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CCPA and the cloud

Since the EU introduced the General Data Protection Regulation (GDPR) in 2018, all eyes have been on the U.S. to see if it will follow suit. While a number of states have enacted data privacy statutes, California’s Consumer Protection Act (CCPA) is the most comprehensive U.S. state law to date. Entities were expected to be in compliance with CCPA as of January 1, 2020.

CCPA compliance requires entities to think about how the regulation will impact their cloud infrastructures and development of cloud-native applications. Specifically, companies must understand where personally identifiable information (PII) and other private data lives, and how to process, validate, complete, and communicate consumer information and consent requests.

What is CCPA and how to ensure compliance

CCPA gives California residents greater privacy rights their data that is collected by companies. It applies to any business with customers in California and that either has gross revenues over $25 million or that acquires personal information from more than 50,000 consumers per year. It also applies to companies that earn more than half their annual revenue selling consumers’ personal information.

In order to ensure compliance, the first thing firms should look at is whether they are collecting PII, and if they are, ensuring they know exactly where it is going. CCPA not only mandates that California consumers have the right to know what PII is being collected, it also states that customers can dictate whether it’s sold or deleted. Further, if a company suffers a security breach, California consumers have the right to sue that company under the state’s data notification law. This increases the potential liability for companies whose security is breached, especially if their security practices do not conform to industry standards.

Regulations regarding data privacy are proliferating and it is imperative that companies set up an infrastructure foundation which help them evolve fluidly with these changes to the legal landscape, as opposed to “frankensteining” their environments to play catch up. The first is data mapping in order to know where all consumer PII lives and, importantly, where California consumer PII lives. This requires geographic segmentation of the data. There are multiple tools, including cloud native ones, that empower companies with PII discovery and mapping. Secondly, organizations will need to have a data deletion mechanism in place and an audit trail for data requests, so that they can prove they have investigated, validated, and adequately responded requests made under CCPA. The validation piece is also crucial – companies must make sure the individual requesting the data is who they say they are.

And thirdly, having an opt-in or out system in place that allows consumers to consent to their data being collected in the first place is essential for any company doing business in California. If the website is targeted at children, there must be a specific opt-in request for any collection of California consumer date. These three steps must be followed with an audit trail that can validate each of them.

The cloud

It’s here that we start to consider the impact on cloud journeys and cloud-native apps, as this is where firms can start to leverage tools that that Amazon or Azure, for example, currently have, but that haven’t been integral for most businesses in a day-to-day context, until now. This includes AI learning tools for data discovery, which will help companies know exactly where PII lives, so that they may efficiently comply with data subject requests.

Likewise, cloud infrastructures should be set up so that firms aren’t playing catch up later on when data privacy and security legislation is enacted elsewhere. For example, encrypt everything, as well as making sure access control permissions are up to date. Organizations must also prevent configuration drift with tools that will automate closing up a security gap or port if one gets opened during development.

For application development teams, it’s vital to follow security best practices, such as CIS benchmarks, NIST standards and the OWASP Top Ten. These teams will be getting the brunt of the workload in terms of developing website opt-out mechanisms, for example, so they must follow best practices and be organized, prepared, and efficient.

The channel and the cloud

For channel partners, there are a number of considerations when it comes to CCPA and the cloud. For one, partners who are in the business of infrastructure consulting should know how the legislation affects their infrastructure and what tools are available to set up a client with an infrastructure that can handle the requests CCPA mandates.

This means having data discovery tools in place, which can be accomplished with both cloud native versions and third party software. Also, making sure notification mechanisms are in place, such as email, or if you’re on Amazon, SNS (Simple Notification Service). Notification mechanisms will help automate responding to data subject requests. Additionally, logging must be enabled to establish an audit trail. Consistent resource tagging and establishing global tagging policies is integral to data mapping and quickly finding data. There’s a lot from an infrastructure perspective that can be done, so firms should familiarize themselves with tools that can facilitate CCPA compliance that may have never been used in this fashion, or indeed at all.

Ultimately, when it comes to CCPA, don’t sleep on it. GDPR went into effect less than two years ago, and already we have seen huge fines doled out to the likes of British Airways and Google for compliance failures. The EU has been aggressive about ensuring compliance, and California is likely to follow the same game. They know that in order to give CCPA any teeth, they have to make sure that they prosecute it.

If you’re interested in learning more about how privacy laws might affect cloud development, watch our “CCPA: State Privacy Law Effects on Cloud Development” webinar on-demand, at your convenience.

– Victoria Geronimo, Product Manager – Security & Compliance

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Protection from Immediate Threats with an AWS Security Rapid Review

Security assessments are a necessity for cloud security, governance, and compliance. Ideally, an assessment will result in a prioritized list of security and compliance gaps within your cloud environment, the context (or standards) for these gaps, and how to fix them. In reality, however, security assessments themselves can have their own vulnerabilities, particularly around scoping and recommendations.

Organizations that do not have in-house security expertise may have trouble defining what they are actually seeking to get out of the assessment. Projects can be ill-scoped, and recommendations may not actually make sense given your security posture and budget. Additionally, many remediation recommendations may just be band-aid solutions and not long-term fixes that will stop the vulnerability from reoccurring. By the end of the engagement, you may end up with a couple of good recommendations, a lot of useless ones, and a month of wasted time and resources.

Enter our AWS Security Rapid Review. This 1-2 week engagement is designed to provide you with a quick turnaround of actionable remediation recommendations. It is scalable from a small sample of accounts to a few hundred. Benefits include:

• Checking your AWS environment against industry-standard benchmarks and 2nd Watch best practices
• List of vulnerabilities
• Threat prioritization
• Prescriptive, actionable remediation recommendations
• Consultation with a 2nd Watch security expert on the underlying systemic issues causing noted vulnerabilities
• 1-2 week turnaround time

This assessment gives you the immediate ability to remediate vulnerabilities as well as the context for why these vulnerabilities are occurring in the first place. You have control over whether you want to just remediate findings or take it a step further and lay down a robust security foundation.

To learn more about our AWS Security Rapid Review, download our datasheet.

-Victoria Geronimo, Product Manager, Security & Compliance

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Leveraging the cloud for SOC 2 compliance

In a world of high profile attacks, breaches, and information compromises, companies that rely on third parties to manage and/or store their data sets are wise to consider a roadmap for their security, risk and compliance strategy. Failure to detect or mitigate the loss of data or other security breaches, including breaches of their suppliers’ information systems, could seriously expose a cloud user and their customers to a loss or misuse of information in such a harmful way that it becomes difficult to recover from. In 2018 alone, there were nearly 500 million records exposed from data breaches, according to the Identity Theft Resource Center’s findings, https://www.idtheftcenter.org/2018-end-of-year-data-breach-report/. While absolute security can never be attained while running your business, there are frameworks, tools, and strategies that can be applied to minimize the risks to acceptable levels while maintaining continuous compliance.

SOC 2 is one of those frameworks that is particularly beneficial in the Managed Service Providers space. It is a framework that is built on the AICPA’s Trust Services Principles (TSP) for service security, availability, confidentiality, processing integrity, and privacy.  SOC 2 is well suited for a wide range of applications, especially in the cloud services space. Companies have realized that their security and compliance frameworks must stay aligned with the inherent changes that come along with cloud evolution. This includes making sure to stay abreast of developing capabilities and feature enhancements.  For example, AWS announced a flurry of new services and features at its annual re:Invent conference in 2018 alone. When embedded into their cloud strategy, companies can use the common controls that SOC 2 offers to build the foundation for a robust Information Systems security program.

CISO’s, CSO’s, and company stakeholders must not take on the process of forming the company security strategy in a vacuum. Taking advantage of core leaders in the organization, both at the management level and at the individual contributor level, should be part of the overall security development strategy, just as it is with successful innovation strategies. In fact, the security strategy should be integrated within the company innovation strategy. One of the best approaches to ensure this happens, for example, is to develop a steering committee with participation from all major divisions and/or groups. This is more effective with smaller organizations where information can quickly flow vertically and horizontally, however, larger organizations would simply need to ensure that the vehicles are in place to allow for a quick flow of information to all stakeholders

Organizations with strong security programs have good controls in place to address each of the major domain categories under the Trust Service Principles. Each of the Trust Service Principles can be described through the controls that the company has established. Below are some ways that Managed Cloud Service providers like 2nd Watch meet the requirements for security, availability, and confidentiality while simultaneously lowering the overall risk to their business and their customers business:

Security

  • Change Management – Implement both internal and external system change management using effective ITSM tools to track, at a minimum, the change subject, descriptions, requester, urgency, change agent, service impact, change steps, evidence of testing, back-out plan, and appropriate stakeholder approvals.
  • End-User Security – Implement full-disk encryption for end-user devices, deploy centrally managed Directory Services for authorization, use multi-factor authentication, follow password/key management best-practices, use role based access controls, segregate permission using a least-user-privilege approach, and document the policies and procedures. These are all great ways towards securing environments fairly quickly.
  • Facilities – While “security of the cloud” environment fall into the responsibility of your cloud infrastructure provider, your Managed Services Provider should work to adequately protect their own, albeit not in scope, physical spaces. Door access badges, logs, and monitoring of entry/exit points are positive ways to prevent unauthorized physical entry.
  • AV Scans – Ensure that your cloud environments are built with AV scanning solutions.
  • Vulnerability Scans and Remediation – Ensure that your Managed Services Provider or third party provider is running regular vulnerability scans and performing prompt risk remediation. Independent testing of the provider’s environment will help to identify any unexpected risks so implementing an annual penetration test is important.

Availability

  • DR and Incident Escalations – Ensure that your MSP provider maintains current documented disaster recovery plans with at least annual exercises. Well thought-out plans include testing of upstream and downstream elements of the supply chain, including a plan for notifications to all stakeholders.
  • Risk Mitigation – Implement an annual formal risk assessment with a risk mitigation plan for the most likely situations.

Confidentiality

  • DLP – Implement ways and techniques to prevent data from being lost by unsuspecting employees or customers. Examples may include limiting use of external media ports to authorized devices, deprecating old cypher protocols, and blocking unsafe or malicious downloads.
  • HTTPS – Use secure protocols and connections for the safe transmission of confidential information.
  • Classification of Data – Make sure to identify elements of your cloud environment so that your Managed Service Providers or 3rd Parties can properly secure and protect those elements with a tagging strategy.
  • Emails – Use email encryption when sending any confidential information. Also, check with your own Legal department for proper use of your Confidentiality Statement at end of emails that are appropriate to your business.

By implementing these SOC 2 controls, companies can be expected to have a solid security framework to build on. Regardless of their stage in the cloud adoption lifecycle, businesses must continue to demonstrate to their stakeholders (customers, board members, employees, shareholders) that they have a secure and compliant business. As with any successful customer-service provider relationship, the use of properly formed contracts and agreements comes into play. Without these elements in place and in constant use, it is difficult to evaluate how well a company is measuring up. This is where controls and a framework on compliance like SOC 2 plays a critical role.

Have questions on becoming SOC 2 compliant? Contact us!

– By Eddie Borjas, Director of Risk & Compliance

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Continuous Compliance: Continuous Iteration

For most students, one of the most stressful experiences of their educational career are exam days.  Exams are a semi-public declaration of your ability to learn, absorb, and regurgitate the curriculum, and while the rewards for passing are rather mundane, the ramifications of failure are tremendous.  My anecdotal educational experience indicates that exam success is primarily due to preparation, with a fair bit of luck thrown in.  If you were like me in school, my exam preparation plan consisted mostly of cramming, with a heavy reliance on luck that the hours spent jamming material into my brain would cover at least 70% of the exam contents.

After I left my education career behind me and started down a new path in business technology, I was rather dismayed to find out that the anxiety of testing and exams continued, but in the form of audits!  So much for the “we will never use this stuff in real life” refrain that we students expressed Calculus 3 class – exams and tests continue even when you’re all grown up.  Oddly enough, the recipe for audit success was remarkably similar: a heavy dose of preparation with a fair bit of luck thrown in.  Additionally, it seemed that many businesses also adhered to my cram-for-the-exam pattern.  Despite full knowledge and disclosure of the due dates and subject material, audit preparation largely consisted of ignoring it until the last minute, followed by a flurry of activity, stress, anxiety, and panic, with a fair bit of hoping and wishing-upon-a-star that the auditors won’t dig too deeply. There must be a better way to be prepared and execute (hint: there is)!

There are some key differences between school exams and business audits:

  • Audits are open-book: the subject matter details and success criteria are well-defined and well-known to everyone
  • Audits have subject matter and success criteria that remains largely unchanged from one audit to the next

Given these differences, it would seem logical that preparation for audits should be easy. We know exactly what the audit will cover, we know when it will happen, and we know what is required to pass.  If only it was that easy.  Why, then, do we still cram-for-the-exam and wait to the last minute?  I think it comes down to these things:

  • Audits are important, just like everything else
  • The scope of the material seems too large
  • Our business memory is short

Let’s look at that last one first.  Audits tend to be infrequent, often with months or years going by before they come around again.  Like exam cramming, it seems that our main goal is to get over the finish line.  Once we are over that finish line, we tend to forget all about what we learned and did, and our focus turns to other things.  Additionally, the last-minute cram seems to be the only way to deal with the task at hand, given the first two points above.  Just get it done, and hope.

What if our annual audits were more frequent, like once a week?  The method of cramming is not sustainable or realistic.  How could we possibly achieve this?

Iteration.

Iteration is, by definition, a repetitive process that intends to produce a series of outcomes.  Both simple and complex problems can often be attacked and solved by iteration:

  • Painting a dark-colored room in a lighter color
  • Digging a hole with a shovel
  • Building a suspension bridge
  • Attempting to crack an encrypted string
  • Achieving a defined compliance level in complex IT systems

Note that last one: achieving audit compliance within your IT ecosystem can be an iterative process, and it doesn’t have to be compressed into the 5 days before the audit is due.

The iteration (repetitive process) is simple:

The scope and execution of the iteration is where things tend to break down.  The key to successful iterations starts with defining and setting realistic goals. When in doubt, keep the goals small!  The idea here is being able to achieve the goal repeatedly and quickly, with the ability to refine the process to improve the results.

Define

We need to clearly define what we are trying to achieve.  Start big-picture and then drill down into something much smaller and achievable.  This will accomplish two things: 1) build some confidence that we can do this, and 2) using what we will do here, we can “drill up” and tackle a similar problem using the same pattern.   Here is a basic example of starting big-picture and drilling down to an achievable goal:

Identify and Recognize

Given that we are going to monitor failed user logons, we need a way to do this.  There are manual ways to achieve this, but, given that we will be doing this over and over, it’s obvious that this needs to be automated.  Here is where tooling comes into play.  Spend some time identifying tools that can help with log aggregation and management, and then find a way to automate the monitoring of failed network user authentication logs.

Notify and Remediate

Now that we have an automated way to aggregate and manage failed network user authentication logs, we need to look at our (small and manageable) defined goal and perform the necessary notifications and remediations to meet the requirement.  Again, this will need to be repeated over and over, so spend some time identifying automated tools that can help with this process.

Analyze and Report

Now that we are meeting the notification and remediation requirements in a repeatable and automated fashion, we need to analyze and report on the effectiveness of our remedy and, based on the analysis, make necessary improvements to the process, and then repeat!

Now that we have one iterative and automated process in place that meets and remedies an audit requirement, there is one less thing that needs to be addressed and handled when the audit comes around.  We know that this one requirement is satisfied, and we have the process, analysis, and reports to prove it.  No more cramming for this particular compliance requirement, we are now handling it continuously.

Now, what about the other 1,000 audit requirements?   As the saying goes, “How do you eat an elephant (or a Buick)?  One bite at a time.”  You need the courage to start, and from there every bite gets you one step closer to the goal.

Keys to achieving Continuous Compliance include:

  • You must start somewhere. Pick something!
  • Start big-picture, then drill down to something small and achievable.
  • Automation is a must!

For help getting started on the road to continuous compliance, contact us.

-Jonathan Eropkin, Cloud Consultant

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Continuous Compliance – Automatically Detect and Report Vulnerabilities in your Cloud Enterprise

Customers are wrangling with many challenges in managing security at scale across the enterprise. As customers embrace more and more cloud capabilities across more providers, it becomes daunting to manage compliance.

The landscape of tools and providers is endless, and customers are utilizing a mix of traditional enterprise tools from the past along with cloud tools to try to achieve security baselines within their enterprise.

At 2nd Watch we have a strong partnership with Palo Alto Networks, which provides truly enterprise-grade security to our customers across a very diverse enterprise landscape – datacenter, private cloud, public cloud and hybrid – across AWS, Azure and Google Cloud Platform.

Palo Alto Networks acquired a brilliant company recently – Evident.io. Evident.io is well known for providing monitoring, compliance and security posture management to organizations across the globe. Evident.io provides continuous compliance across AWS and Azure and brings strong compliance vehicles around HIPAA, ISO 27001, NIST 800-53, NIST 900-171, PCI and SOC 2.

The key to continuous compliance lies in the ability to centralize monitoring and reporting as well as insight into one console dashboard where you can see, in real time, the core health and state of your cloud enterprise.

This starts with gaining core knowledge of your environment’s current health state. You must audit, assess and report on where you currently stand in terms of scope of health. Knowing current state will allow you to see the areas where you need to correct and will also open insight into compliance challenges. Evident.io automates this process and allows for automated, continuous visibility and control of infrastructure security while allowing for customized workflow and orchestration, which allows clients to tune the solution to fit specific organizational needs and requirements easily and effectively.

After achieving the core insight of current state of compliance, you must now work on ways to remediate and efficiently maintain compliance moving forward. Evident.io provides a rich set of real-time alerting and workflow functionality that allows clients to achieve automated alerting, automated remediation and automated enforcement. Evident.io employs continuous security monitoring and stores the data collected in the evident security platform, which allows our clients to eliminate manual review and build rich reporting and insight into current state and future state. Evident.io employs a rich set of reporting capabilities out of the box, across a broad range of compliance areas, which helps to report compliance quickly and address existing gaps and reduce and mitigate risk moving forward.

Evident.io works through API on AWS and Azure in a read-only posture. This provides a non-intrusive and effective approach to core system and resource insight without the burden of heavy agent deployment and configuration. Evident Security Platform acquires this data through API securely and analyzes it against core compliance baselines and security best practices to ensure gaps in enterprise security are corrected and risk is reduced.

Continuous Compliance requires continuous delivery. As clients embrace the cloud and the capabilities the cloud providers provide, it becomes more important then ever before that we institute solutions that help us manage against continuous software utilization and delivery. The speed of the cloud requires a new approach for core security and compliance, one that provides automation, orchestration and rich reporting to reduce the overall day-to-day burden of managing towards compliance at scale in your cloud enterprise.

If you are not familiar with Evident.io, check them out at http://evident.io, and reach out to us at 2nd Watch for help realizing your potential for continuous compliance in your organization.

-Peter Meister, Sr Director of Product Management

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Assessing your cloud environment and maintaining a baseline security posture

The cloud is an exciting place, where the realization of instant implementation and execution of enterprise applications and workloads at scale is achieved. As we move to utilize the cloud we tend to utilize already existing applications and operating systems that are baked into the cloud service provider’s frame. Baseline images and cloud virtual machines are readily available, and we quickly utilize these images to put our infrastructure in motion in the cloud. This presents some challenges in terms of security, as we tend to deploy first and secure second, which is not ideal from a proactive security stance.

Continuous deployment is becoming the normality. We are literally updating and changing our systems many times a day now in the cloud. New features become available and new ISV applications and services roll out on a continuous basis, and we leverage them rapidly.

To maintain a healthy cloud state for our infrastructure and applications, we need to focus our attention on managing towards a baseline configuration state and desired state configuration for our systems. We need to monitor, maintain and continuously be aware of our systems’ state of health and state of configuration at any given time.

Clients are evolving so quickly in the cloud that they end up  playing catchup on the security side of their cloud environment.  One way to support a proactive level of security for your cloud environment is to perform continuous vulnerability, assessment and remediation activities on a regular basis to ensure all areas of your cloud environment meet a baseline of security.

The cloud service providers are doing a lot of heavy lifting to support you to achieve a proactive security architecture, and they provide many different layers of tools and technologies to help you achieve this.

The first area to focus on is your machine library. Maintaining a secure baseline image scope across the catalog of your infrastructure and applications will ensure you can track and maintain those image states per role of operation. This helps to ensure that when the cataloged healthy state image takes an un-approved change, you become instantly aware of it and can roll back to a healthy image state, undo any compromises to image integrity and return to a secure and compliant operating state.

AWS has a great tool that helps us maintain configuration state management. AWS Config allows you to audit, evaluate and assess configuration baselines of your cloud resources continuously. It provides strong monitoring of your AWS resource configurations and support evaluating the state against your secure baseline and ensuring your desired state is maintain and recovered. It gives you the ability to quickly review changes to configuration state and how that state changes across the broad set of resources that make up your infrastructure or application.

It provides deep insight and details around resources, resource historical records and configuration and supports strong capabilities around compliance, specifically for your organization and specified resource guidelines.

Utilizing tools such as AWS Config provides you a strong first step in the path to achieving continuous security baseline protection and managing against vulnerabilities and unwarranted changes to your resources in production. Outside of AWS Config, AWS provides a strong suite of tools and technologies to help us achieve a more comprehensive security baseline. Check out Amazon System Manager, which supports a common agent topology across Windows and Linux with the SSM agent to support clients scanning and maintaining resource health and information continuously – not to mention it’s a great overall agent to maintain core IT operations management in AWS. We can maintain strong operational health of our cloud resources in AWS with Amazon CloudWatch.

One recent addition for security is Amazon GuardDuty, which provides intelligent threat detection and continuously monitors to protect your AWS accounts and workloads. Amazon GuardDuty is directly accessible through the amazon console and, with a few clicks, can be fully implemented to help support your workload protection proactively.

If you need assistance in achieving strong continuous security for your AWS cloud environment, 2nd Watch offers services to help our clients realize the security posture within their cloud environment today. We can also help create and customize a vulnerability, assessment and remediation strategy that will have long standing benefits in continuously achieving strong security defense in depth in the cloud.

-Peter Meister, Sr Director of Product Management

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