Welcome!

Containers Expo Blog Authors: Mehdi Daoudi, Elizabeth White, Don MacVittie, XebiaLabs Blog, Stackify Blog

Related Topics: Cloud Security, @CloudExpo

Cloud Security: Article

A Service Auditor’s Letter to the Cloud

As an auditor (and former auditee), I will never be complacent about cloud security

SAS 70 Solutions Session at Cloud Expo

Dear Cloud:

Hello! Can you hear me? I know you can. Yes, yes...no one likes an auditor and I am even worse. I am that CPA who spent the last decade working in information security, both as a security consultant and as someone who managed the product lines of a global managed services business. So whether or not you want to open up those big APIs of yours and listen to me, this is what I have to say...

I know who you are and where you live.

Your name is "the cloud." I will admit that you are the catchiest IT buzzword since Java. Although you claim to live in the gated community called Web 2.0, I know better. You actually live in an unmarked windowless datacenter, with complex networks, servers, applications, policies, contracts, and worst of all, people!

You are unique, just like everyone else.

Your predecessors, such as the ASP, SaaS, and MSSP providers, have been providing customers with a vast array of multi-tenant solutions using the same underlying technology we now call "the cloud" for over a decade. I know because I was responsible for a managed security platform and your shared architecture model was our only path to profitability. From where I am standing, you look a lot like your predecessors, the only major exception being the amount of publicity you get from technology marketers as well as the security community as evidenced by the RSA Security Conference a few weeks ago.

You can be audited.

I have never met a technology that could not be audited...and you aren't going to be the first. Although I believe that many of my traditional methods are sufficient to gauge your control environment, my auditor and security friends are feverishly issuing new methods for assessing you. With time, there will be an army of IT auditors who will find very little about you to be "cloudy."

Like it or not... SAS 70 is the most widely adopted approach for Cloud Assurance

You know I work for a SAS 70 audit company. I do not claim independence on this matter. But lacking independence does not inherently make me wrong. You will also agree that there is no generally accepted standard for auditing you.

Contrary to what the security consultants tell you, Statement on Auditing Standard (SAS) No. 70 is not a weak security standard. It is not a security standard at all! It contains no mention of encryption, network segmentation, or password settings. It is, in fact, an auditing standard. Rather than attempt to tell you what to do, the standard tells you how to describe your services and related controls and tells me how I should test that description for the purposes of issuing results and an opinion. Security topics are normally included in the scope of SAS 70 audits (the extent of which is up to you, cloud), but security is not the primary objective of the audit. My security consulting friends continue to give themselves heartburn over this misconception.

What about the others standards and certifications?

ISO 27001 certification is sometimes mentioned as an alternative. However, with less than 100 certified companies in the United States, this certification has yet to hit mainstream service providers. Make no mistake, aligning with ISO 27001 and ISO 27002 will be both comprehensive and resource intensive. Vendor-specific certifications and seals are great for their specified purposes, but you must remember that they are focused on gauging compliance with static criteria. Such standards are prone to miss the forest for the trees and will disregard worthwhile controls beyond those contemplated by the standard.

PCI cannot provide cloud assurance either as it has a very specific application for providers who process or store credit card data. It is also a prescriptive standard, well liked by the security community but prone to the same cost issues as the ISO 27001/2 standards, which is why providers work so hard to reduce their card data footprints. The good news is that you can incorporate those commodity controls (such as physical security, access control, etc.) for PCI and other such standards into the SAS 70 audit scope such that if you have a comprehensive set of controls, you can potentially save significant time and assessment fees.

Why is SAS 70 more adopted than the others? One, it can adapt to your environment without excessive compliance cost that your end customers have not shown a willingness to share. In addition, it has utility. Only the SAS 70 audit can be leveraged for the purposes of customer assurance, financial auditor, Sarbanes Oxley compliance, regulators, and more. Last and unlike other assessments, the SAS 70 audit is regulated by both law and professional standards, so don't believe for a second that this is an easy undertaking for someone who maintains a CPA license along with CISSP, QSA, and other certifications!

There is always room for improvement.

As an auditor (and former auditee), I will never be complacent about cloud security. I was very excited about the Cloud Security Alliance announcement of the cloud controls matrix at RSA and anxiously await its release. I am also an active participant with Chris Hoff in the newly formed CloudAudit group. Even the AICPA and ISACA are working to make strides by updating their standards and modernizing with offerings such as WebTrust and SysTrust and an update to SAS 70 (SSAE 16), which also includes an international counterpart (ISAE 3402).

You see Cloud, it is unlikely that I will write any new standards, but I will contribute to groups that are focused on harnessing your potential (and addressing your risks). Most important, my day-to-day efforts will be focused on helping my clients understand, improve, and communicate the state of their internal controls to whoever needs to know and all within the bounds of economic reasonableness.

In the meantime, see you at 20,000 feet!

Yours Truly,

Doug

P.S. Want to discuss cloud assurance? Come find us at the 5th International Cloud Computing Expo in New York City. We will be at the SAS 70 Solutions booth in the exhibit hall and I am also presenting "Cloud Computing? There's an Audit for That!" on the Hot Topics! track (http://cloudcomputingexpo.com/event/session/768). Come by the booth or the presentation to register for a drawing for $200+ gift cards from Apple, American Express and more!

More Stories By Douglas Barbin

Doug Barbin is a Director at SAS 70 Solutions, a company that provides assurance and technology compliances services with an emphasis on SAS 70 audits, PCI validation, and ISO 27001/2 compliance. After starting his career with a "Big 4" global accounting firm, Doug has spent the last ten years working in the trenches of a wide variety of information security topics, and thus, understands the perspective of both the security consultant and the managed services / SaaS provider. Prior to joining SAS 70 Solutions, Barbin was Director of Product Management for VeriSign's Managed Security Services business, where he was responsible for the MSS "SaaS" platform architecture and compliance (including overseeing the conduct of the SAS 70 audit, PCI validation, and other types of compliance assessments). Prior to that, Doug was in charge of VeriSign's western US security consulting practice, where among other projects, he led some of the prototype PCI assessments. He has BS degrees in Accounting and Criminal Justice from Penn State University and an MBA from Pepperdine University.

Comments (0)

Share your thoughts on this story.

Add your comment
You must be signed in to add a comment. Sign-in | Register

In accordance with our Comment Policy, we encourage comments that are on topic, relevant and to-the-point. We will remove comments that include profanity, personal attacks, racial slurs, threats of violence, or other inappropriate material that violates our Terms and Conditions, and will block users who make repeated violations. We ask all readers to expect diversity of opinion and to treat one another with dignity and respect.


@ThingsExpo Stories
"Cloud Academy is an enterprise training platform for the cloud, specifically public clouds. We offer guided learning experiences on AWS, Azure, Google Cloud and all the surrounding methodologies and technologies that you need to know and your teams need to know in order to leverage the full benefits of the cloud," explained Alex Brower, VP of Marketing at Cloud Academy, in this SYS-CON.tv interview at 21st Cloud Expo, held Oct 31 – Nov 2, 2017, at the Santa Clara Convention Center in Santa Clar...
In his session at 21st Cloud Expo, Carl J. Levine, Senior Technical Evangelist for NS1, will objectively discuss how DNS is used to solve Digital Transformation challenges in large SaaS applications, CDNs, AdTech platforms, and other demanding use cases. Carl J. Levine is the Senior Technical Evangelist for NS1. A veteran of the Internet Infrastructure space, he has over a decade of experience with startups, networking protocols and Internet infrastructure, combined with the unique ability to it...
"IBM is really all in on blockchain. We take a look at sort of the history of blockchain ledger technologies. It started out with bitcoin, Ethereum, and IBM evaluated these particular blockchain technologies and found they were anonymous and permissionless and that many companies were looking for permissioned blockchain," stated René Bostic, Technical VP of the IBM Cloud Unit in North America, in this SYS-CON.tv interview at 21st Cloud Expo, held Oct 31 – Nov 2, 2017, at the Santa Clara Conventi...
Gemini is Yahoo’s native and search advertising platform. To ensure the quality of a complex distributed system that spans multiple products and components and across various desktop websites and mobile app and web experiences – both Yahoo owned and operated and third-party syndication (supply), with complex interaction with more than a billion users and numerous advertisers globally (demand) – it becomes imperative to automate a set of end-to-end tests 24x7 to detect bugs and regression. In th...
Widespread fragmentation is stalling the growth of the IIoT and making it difficult for partners to work together. The number of software platforms, apps, hardware and connectivity standards is creating paralysis among businesses that are afraid of being locked into a solution. EdgeX Foundry is unifying the community around a common IoT edge framework and an ecosystem of interoperable components.
"MobiDev is a software development company and we do complex, custom software development for everybody from entrepreneurs to large enterprises," explained Alan Winters, U.S. Head of Business Development at MobiDev, in this SYS-CON.tv interview at 21st Cloud Expo, held Oct 31 – Nov 2, 2017, at the Santa Clara Convention Center in Santa Clara, CA.
Large industrial manufacturing organizations are adopting the agile principles of cloud software companies. The industrial manufacturing development process has not scaled over time. Now that design CAD teams are geographically distributed, centralizing their work is key. With large multi-gigabyte projects, outdated tools have stifled industrial team agility, time-to-market milestones, and impacted P&L stakeholders.
"Space Monkey by Vivent Smart Home is a product that is a distributed cloud-based edge storage network. Vivent Smart Home, our parent company, is a smart home provider that places a lot of hard drives across homes in North America," explained JT Olds, Director of Engineering, and Brandon Crowfeather, Product Manager, at Vivint Smart Home, in this SYS-CON.tv interview at @ThingsExpo, held Oct 31 – Nov 2, 2017, at the Santa Clara Convention Center in Santa Clara, CA.
"Akvelon is a software development company and we also provide consultancy services to folks who are looking to scale or accelerate their engineering roadmaps," explained Jeremiah Mothersell, Marketing Manager at Akvelon, in this SYS-CON.tv interview at 21st Cloud Expo, held Oct 31 – Nov 2, 2017, at the Santa Clara Convention Center in Santa Clara, CA.
Coca-Cola’s Google powered digital signage system lays the groundwork for a more valuable connection between Coke and its customers. Digital signs pair software with high-resolution displays so that a message can be changed instantly based on what the operator wants to communicate or sell. In their Day 3 Keynote at 21st Cloud Expo, Greg Chambers, Global Group Director, Digital Innovation, Coca-Cola, and Vidya Nagarajan, a Senior Product Manager at Google, discussed how from store operations and ...
"There's plenty of bandwidth out there but it's never in the right place. So what Cedexis does is uses data to work out the best pathways to get data from the origin to the person who wants to get it," explained Simon Jones, Evangelist and Head of Marketing at Cedexis, in this SYS-CON.tv interview at 21st Cloud Expo, held Oct 31 – Nov 2, 2017, at the Santa Clara Convention Center in Santa Clara, CA.
SYS-CON Events announced today that CrowdReviews.com has been named “Media Sponsor” of SYS-CON's 22nd International Cloud Expo, which will take place on June 5–7, 2018, at the Javits Center in New York City, NY. CrowdReviews.com is a transparent online platform for determining which products and services are the best based on the opinion of the crowd. The crowd consists of Internet users that have experienced products and services first-hand and have an interest in letting other potential buye...
SYS-CON Events announced today that Telecom Reseller has been named “Media Sponsor” of SYS-CON's 22nd International Cloud Expo, which will take place on June 5-7, 2018, at the Javits Center in New York, NY. Telecom Reseller reports on Unified Communications, UCaaS, BPaaS for enterprise and SMBs. They report extensively on both customer premises based solutions such as IP-PBX as well as cloud based and hosted platforms.
It is of utmost importance for the future success of WebRTC to ensure that interoperability is operational between web browsers and any WebRTC-compliant client. To be guaranteed as operational and effective, interoperability must be tested extensively by establishing WebRTC data and media connections between different web browsers running on different devices and operating systems. In his session at WebRTC Summit at @ThingsExpo, Dr. Alex Gouaillard, CEO and Founder of CoSMo Software, presented ...
WebRTC is great technology to build your own communication tools. It will be even more exciting experience it with advanced devices, such as a 360 Camera, 360 microphone, and a depth sensor camera. In his session at @ThingsExpo, Masashi Ganeko, a manager at INFOCOM Corporation, introduced two experimental projects from his team and what they learned from them. "Shotoku Tamago" uses the robot audition software HARK to track speakers in 360 video of a remote party. "Virtual Teleport" uses a multip...
A strange thing is happening along the way to the Internet of Things, namely far too many devices to work with and manage. It has become clear that we'll need much higher efficiency user experiences that can allow us to more easily and scalably work with the thousands of devices that will soon be in each of our lives. Enter the conversational interface revolution, combining bots we can literally talk with, gesture to, and even direct with our thoughts, with embedded artificial intelligence, whic...
SYS-CON Events announced today that Evatronix will exhibit at SYS-CON's 21st International Cloud Expo®, which will take place on Oct 31 – Nov 2, 2017, at the Santa Clara Convention Center in Santa Clara, CA. Evatronix SA offers comprehensive solutions in the design and implementation of electronic systems, in CAD / CAM deployment, and also is a designer and manufacturer of advanced 3D scanners for professional applications.
Leading companies, from the Global Fortune 500 to the smallest companies, are adopting hybrid cloud as the path to business advantage. Hybrid cloud depends on cloud services and on-premises infrastructure working in unison. Successful implementations require new levels of data mobility, enabled by an automated and seamless flow across on-premises and cloud resources. In his general session at 21st Cloud Expo, Greg Tevis, an IBM Storage Software Technical Strategist and Customer Solution Architec...
To get the most out of their data, successful companies are not focusing on queries and data lakes, they are actively integrating analytics into their operations with a data-first application development approach. Real-time adjustments to improve revenues, reduce costs, or mitigate risk rely on applications that minimize latency on a variety of data sources. In his session at @BigDataExpo, Jack Norris, Senior Vice President, Data and Applications at MapR Technologies, reviewed best practices to ...
An increasing number of companies are creating products that combine data with analytical capabilities. Running interactive queries on Big Data requires complex architectures to store and query data effectively, typically involving data streams, an choosing efficient file format/database and multiple independent systems that are tied together through custom-engineered pipelines. In his session at @BigDataExpo at @ThingsExpo, Tomer Levi, a senior software engineer at Intel’s Advanced Analytics gr...