Welcome!

Containers Expo Blog Authors: Carmen Gonzalez, Jyoti Bansal, Elizabeth White, Liz McMillan, Chris Colosimo

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
NHK, Japan Broadcasting, will feature the upcoming @ThingsExpo Silicon Valley in a special 'Internet of Things' and smart technology documentary that will be filmed on the expo floor between November 3 to 5, 2015, in Santa Clara. NHK is the sole public TV network in Japan equivalent to the BBC in the UK and the largest in Asia with many award-winning science and technology programs. Japanese TV is producing a documentary about IoT and Smart technology and will be covering @ThingsExpo Silicon Val...
New competitors, disruptive technologies, and growing expectations are pushing every business to both adopt and deliver new digital services. This ‘Digital Transformation’ demands rapid delivery and continuous iteration of new competitive services via multiple channels, which in turn demands new service delivery techniques – including DevOps. In this power panel at @DevOpsSummit 20th Cloud Expo, moderated by DevOps Conference Co-Chair Andi Mann, panelists will examine how DevOps helps to meet th...
SYS-CON Events announced today that Hitachi Data Systems, a wholly owned subsidiary of Hitachi LTD., will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City. Hitachi Data Systems (HDS) will be featuring the Hitachi Content Platform (HCP) portfolio. This is the industry’s only offering that allows organizations to bring together object storage, file sync and share, cloud storage gateways, and sophisticated search an...
SYS-CON Events announced today that Hitachi, the leading provider the Internet of Things and Digital Transformation, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Hitachi Data Systems, a wholly owned subsidiary of Hitachi, Ltd., offers an integrated portfolio of services and solutions that enable digital transformation through enhanced data management, governance, mobility and analytics. We help globa...
The explosion of new web/cloud/IoT-based applications and the data they generate are transforming our world right before our eyes. In this rush to adopt these new technologies, organizations are often ignoring fundamental questions concerning who owns the data and failing to ask for permission to conduct invasive surveillance of their customers. Organizations that are not transparent about how their systems gather data telemetry without offering shared data ownership risk product rejection, regu...
SYS-CON Events announced today that Hitachi, the leading provider the Internet of Things and Digital Transformation, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Hitachi Data Systems, a wholly owned subsidiary of Hitachi, Ltd., offers an integrated portfolio of services and solutions that enable digital transformation through enhanced data management, governance, mobility and analytics. We help globa...
SYS-CON Events announced today that SoftLayer, an IBM Company, has been named “Gold Sponsor” of SYS-CON's 18th Cloud Expo, which will take place on June 7-9, 2016, at the Javits Center in New York, New York. SoftLayer, an IBM Company, provides cloud infrastructure as a service from a growing number of data centers and network points of presence around the world. SoftLayer’s customers range from Web startups to global enterprises.
With major technology companies and startups seriously embracing IoT strategies, now is the perfect time to attend @ThingsExpo 2016 in New York. Learn what is going on, contribute to the discussions, and ensure that your enterprise is as "IoT-Ready" as it can be! Internet of @ThingsExpo, taking place June 6-8, 2017, at the Javits Center in New York City, New York, is co-located with 20th Cloud Expo and will feature technical sessions from a rock star conference faculty and the leading industry p...
SYS-CON Events announced today that Juniper Networks (NYSE: JNPR), an industry leader in automated, scalable and secure networks, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Juniper Networks challenges the status quo with products, solutions and services that transform the economics of networking. The company co-innovates with customers and partners to deliver automated, scalable and secure network...
Five years ago development was seen as a dead-end career, now it’s anything but – with an explosion in mobile and IoT initiatives increasing the demand for skilled engineers. But apart from having a ready supply of great coders, what constitutes true ‘DevOps Royalty’? It’ll be the ability to craft resilient architectures, supportability, security everywhere across the software lifecycle. In his keynote at @DevOpsSummit at 20th Cloud Expo, Jeffrey Scheaffer, GM and SVP, Continuous Delivery Busine...
Bert Loomis was a visionary. This general session will highlight how Bert Loomis and people like him inspire us to build great things with small inventions. In their general session at 19th Cloud Expo, Harold Hannon, Architect at IBM Bluemix, and Michael O'Neill, Strategic Business Development at Nvidia, discussed the accelerating pace of AI development and how IBM Cloud and NVIDIA are partnering to bring AI capabilities to "every day," on-demand. They also reviewed two "free infrastructure" pr...
SYS-CON Events announced today that T-Mobile will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. As America's Un-carrier, T-Mobile US, Inc., is redefining the way consumers and businesses buy wireless services through leading product and service innovation. The Company's advanced nationwide 4G LTE network delivers outstanding wireless experiences to 67.4 million customers who are unwilling to compromise on ...
SYS-CON Events announced today that Super Micro Computer, Inc., a global leader in compute, storage and networking technologies, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Supermicro (NASDAQ: SMCI), the leading innovator in high-performance, high-efficiency server technology, is a premier provider of advanced server Building Block Solutions® for Data Center, Cloud Computing, Enterprise IT, Hadoop/...
NHK, Japan Broadcasting, will feature the upcoming @ThingsExpo Silicon Valley in a special 'Internet of Things' and smart technology documentary that will be filmed on the expo floor between November 3 to 5, 2015, in Santa Clara. NHK is the sole public TV network in Japan equivalent to the BBC in the UK and the largest in Asia with many award-winning science and technology programs. Japanese TV is producing a documentary about IoT and Smart technology and will be covering @ThingsExpo Silicon Val...
In his general session at 19th Cloud Expo, Manish Dixit, VP of Product and Engineering at Dice, discussed how Dice leverages data insights and tools to help both tech professionals and recruiters better understand how skills relate to each other and which skills are in high demand using interactive visualizations and salary indicator tools to maximize earning potential. Manish Dixit is VP of Product and Engineering at Dice. As the leader of the Product, Engineering and Data Sciences team at D...
The 20th International Cloud Expo has announced that its Call for Papers is open. Cloud Expo, to be held June 6-8, 2017, at the Javits Center in New York City, brings together Cloud Computing, Big Data, Internet of Things, DevOps, Containers, Microservices and WebRTC to one location. With cloud computing driving a higher percentage of enterprise IT budgets every year, it becomes increasingly important to plant your flag in this fast-expanding business opportunity. Submit your speaking proposal ...
The age of Digital Disruption is evolving into the next era – Digital Cohesion, an age in which applications securely self-assemble and deliver predictive services that continuously adapt to user behavior. Information from devices, sensors and applications around us will drive services seamlessly across mobile and fixed devices/infrastructure. This evolution is happening now in software defined services and secure networking. Four key drivers – Performance, Economics, Interoperability and Trust ...
SYS-CON Events announced today that CollabNet, a global leader in enterprise software development, release automation and DevOps solutions, will be a Bronze Sponsor of SYS-CON's 20th International Cloud Expo®, taking place from June 6-8, 2017, at the Javits Center in New York City, NY. CollabNet offers a broad range of solutions with the mission of helping modern organizations deliver quality software at speed. The company’s latest innovation, the DevOps Lifecycle Manager (DLM), supports Value S...
With billions of sensors deployed worldwide, the amount of machine-generated data will soon exceed what our networks can handle. But consumers and businesses will expect seamless experiences and real-time responsiveness. What does this mean for IoT devices and the infrastructure that supports them? More of the data will need to be handled at - or closer to - the devices themselves.
Web Real-Time Communication APIs have quickly revolutionized what browsers are capable of. In addition to video and audio streams, we can now bi-directionally send arbitrary data over WebRTC's PeerConnection Data Channels. With the advent of Progressive Web Apps and new hardware APIs such as WebBluetooh and WebUSB, we can finally enable users to stitch together the Internet of Things directly from their browsers while communicating privately and securely in a decentralized way.