It's imperative for public and private sector organizations to recognize the essential truth that governance of data entrusted to them cannot be relinquished, regardless of where the data is maintained.

John Moynihan, President, Minuteman Governance

August 7, 2017

2 Min Read

The recent reports that Verizon and Dow Jones left their respective Amazon Web Services platforms exposed to unauthorized access should serve as a wakeup call to all who are engaged in cloud computing. At the outset, it is important to note that the two incidents were inadvertently caused by individuals acting on behalf of these companies, and were not the result of an AWS vulnerability.

The technology community continues to perpetuate the falsehood that migration to the cloud solves both capacity and security issues. This is a dangerously misguided perspective that subjects enterprises that subscribe to it to significant risk. Unfortunately, many executives are led to believe that by transferring core processes to a cloud environment, the responsibility for securing the data residing therein is also transferred to the hosting third party. This is simply untrue. 

It's imperative for public and private sector organizations to recognize that governance of the data entrusted to them cannot be abdicated, regardless of where the data is maintained. While outsourcing may assist with scale and resource limitations, management must exercise ongoing and adequate oversight of information maintained within cloud environments.

Concurrent with every cloud deployment, specific controls should be implemented. The following is a list of three necessary controls, and a brief description.

1. Employee Education
Prior to providing anyone with access to an organization's cloud platform, each individual should receive comprehensive, formal direction on acceptable use. This requirement should apply to all employees, contractors and vendors. Without clearly written guidance, and corresponding awareness training, individuals will behave arbitrarily when accessing cloud applications. An informed employee is management's responsibility.

2. Vendor Oversight 
As with all service providers, ongoing oversight of cloud vendors should be a core element of an organization's security and compliance strategy. Through a combination of on-site visits, third party risk assessments, compliance attestations and contractual provisions, management must continually verify that the hosted environment is protected from internal and external threats. 

3. System Monitoring
With increased frequency, organizations are electing to maintain customer information and intellectual property in the cloud. To protect against unauthorized access of this information, and to comply with related compliance mandates, it is essential that all accesses be continuously logged, monitored and analyzed.  Cloud database vendors have recently implemented robust auditing and alerting tools within their hosted applications. The functionality to perform real time monitoring of cloud data is now available; organizations must therefore devote the necessary resources to do so.

Unauthorized access of customer and proprietary information has emerged into a crisis that is currently undermining all industries. Any organization that is be perceived to be unable to protect the sensitive data entrusted to them, regardless of where it is maintained, undoubtedly will experience the consequences that accompany an apprehensive public.

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About the Author(s)

John Moynihan

President, Minuteman Governance

John Moynihan, CGEIT, CRISC, is President of Minuteman Governance, a Massachusetts cybersecurity consultancy that provides services to public and private sector clients throughout the United States. Prior to founding this firm, he was CISO at the Massachusetts Department of Revenue from 1997-2008. He has published several articles, presents at major industry events and regularly provides media commentary on evolving cyber security issues.

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