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October 29, 2008
The Economist opines that the world is flirting with recession and IT may suffer; which in turn will hasten the move to “cloud computing”, which in a pithy distillation is described as “a trade-off between sovereignty and efficiency”.
Computing as a borderless utility? Whereas most privacy laws assume data resides in one place…the cloud makes data seem present everywhere and nowhere.
In a recent post Steve differentiated between security OF the cloud and security IN the cloud. This led us to an analysis of cloud computing as it is currently offered by Amazon AWS, Google Apps and Zoho.
From a risk perspective, security of content IN the cloud is essentially considered your problem by Amazon whereas Google and Zoho say “trust in me, just in me”. When pressed, Google says “we do not recommend Google Apps for content subject to compliance regulations” but is apparently working to assuage concerns about access control.
However moving your data to the cloud does not absolve you from responsibility on who accessed it for what purpose — the main concern of auditors everywhere.
At the present time, neither Google nor Zoho make any audit trail available to subscribers while at Amazon it’s your problem. We think widespread adoption by the business community (and what of the federal government?) will require significant transparency to provide visibility. This is also true for popular hosted applications like Intuit Quickbooks and Salesforce.
As Alex notes “…in order to gain that visibility, our insight into Cloud Risk Management must include significant provisions for understanding a joint ability to Prevent/Detect/Respond as well as provisions for managing the risk that one of the participants won’t provide that visibility or ability via SLA’s and penalties.”
Clear as mud.
October 24, 2008
In a recent post I talked a little about the security and compliance issues facing companies that adopt cloud-based SaaS for any mission-critical function. I referred to this as security OF the cloud to differentiate it from a cloud-based security offering or security IN the cloud. This is going to pose a major change in the security industry if it takes off.
Take a typical small business “SmallCo” as an example – They depend on a combination of Quickbooks and an accounting firm for their financial processes. For all practical purposes SmallCo outsources the entire accounting function. They use a hosting company to host Quickbooks for a monthly fee, and their external CPA, internal management and accounts staff access the application for data processing. Very easy to manage, no upfront investment, no servers to maintain, all the usual reasons why a SaaS model is so appealing.
One can easily argue the crown jewels of SmallCo’s entire business are resident in that hosted solution. SmallCo began to question whether this critical data was secure from being hacked or stolen. Would SmallCo be compliant if they were obligated to follow a compliance standard? Is it the role of the hosting provider to ensure security and compliance? To all of those questions there was and is no clear cut answer. SmallCo is provided access to the application and can have access to any audit capability that is supported in the Quickbook product (which is not a great deal), and there is no ability to collect that audit and usage data other than to manually run a report. At the time SmallCo began it did not seem to be important but as SmallCo grew so did their exposure.
Salesforce, another poster child for SaaS, is much the same. I read a while back they were going to put the ability to monitor changes in some of their database fields in their Winter 2008 release. But there appears to be nothing for user level auditing or even admin auditing (of your staff much less theirs). A trusted user can steal an entire customer list and not even have to be in the office to do it. The best DLP technology will not help you as it can be accessed and exported through any web browser on any machine. Having used Salesforce in previous companies I can personally attest, however, that it is a fine CRM system, cost-effective, powerful and well-designed. But you have to maintain a completely separate access control list, and you have no real ability to monitor what is accessed by whom for audit purposes. For a prospect with privacy concerns is it really a viable, secure solution?
Cloud based computing changes the entire paradigm of security. Perimeter defense is the first step of a defense in depth to protect service availability and corporate data, but what happens when there is no data resident to be defended? In fact, when there are a number of services in the cloud, is event management going to be viable? Will the rules be the same when you are correlating events from different services on the cloud?
So here is the challenge I believe — as more and more mission critical processes are moved to the cloud, SaaS suppliers are going to have to provide log data in a real-time, straight forward manner, probably for their admins as well as their customers’ personnel. In fact since there is only a browser and login and no firewall, network or operating system level security to breach, auditing would have to be very, very robust. With all these cloud services is it feasible that an auditor will accept 50 reports from 50 providers and pass the company under audit? Maybe, but someone – either the end-user or a MSSP has to be responsible for monitoring for security and compliance, and unless the application and data is under the control of end-users, they will be unable to do so
So If I were an application provider like Salesforce I would be thinking really hard about being a good citizen in a cloud based world. Like providing real-time audit records for at least user log-on and log-off, log-on failures and a complete audit record of all data extracts as a first step, as well as a method to push the events out in real-time. I would likely do that before I worried too much about auditing fields in the database.
October 14, 2008
Performing well during a security “Every crisis offers you extra desired power” William Moulton Marston Jasmine’s corollary: “Only if you perform well during that crisis.” Crises will happen no matter how many precautions we take. The need to blame someone is a human desire and it is easy to focus that on the crisis response team, because they are visible. Yet when teams perform well during the crisis they don’t merely avoid blame. They do garner the potential to become powerful advisors or outright leaders. It’s even better if you can also demonstrate that lessons learned from past crises are making the current environment more secure. After all, the Justice League members wouldn’t be heroes if no one knew about their actions. But what does it mean to perform well in a crisis?