with my employer (government entity) to establish a common security requirement "checklist" approach to cloud services assessment.  We plan to tell data owners within the organization that if a cloud service is going to be used for any solution our organization establishes, the service will be reviewed as if it were an extension of the organization and subject to the same auditing requirements.  In general, for us this means that NIST controls will need to be mapped to the cloud service equivalent where applicable.  The cloud service vendor(s) will need to provide an acceptable control implementation/solution for each required control that our risk assessment team (management) has deemed necessary to protect the data.  If there are any issues with how the cloud service supports or provides a specific controls, along with how they will be audited and monitored, they will likely not get any of our business unless our management can establish compensating controls or assume ownership of the control requirement.  Risk acceptance is a reality as well, but it is our hope that we can reduce the risk on all points possible before any risk acceptance takes place.

I know that what we are trying to do will very likely make things difficult for cloud service vendors to get our business, but the glaring fact is if there is an unauthorized breach of our data environments, all the finger pointing in the world would not take my employers name out of the newspapers and very likely will not protect my employer from legal filings unless the risk assumption is fully documented in the contract with the vendor.  Even if the contract is specificially established, my employer would still get a black eye in the reputation arena.

So...  big foot stomping hint to you cloud vendors out there.... Make it easier for organizations that handle sensitive or regulatory affected data to know EXACTLY how security controls are implemented in your environments...  from the physical to the virtual.  A to Z...  top to bottom.  And be prepared to provide auditing capabilities that are verifiable via 3rd party were necessary. 
I suggest NIST SP800-53 as a starting point.  Be ready to talk to other risk management frameworks (ISO anyone?). 
And NO...  a fancy letter from an external auditing firm does not come close to acceptable.  The devil is in the details...  so break out all the details as much as possible for your potential customers.  You want extra points?  Provide verifiable case documentation of security events that your environment identified and/or thwarted.  Full disclosure is a good thing!!
Marilyn Cohodas
Marilyn Cohodas,
 User Rank: Strategist
7/8/2014 | 4:59:55 PM
Re: SOC v CSP: Chicken or the egg?
Thanks for your thoughtful and detailed reply @aws0513. I hope you will tell us how your checklist approach works to cloud services assessment works. When do you thnk you will see some results?
Kelly Jackson Higgins
Kelly Jackson Higgins,
 User Rank: Strategist
7/10/2014 | 4:29:24 PM
Re: SOC v CSP: Chicken or the egg?
This actually applies to a lot of things in security, so it's a wise joke well-taken. 
freespiritny25
freespiritny25,
 User Rank: Apprentice
8/1/2014 | 4:24:57 PM
Re: Cartoon: Cloud Conundrum
LOL so true- pointing the blame!


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