CONTROL AND ASSURANCE ISSUES IN CLOUD ADOPTION EVERY CLOUD HAS A SILVER LINING INDRANIL MUKHERJEE 14th August 2012 ISACA SINGAPORE Cloud Computing - a genealogy perspective -Born for CLOUD Computing “Indra” in Indian culture is the god of the Clouds, which supply rain and thunder, and the weather is at his command. As controller of the megha (cloud), he is master of the clouds and is also known as Maghavan. “Nil” means Cloud or or champion, in Gaelic DISCLAIMER Any views or opinions presented in this Presentation are solely those of the author and do not necessarily represent those of his employers, past or present. Any images used in this presentation are either i)free of copyright or ii) ISACA Copyright materials for free distribution within the ISACA community. Control & Assurance Issues in Cloud Adoption I 4,000 business and IT managers across 7 countries -Cloud Survey by the Ponemon Institute - commissioned by Thales - July 2012 survey on perceptions and current practices relating to sensitive or confidential data in the cloud. - Who is considered responsible for protecting this valuable and often regulated class of data – the cloud service provider or cloud service consumer. ? - The findings are also significant in explaining where data encryption is applied inside and outside the cloud and, most importantly who manages the associated encryption keys. # Specifically addresses questions about whether organizations apply encryption themselves before data leaves the organization’s environment or whether encryption is expected to be a component of the cloud services they use. Control & Assurance Issues in Cloud Adoption II What proportion of organizations are already transferring sensitive data to the cloud? - About 50% currently transfer sensitive or confidential data to cloud - Another 33% are very likely to transfer sensitive or confidential data to the cloud within the next 2 years. Has the use of cloud computing for sensitive data increased or decreased overall security? 39% believe cloud adoption has decreased their companies’ security Who is responsible for data security in the cloud? 64% that currently transfer sensitive or confidential data to the cloud believe the cloud provider has primary responsibility for protecting it How much visibility do decision makers have regarding cloud security? Nearly two thirds of respondents say they do not know what cloud providers are actually to protect their sensitive confidential data Control & Assurance Issues in Cloud Adoption III Where is data encryption applied? Almost half the respondents who say their organization applies persistent encryption to data before it is transferred to the cloud provider and the other half say they rely on encryption that is applied within the cloud environment. Who manages the encryption keys when data is transferred to the cloud? -36% say their organization has primary responsibility for managing the keys. -22% say the cloud provider has primary responsibility for encryption key management. Even in cases where encryption is performed inside the enterprise, more than 50% hand over control of the keys to the cloud provider. # Encryption is used for protecting stored data as well as application-based encryption, which applies protection more selectively usually , potentially protecting individual data items CONTROLS, CLOUDS & CONTENT 1 • Cloud Computing-The Basics 2 • Practical Challenges in a Cloud Environment 3 • ISACA‘s Control Objectives for Cloud Computing Cloud Computing – the Basics WHAT IS CLOUD COMPUTNG Enormous Computing Resources, deployed among virtual data centres, dynamically allocated to specific users & tasks and Accessed as a service via a user-Interface, such as an Internet Browser. Cloud computing is nothing but saving your worked data in the clouds (i.e. on third party server) not a local hard disk. WHAT IS CLOUD COMPUTNG- the Lighter Side CLOUD CATEGORIES Software as a Service (SaaS) is software offered by a third party provider, available on demand, usually via Internet configurable remotely Examples: Salesforce CRM, Google Docs Platform as a Service (PaaS) allows customers to develop new applications using APIs deployed and Configurable remotely, includes Development tools,configuration Management & deployment platforms Examples : Microsoft Azure, Force, Google App Engine Infrastructure as a Service (IaaS) provides virtual machines and other abstracted hardware and operating systems which may be controlled through a service API. Examples: Amazon EC2/S3,Windows Live Skydrive, Rackspace Cloud Cloud Computing - Categories Infrastructure as a service Software as a service Platform as a service CLOUD TYPESthe Lighter Side CLOUD DEPLOYMENT MODELS ( ISACA Definition) Private cloud: – Operated solely for an organization – May be managed by the organization or a third party – May exist on or off premise • Community cloud: – Shared by several organizations – Supports a specific community that has a shared mission/ interest – May be managed by the organizations or a third party – May reside on or off premise • Public cloud: – Made available to the general public or a large industry group – Owned by an organization that sells cloud services • Hybrid cloud: – Composed of two or more clouds (private, community or public) that remain unique entities, but are bound together by standardized or proprietary technology that enables data and application portability (e.g., cloud bursting for load balancing between clouds) Source: ISACA : page 122 of IT Control Objectives for Cloud Computing, 2011 CLOUD QUIZ Which Cloud Framework is named after the Creator’s son’s toy elephant? HADOOP after Doug Cutting son’s Toy elephant Control & Assurance Issues - A case of How to lose your Cloud based data Last week, on 7th August 2012, A large Enterprise that is synonymous with smartphones has suspended its password resets following the hack of journalist Mat Honan's Cloud account - - Support staff not to process password change requests that come in via the phones. Customer service representative that it was halting all password resets by phone. The password freeze lasted at least 24 hours while the company performs system-wide "maintenance updates" Related Content - It is still possible to change passwords of this vendor ONLINE ! The Company says that its "internal policies were not followed completely" in the case that enabled hackers. (http://www.macworld.co.uk/macsoftware/news/?newsid=3374449) According to Honan, the hackers called the company , gave his name, address and the last four digits of his credit card (which they got from the Cloud Provider. The Company’s technical support reset his Cloud account & issued a temporary password. The Cloud Provider has also made security changes following the hack. Previously it was possible for a hacker to access an account with just the name, email address, and mailing address of a customer. The changes have closed this loophole. PRACTICAL CHALLENGES IN A CLOUD ENVIRONMENT Cloud Computing -an Auditor's View • Increased demand for Cloud Audits • Current third party controls may not be effective for Cloud ownership, insurance, project management & reporting /Incident Best Practice : 1)COBIT 5 – ISACA (http://isaca.org/COBIT/) 2) Cloud Audit Working Groups and Forums -Cloud Security Alliance (http://cloudsecurityalliance.org/) & ITIL Tip:Use ITAF Guidelines for preparing the Cloud Audit Report CLOUD RISKS- I Policy and Organizational Risks - Lock –in with a single Provider - Loss of Governance - Compliance Challenges e.g MAS Circular dated 14th July 2011 http://www.nortonrose.com/knowledge/publications/54960/monetary-authority-of-singapore-circular-regarding-its-outsourcing-and-cloud-computing - - - - Loss of Business Reputation due to co-tenant activities Cloud service termination or failure Cloud Provider acquisition Supply Chain Failure Legal Risks - Sub-poena and e-discovery - Risk from changes in jurisdiction - Data Protection risks - Licensing risks CLOUD RISKS-II Technical Risks - Resource exhaustion (under or over provisioning) - Isolation Failure – resulted the first documented Cloud security hack - Cloud provider malicious insider-abuse of high privilege roles - Management interface compromise (manipulation, availability of infrastructure) - Intercepting data in transit - Data leakage on up/download, intra-cloud - Insecure or ineffective deletion of data - Distributed Denial of Service (DDOS) - Economic Denial Of Service (EDOS) - Loss of Encryption keys - Undertaking Malicious probes or scans - Compromise service engine - Conflicts between customer hardening procedures and cloud environment - - - - - - - - - RISKS NOT CLOUD SPECIFIC (that affect it) Network breaks Network Management (ie: network congestion/ mis-connection/ non optimal use) Modifying network traffic Privilege escalation Social Engineering attacks (ie, impersonation) Loss or compromise of operational logs Loss or compromise of security logs (manipulation of forensic investigation) Backups lost/ stolen Unauthorised access to premises (including physical access to machines and other facilities) - Theft of computer equipment - Natural disasters Reference Source: ENISA - Cloud Computing- Benefits, Risks and Recommendations for Information Security,November 2009 ISACA CONTROL OBJECTIVES FOR CLOUD COMPUTING Copyright IT CONTROL OBJECTIVES for the Cloud -Introduction - Consists of 5 Sections - has 2 Appendixes - only 193 pages ! - Glossary has been updated over conventional ENISA / CSA definitions to include the concept of “Community Cloud” The 5 Sections are Preface -which includes the Cloud Computing Service Models (IaaS/ PaaS/ SaaS) and the Cloud Deployment Models. Key updates – include the Community Cloud model which could be Business-process Specific, Industry -specific Cloud Computing Fundamentals discusses cloud evolution, rovides technical building blocks, Cloud characteristics, cloud drivers and cloud computing Challenges IT CONTROL OBJECTIVES for Cloud Governance The third Sections covers Governance -which has the Cloud Computing IT Benefits/ Value Enablement Risk and how to leverage Risk IT / Val IT/ COBIT for the Cloud. Key updates – include the “Outcome of Good Governance” and the Mapping of ISACA’s COBIT , Risk IT and Val IT Frameworks to Cloud Governance IT CONTROL OBJECTIVES for Security & Assurance in Cloud Computing Section 4 covers Whether Businesses are ready for the Cloud, Risk Considerations, Graduated Risk Responsibilities, IAM (Identity and Access management), Physical security, Operational Risk, Security concerns and Secure Code Section 5 includes 1) Common Framework CSP Applicability for Third-party Certification/ Examination – page 62/63, 2) Key elements of a Unified IT Compliance program – page 65 3) Assurance through the Vendor management process- page 66-68 Appendix A on page 69 has the IT Control objectives for Cloud Computing Appendix B –8 useful Templates/Frameworks for Audit & Assurance Cloud Controls -Summary/Recommendations • Requests for third party Cloud Audits would get more common Ø IT Control Objectives for Cloud Computing from ISACA serves as a useful reference guide Ø Risk assessment / Risk based IT Audit aligned to the COBIT 5 should be a good starting point Ø Check Compliance with local standards and guidelines (MAS) Ø Map Business Goals to IT Processes and the maturity of each Cloud deployment model against these attributes using the Templates in the Appendix (Figure 3.8 , page 37, Page 169, Page 176) REFERENCES/ ACKNOWLEDGEMENTS Author Source Samuel GreenGard A Clear View of Cloud Security, August 2012 ISACA IT Control Objectives for Cloud Computing, 2011 V 1.0 Controls and Assurance in the Cloud ISACA IT Audits for Clouds and SaaS, Information Systems Control Journal, Volume 3, 2010 ENISA Cloud Computing- Benefits, Risks and (European Network and Recommendations for Information Security, Information Agency) November 2009 QUESTIONS? 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