“We must push the envelope,” said James Williams, CIO at NASA’s Ames Research Center, which is developing the Nebula infrastructure as a service offering for the entire agency. “It’s not so much about making the cloud secure but about using the cloud to leverage best practices in security across an enterprise.”

Interesting! I recently had a discussion with our Chief Security Advisor in Australia and he told me how currently the Cloud comes into the play: Customers are not looking for a cloud solution but a way to improve their GRC processes. In parallel they have to reduce costs. Why not use the Cloud for this? Instead of trying to get ISO 27001 certified – we are. Instead of getting the ISO audit under SAS 70 Type II – we have. And the reason for that is fairly simple: We need to in order to help you to get compliant and then – it is our core business. Is running a datacenter in a compliant way yours?

So, the article above mentions four reasons, why you should stop worrying:

1. Sharing the cloud with strangers isn’t always a deal breaker.

[…]

Those risks are real, but they shouldn’t be deal breakers if proper steps are taken, especially given the potential financial rewards of multitenancy services. “You make a mistake if, in order to get security, you avoid co-tenancy entirely,” Rasch said.

There are ways to make such environments safer. At the Treasury Department, for example, officials are choosy about what they send to the cloud.

[…]

But Williams warned that cloud customers need to look below the surface. “Serious attention must be paid to crypto-implementation for processing and storage,” he said. He advises administrators to investigate each provider’s encryption strategy to answer the ultimate question: “Do you trust the algorithm as implemented by the vendor?”

It has to be about understanding your data and the classification thereof. If you do not understand your data, you cannot take the decision as described above. It reflects the last point in our paper on Information Protection. Additionally, trust leads back to certification. The encryption has to be FIPS certified.

2. FedRAMP is good start, but only the beginning.

Federal officials are optimistic that the budding Federal Risk and Authorization Management Program will simplify cloud security, but agencies shouldn’t let their guards down. Even after it’s finalized, don’t expect FedRAMP to relieve you of all security burdens.

I cannot (and do not want to) comment on FedRAMP. But what I keep saying (and again wrote in the paper), whatever you do with the Cloud, compliance and risk management remains your responsibility!

However, the interesting thing is that as soon as money is involved the discussions starts, which are the right standards to build something like that upon… I will not comment that further.

3 Outsourcing to the cloud? Don’t abdicate on security

Cloud computing increases the importance of a security best practice that every agency CIO might soon need to implement: continuous monitoring of IT resources and activities

See the point I made above. It is your responsibility. One thing is important to understand: If you are shooting for a public Cloud, you have to be aware of the fact, that this is a standard service, out of the box. The ability to customize it to your compliance needs is very, very limited as this is what the public Cloud is all about. You will have to trust the standards applied and the audits done by the Cloud provider. These audit reports have to be accessible to you if you are a customer (maybe under NDA). We are talking about economy of scale as you are looking for lower costs.

If you need tighter security, more controls etc. you might want to consider a private Cloud (on- or off-premise).

4. Off-the-shelf security terms are often negotiable.

Not all cloud security challenges are caused by still-evolving best practices and immature technologies. Some are the result of ongoing confusion about where a cloud service provider’s data management responsibilities end and the agency’s begin.

For example, don’t assume that the cloud provider will automatically back up data and store it on off-site tapes — a reasonable assumption under long-standing data protection practices. Similarly, a traditional intrusion detection system might not be included in a standard cloud contract.

“Those are services you can add, but if you don’t ask, you are not getting them oftentimes,” Cronin said.

Avoid unpleasant surprises and finger-pointing by diligently combing through cloud quotes to clearly understand what is being provided. And be ready to negotiate for anything that’s not spelled out in the document.

Therefore we ask customers to run a strong security and risk management team within their organizations. They need to be included in contract negotiations and I would definitely expect a Cloud provider to run the service in a professional way. At the end of the day, you have to be able to trust your provider.

And finally, there is a very interesting statement at the end:

“There is initially a belief that the cloud may not be as secure as [an agency’s] own infrastructure,” Cronin said. “But a cloud solution can be more secure than many federal systems that are on legacy infrastructures using legacy controls.”

If you are honest and try to get around your feelings: How good is your security? Really! Don’t get me wrong. I do not claim that security is bad everywhere and only Cloud providers know how to deal with it but I have seen a lot of very scary things, which cannot be changed internally because you are internal. If the best practices are applied by the provider you “have to” apply to these processes. This might be a great opportunity to increase your security.

And finally, there was an Australian KPMG report, which makes similar statements: Customer Experience: Security Can Improve in the Cloud

Roger

Let me start, however, with a case I had a while ago. I was called by a customer, who lost data. The data was very, very sensitive and the customer is in a business where losing such data can really hurt. So, they called me and wanted forensic support. The interesting thing was, that the criminal copied the sensitive data on to a CD and sent it to a very famous boulevard newspaper to be published. The only goal was to hurt the company. What I liked was the reaction of the newspaper: They called the company and told them that they most probably had a problem, handed them the CD including the data and did an anonymous story about such challenges, taking this as an example without revealing who the company was.

So, basically we have two fundamentally different tactics and ethics: One is to publish everything, which gets in your hands for a moment of fame and probably money. The other one is trying to go for a win-win (as far as you can win if you lose data). Do you have the right to risk a company’s reputation or even a country’s safety “just” for this moment of fame?

I leave that to you. My opinion is set

Roger

Andrea Du Maio from Gartner now offered his perspective on this paper in an article called Microsoft offers a refreshing perspective on government clouds – so it seems that the paper hit the mark. He said:

The paper is surprisingly refreshing since it does not try to match the reality of current Microsoft’s offering, which spans from on-premises, to dedicated and shared implementations, potentially able to meet any flavor of cloud. On the contrary Microsoft shows remarkable common sense in providing public sector clients with a realistic and cautionary picture about both private and community clouds

Roger

In order to see photos from the archive of UNHCR, zoom into the picture of the girl on the first page. A great technology to show a very sad reality.

Roger

I tried to look at it from the angle of the generic framework we developed this January, when we released our Cloud Security Considerations Whitepaper. I used the content of the paper fairly often in the past few months and it resonates very well because of its simplicity but still completeness of the considerations raised. Basically we talk of five areas of consideration:

1. Compliance and Risk Management: Compliance requirements can be fulfilled by a skilled internal team and a certain level of process transparency by the cloud provider(s).
2. Identity and Access Management: Any digital identity system for the cloud has to be interoperable across different organizations and cloud providers and based on strong processes.
3. Service Integrity: The provider should follow a clear, defined, and provable process to integrate security and privacy in the service from the beginning and for the whole lifecycle and The service delivery capabilities of the provider and the security management and auditing needs of the customer must be aligned.
4. End Point Integrity: It is very important to include the end point in any security consideration for cloud-based services.
5. Information Protection: Implemented Data Classification helps to decide which data is ready for the cloud, under which circumstances, and with which controls.

As Scott was not addressing a general audience but the government, he took a different angle and was talking about the key responsibilities of the Cloud providers, the government and where there are shared responsibilities. Let me take some quotes from Scott’s note and frame them in the model above.

1. Compliance and Risk Management

An area, where I struggle most is that there are too many customers out there (private and public sector) who think that they can outsource a problem and then they are done. “Let’s move part of our IT to the cloud and then the cloud provider ensures our compliance” – and the industry often supports this behavior by telling the customer that they should look at it like a bank: Give us all your money and you do not have to care anymore – well recent developments in the economy showed that not even this is true! This approach simply works in fairytales.

Scott said in that respect:

Of course, the fact that a customer has transferred these responsibilities to the cloud provider — and may even have transferred legal liability by contract — is not the end of the matter. For example, citizens ultimately may hold a government accountable if data is lost or stolen, or critical data is not available when needed, notwithstanding any cloud provider agreement. Thus, a government may remain ―accountable‖ to its constituents when an incident occurs, notwithstanding any contractual apportionment of responsibility. That said, as the federal government becomes a customer of cloud services, it must be clear about its requirements — and cloud providers must be responsible for meeting those requirements.

I am personally convinced that the cloud provider need to show a certain level of transparency in order to help the customer to be compliant. The level of transparency is dependant on different factors like whether you are operating in a private or a public cloud, your requirements etc. In Scott’s words:

Defining how responsibilities for security, privacy, and reliability are allocated — and creating sufficient transparency about this allocation — represent new challenges. Both customers and cloud providers must understand their respective roles and be able to communicate compliance requirements and controls across the spectrum of services available in the cloud.

The interesting challenge now is, to clarify who takes what kind of responsibility in this. It is clearly the responsibility of the customer to have a team of people as I mentioned above to ensure compliance and a proper risk management across all the systems they operate. However, this does not mean that the cloud provider does not carry any responsibility – the contrary is the case.

The importance of assuring the confidentiality, integrity, and availability of customer data and operations is not new, but cloud computing does have the effect of shifting the responsibility (in whole or in part) for these areas to cloud service providers. Providers must rise to this new reality and provide commensurate levels of assurance for their customers.

Usually this is the point where people start to ask what we do to help here. Instead of me summarizing this, I use Scott’s words again:

Microsoft addresses this challenge through our holistic approach for managing security, privacy, and reliability that is designed to meet or exceed customer requirements. Our approach includes three cross-cutting functions to manage physical, personnel, and IT security: (1) utilizing a risk-based information security program that assesses and prioritizes security and operational threats to the business; (2) maintaining and updating a detailed set of security controls that mitigate risk; and (3) operating a compliance framework that ensures controls are designed appropriately and are operating effectively.

In order to prove our processes, Microsoft Online Services is ISO 27001:2005 and SAS 70 Type I and Type II certified – Microsoft’s online Information Security Program has been independently certified by British Standards Institute (BSI) Management Systems America as being compliant with ISO/IEC 27001:2005. To be clear: I understand the limitations of these certifications however, there is to my knowledge nothing in the market which does a better job. In my opinion we should start thinking about security metrics rather than a new standard to add to ISO 27001.

Another challenge is geo-location which may play into regulatory compliance, here we provide the ability to geo-location the customer’s data.

But on the other end, governments have their duty to look at the cloud from a risk-based approach. It is not about “we cannot do it because of…” nor is it about jumping into the cloud because it seems tempting – it is about sound risk management to bridge the gap between technology and the business:

For security, agencies must approach the cloud thoughtfully, with an unwavering commitment to evaluate threats, assess risks, and define security requirements in order to ensure risks are managed at acceptable levels.

2. Identity and Access Management

Since the publication of the End to End Trust paper, we state that running an interoperable and federate identity metasystem is key for the future. This is even more true in the cloud. However, when we talk about all these new concepts, we should not forget that most of our customers struggle with the basic processes – not necessarily with technology. When it comes to identity, Scott references it towards the end as one of the key areas to look into:

Today, there are over 1.8 billion Internet users in the world, or more than 26% of the population.  Internet users continue to grow at over 19% year over year, yet the mechanisms to provide identity, authentication, and attribution in cyberspace do not yet meet the needs of citizens, enterprises, or governments in traditional computing environments or for the cloud. The lack of trust online stems in part from our inability to manage online identities effectively. The cloud only amplifies the need for more robust identity management to help solve some of the fundamental security and privacy problems inherent in current Internet systems.

Cyber attacks are facilitated by the anonymity and lack of traceability of the Internet; malicious actors in cyberspace must be convinced that either the cost of their actions is not worth the return on investment or that there is a real chance of attribution and punishment. Mandating robust authentication for some Internet uses — such as accessing critical infrastructures — while ensuring anonymity at other times (e.g., when citizens want to access public information) can help strike the right balance between security and privacy. Modern identity systems increasingly permit users to provide elements of their identity without having to provide more information than is required for a given transaction. Additionally, in appropriate cases, hardware, software and data should be authenticated as well.

To be very clear (even though Scott is already) let me re-enforce our position: It is not about authenticating everybody as strong as possible. We need the right balance between authentication and anonymity. A key role in this plays the option to use attributes of my identity only when I use the Internet (e.g. my age or my nationality). For a lot of services, this may well be good enough.

3. Service Integrity

If you are a customer, you have to understand how your services are engineered and operated. How can you otherwise assume the responsibility you have to according to what we said above? Or even better: How can you trust a provider otherwise? Well, there is security and privacy in this and Scott just give a high level overview on what we do there:

Any analysis of the cloud must start with the technology that powers it. Microsoft has long recognized the importance of building secure and reliable software, and we devote considerable resources to ensuring the quality of our software, including adherence to the Security Development Lifecycle (SDL). The SDL consists of continuously evolving processes and tools designed to reduce the number and severity of vulnerabilities in software products and ensure appropriate and agile response when necessary. Importantly, in the context of discussing providers’ responsibilities in the cloud, it should be noted that the SDL considers and accounts for risks related to the environment in which the application will run (e.g., client computers, on-premises services, or the cloud). Thus, the SDL ensures that Microsoft cloud services are developed using secure development practices.

Online service providers can use a variety of technologies and procedures to help protect personal information from unauthorized access, use, or disclosure. Microsoft’s software development teams apply the ―PD3+C‖ principles, defined in the SDL, throughout the company’s development and operational practices (PD3+C means Privacy by Default, Privacy by Design, Privacy in Deployment and Communication)

But it is not “only” about these processes, it is about constant learning as well:

The integrity of cloud providers — including their personnel — is increasingly important, because the scale and scope of their actions can be exponentially increased in the cloud. Microsoft engineers are required to complete state-of-the-art training on many technology topics, including security and privacy, to help them keep pace with an ever-changing industry.

This is all good. I just do not think that the industry will finally move to that level unless there is a market pressure as there is a need by governments and customers all across the globe:

The government also should require that providers from which it procures cloud computing services meet the government’s operational requirements for security, privacy and reliability. As threats continue to evolve, it remains critically important that cloud providers demonstrate secure development practices and transparent response processes for their applications. More broadly, the government should, wherever practicable, ensure that the technologies it procures, acquires, and uses are built and maintained in accordance with industry best practices for secure development.

4. Endpoint Integrity

As the testimony was about the cloud, he touched on that a tiny little bit but not deeply.

5. Information Protection

Our basic claim in our paper is that you should move to the cloud once you understood your data. You have to know your classified data and understand what can be moved where. Scott was fairly clear here:

Agencies’ current struggles to identify, manage, or account for security of data and systems are not immediately solved by integrating cloud services.

I guess, that this is not only true for the US…

What does this now mean as a conclusion. Well, Scott put it that way: The Information Age has arrived and the cloud is ready for the government, but in many respects, the government is not yet ready for cloud computing. Now again, this is for the US government but my experience across EMEA shows, that this is true for almost all governments. Key pieces of a sound security strategy are missing: Implementation of data classification schemas, a clear understanding of an identity strategy etc. etc. I usually summarize it with the term of a Cybersecurity Agenda or Program, which is missing. Surprising to me was that governments often know about this and they are open to accept help – one of the reasons why we increase the coverage of senior security people across the globe again.

Additionally, it is really time to collaborate in a partnership between governments to start with but between governments and the private sector. These collaborative efforts should focus on promoting transparency around cloud computing providers’ security, privacy, and reliability practices and, in turn, helping to ensure that users can make informed choices.

If you think about the cloud keep this in mind:

The success of this transition depends on two factors: (1) the ability to adapt and advance information security programs and to communicate requirements to agencies’ cloud providers; and (2) the ability of cloud providers to meet customers’ requirements with sufficient transparency to ensure that requirements for security, privacy, and reliability are met appropriately.

The alignment and understanding of responsibility in the cloud requires greater transparency from both cloud providers and cloud customers (including enterprises and governments). The more precise and transparent we are, the greater the trust we will build, and the greater opportunity we create.

People in my community, called Chief Security Advisors, are present in almost 30 countries to help governments and customers to address key challenges and questions in this security space. But to be clear upfront: We do not have all the answers nor do we claim to have them (and honestly, I do not even think that we in the industry already know all the questions )

Roger

So, the nervousness is really about the customs officer keeping a notebook and getting access to the data, which is scary but again, is this any different to carrying paper across the border – except for the sheer volume but basically if you carry confidential documents across any country’s border the customs officer can search you and have a look at your paper.

So far so good but it seems that some customs officers took their time when they actually wanted to search a notebook – a few months until an year.  They simply kept it. Now a court in the US ruled that this is illegal: Judge limits DHS laptop border searches

So, while the search at entry is still acceptable due to the points I made above, the confiscation of a computer for a longer period of time seems to be illegal. Will be interesting to see how this will develop.

Roger