Security, Privacy, and liability are top issues for #Cloud security and a popular topic at #RSAC (RSA SFO 2011 Conference) The first session today was moderated by Drue Reeves (Gartner), Michelle Dennedy (iDennedy), Tanya Forsheit (InfoLawGroup LLP), Archie Reed (HP), and Eran Feigenbaum (Google). A great discussion and lots of interesting points, and I would highlight ideas for managing security pragmatically for organizations. Below are my notes. Apologies for broken flows in logic, as I was trying to capture ideas put forward by panel I sometimes got lost in discussion.
Customers cannot rely only on provider to ensure data confidentiality and compliance, but are seeking assurances.
- Erin Feigenbaum (Google) – Customers want more transparency in general in the Cloud. Google is seeing smaller companies move into the cloud and we see that the service and type of cloud sought varies. Some clouds vary in ability to serve (Gmail in 2010 had uptime of 99.984%).
- Panel – Due diligence is necessary for both sides of the customer-cloud provider model. As such must and get a fair assessment of is happening today for both sides – to know what is happening today. Understanding what the customer is doing individually to create an ‘honest conversation’. Create a performance and services assessment of internal (corporate data center and software services) delivery and then determine what Cloud providers meet the current and future state target. Understanding what is essential to your business is critical to having reasonable expectations and having a proper cost/benefit return.
Legal, procurement, internal audit, business, and technology team members must get together to determine what is important and rate these items. This then can allow for a better data set identification and procurement of service providers.
- The end result is the business needs to determine what are their risk tolerance – such as what are they willing to accept. The universe of Cloud providers allows businesses to identify those that can meet and demonstrate adherence to the criteria that matters to the business.
Focusing on the dataset is what matters and consideration of the period of time. The dataset released to the cloud must meet your internal safeguard and risk tolerance criteria.
- Set Principles first – save money, keep agility, achieve availability
- Check application – is it generating revenue; does it create a loss of life scenario
- Keeping it in-house does not eliminate the risk vs. having it in the cloud.
Must focus at the strategic level …
Shadow IT, an example:
- Shadow IT is a problem and is still ongoing. A security survey with a bank in Canada where the marketing department did a survey in Salesforce.com. The problem was using the system the data of private Canadian citizens was crossing the U.S. border – which is against the law. This required a re-architecture effort to correct these activities.
There is a need for awareness and education on the implications of engaging cloud providers and how the flow of datasets impact the business’ legal obligations.
Consumer Technology in Business:
- Eran – 50% of people surveyed installed applications that are not allowed by their corporations and IT. The consumerization of technology is creating complex and intertwined technology ecosystems that must be considered by the business, risk management, legal, and security.
- It is your responsibility to do the due diligence on what the cloud providers are doing to provide assurance, and work with those that provide such information. The necessity is a balance between providing sufficient information security confidence and mapping out attack vectors for criminals.
Google Growth rate on Cloud:
- 3,000 new businesses are signing up on the Google cloud every day – impossible to respond uniquely to each one individually.
- It is up to the customer on knowing what are the legal aspects and appropriate uses of the business data. Understanding the transportation of sensitive data across borders is the business responsibility.
- It is up to the business to understand and act to protect the data of the business – pushing the information onto a Cloud provider is not a transfer of risk / ownership / responsibility.
If you had the chance today to rebuild your systems, would you do it the same way?
- Cloud does provide unique technologies beyond what you have already today. Cloud providers today have allowed them to rebuild their centers that consider today’s technology data architecture and leverage new tech.
Points of reality and impossibility
- If an organization does not have deep Identity Access Management (IAM) it is poor to try and bolt this on while transitioning to the cloud. Reasonable expectations must be had for both the consumer and of the cloud provider.
Liability and Allocation between Customers and Clouds
- Customers with data in their own data centers – they are basically self-insuring their operations. When moving to the Cloud these customers are now transferring this a third party. There is a financial aspect here. How can liability be balanced between customer and service provider?
- When Customer absorbs all liability they are hesitant to put X data on Cloud. If Cloud absorbs liability the cost will be to high.
Data in Space
- People are putting data on the cloud based on rash decisions without unique risk assessments on the data sets and providers.
Agreeing on Liability in the Cloud
- Organizations have been able to negotiate liability clauses with cloud providers. Ponemon institute figures are used in determining the limit of liability and are a good way of coming to a proper number that is even with industry figures. I.e., If Ponemon institute says cost of a breach per record is $224 and business has 20,000 employee records —> The limit of liability should equal the product of these two numbers, and this has proven to be a reasonable discussion with cloud providers. Indemnification is generally a non-discussion point.
- The world will move into specialized applications and services. These point organizations allows for specific legal and technology considerations that are appropriate for that niche. This is seen at the contract level, notification levels, prioritization on RTR, and across many areas.
Everything is negotiable for the right amount of money or love – Eran
- Cloud providers do not like to do one-offs. Cloud providers including Google will negotiate.
APPROACH to cleanse data with confidence
- Best tip is to encrypt data online… When de-provisioning systems and cleansing .. consider rewriting databases / applications / instances with clean values fully. Is this a practical method of ensuring the data is satisfied. How long should the data be in this state to ensure the data is pushed to other parallel instances?
- Are PCI, SIGS, and such standards for financial services appropriate for the Cloud provider? The responsibility is always the data owner. Internal controls must be migrated out to the cloud evenly as applied internally. It is the business’ risk and responsibility.
Recommendations of the Panel
Archie Reed: Everyone becomes a broker and recommend that IT teams to embrace this role. Need to understand how to source, and the chemistry and structure of the IT organization needs to shift. It will and must include working with the business to have such parties as legal, internal audit, and risk management.
Tanya Forsheit: I would love to see standards developed and the customers participate in a meaningful way. The provider side has thought through these seriously over the last few years. The business to business relationship within the Cloud – Customer relationship is weak. Be reasonable.
Eran: There is a paradigm shift from a server you can touch and be managed by an Admin that you hired vs. one that is acquired by a contract through a Cloud providers. Google has over 200 security professionals. Bank robbers go where the data is – the Cloud has the data.
How do you respond to a vulnerability, how do you respond to a hack … ARE THESE the new / right questions to seek of Cloud providers?
Michelle Dennedy: Leverage and plan for a loss with cloud providers.
Drue: There are risks you can identify to mitigate risks on the technology side, and there are financial tools (insurance, etc…) that must be deployed.
Question and Answer:
- Cloud providers have the opportunity to have a dashboard to track and demonstrate controls. These are hard we know.
- FedRamp and continuous auditing is a future component of the Cloud providers (that some) will adhere to and demonstrate.
An engaging panel and some interesting and useful points raised. Welcome any feedback and expansions on the ideas above,