About a month or so back, I was attending a tradeshow where I happened to overhear a passionate argument between sessions about the impact of cloud on risk management. It was one of those times when I was trying my best not to eavesdrop, but these two gentlemen were so vocal about their various opinions that it was hard not to hear.
The crux of the argument had to do with whether cloud made risk assessment easier or harder to accomplish. On the "easier" side was the argument that reviewing a cloud services provider once and using contractual language to "lock in" operational controls took several review steps out of scope. On the "harder" side, the argument was that the risk assessment process had to be done for each type of business process that intersected the provider since no one audit could account for every way that the provider would be used (i.e., "Today we use the CSP for public data and we audit their controls for that case, but the business could move private data there tomorrow once the vendor is approved").
It was an interesting discussion and, as you can tell, it stuck with me. I'm still not sure who was "right" in this particular discussion - they both made valid points. But it seems to me that there was something bigger left out of the discussion: namely, the impact of cloud on mitigating control selection.
Here's what I mean: No matter whose model of risk management you're using (ISO, NIST, Octave, etc.), there's more than just the assessment phase. After assessment, there comes risk treatment. In most cases, that means control selection.
Cloud changes this, it seems to me, quite drastically. Specifically, when you engage a cloud provider - whether IaaS, PaaS or SaaS - you are drawing a line in the sand. In effect you say, "Everything below X level of the application stack will be a black box." You are deliberately abstracting yourself away from some portion of the technical substrate. In an IaaS context, it could be that portions of the network leave your scope of control while the OS and platform stay in it. For the PaaS, you retain control over the app but you give up control over the platform ... and everything below that (OS, network, etc.). For SaaS, the whole potato is a black box (the application and everything below).
For some purposes, this is a good thing. The less that's in your scope of control, the less you have to deploy custom security controls to address particular issues. However, it's also important to remember that once a particular level of the stack goes from being "something you can manipulate" to "something you can't," you also lose the ability to deploy a compensating control at that level. This impacts (or at least should impact) your control selection.
As an example, say you have an application that's historically been hosted within your organization's infrastructure. If you discover an issue at the application layer (say the application is vulnerable to SQL injection), you have a number of options across every level of the application stack. You could, for example, update the app. Alternatively, you could implement monitoring in the database or middleware, or you could implement host-level controls or network-level monitoring. All these options are open to you because you control every layer of the stack.
In a cloud context, options are more limited. If you use a PaaS, you can't deploy an OS-level control because you don't control the OS. Is this an issue? Maybe not ... at least, not if you're planning for it. But the bigger issue is what happens when you move existing applications and business processes to the cloud. In that case, compensating controls can "fall on the floor" unless you've either A.) kept detailed records of compensating controls you've historically put in place mapped to the original risks so that you can gauge their efficacy in the new environment or B.) systematically re-evaluated each application to determine what compensating controls will need to be re-implemented. And, not to be a pessimist, but most firms aren't doing either of those things.
Now, I'm not going to say that every firm out there should start from scratch in their risk mitigation strategy when they move to cloud. But I will say that a move to the cloud - at least for firms that are serious about security - could be a useful time to evaluate risks in the applications and processes that they plan to move.
Ed Moyle is senior security strategist at Savvis, a CenturyLink company.
Savvis Security Webinar:
"Eight Steps to a Secure Cloud Infrastructure"
June 6, 2012
Presented by Chris Richter, vice president of security products at services
http://ht.ly/aXlSC


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