Cloud compliance, cloud security…NOT the same thing. Victoria Geronimo, Security & Compliance Product Manager at 2nd Watch who also happens to have an internet law and internet policy background, joins us today as we look at how security, compliance, and state regulations affect architecting your cloud environment and the farther-reaching effects they have on business. We’d love to hear from you! Email us at CloudCrunch@2ndwatch.com with comments, questions and ideas. Listen now on Spotify, iTunes, iHeart Radio, Stitcher, or wherever you get your podcasts.
In the world of IT, disasters come in all shapes and sizes from infrastructure and application outages, to human error, data corruption, ransomware, malicious attacks, and other unplanned events. Other than perhaps a hurricane or blizzard, we often don’t have visibility into when a disaster will occur. After the immediate impact of the disaster subsides, the focus rapidly shifts to the recovery.
At the core of the disaster recovery is a focus on how quickly applications and data can be restored to resume servicing your customers. Downtime means a loss of productivity, revenue, or even profit from credits being paid out to your customers for failure to maintain service.
But disaster recovery goes well beyond the post-crisis events, and its success hinges on the preparation done well in advance of any disaster occurring. Now, a disaster recovery strategy should not be confused with a business continuity plan. A business continuity plan is far greater in scope, covering not only recovering your IT systems, data, and applications to service customers again, but how to continue running your business even beyond IT system disruptions. For example, a business continuity plan will outline what steps to take when the physical building becomes unavailable and your employees can’t come into the office; how to handle supply chain disruptions, etc.
When discussing disaster recovery strategies, often times back-up and disaster recovery are used synonymously. Back-up should factor into your business continuity planning, and in some cases a back-up may be sufficient in restoring your systems and meeting compliance requirements. However, back-ups are a point-in-time solution and can take significant time to restore your systems, delaying your recovery time. Compounding this dilemma, back-ups are only as up to date as the last snapshot taken, which, for many, could mean losing a complete day’s worth of sales. A solid disaster recovery strategy should not only focus on recovering your systems but do it in a manner that exceeds the business requirements and minimizes the disruption your customers.
Traditional disaster recovery solutions have really required significant investment from both a financial perspective and a human resource perspective. It’s not unusual for enterprises to be required to purchase fully redundant hardware and duplicative software licenses, locate that hardware in geographically disbursed colo facilities, set-up connectivity and replication between the two sites, and have IT admins maintain the second site, which is commonly under-utilized.
Cloud based disaster recovery has solved many of these problems and can do it for a fraction of the price. To help bring this solution to our customers, 2nd Watch has partnered with CloudEndure, an AWS Company, to help enterprises accelerate their adoption of Cloud Disaster Recovery.
The CloudEndure Disaster Recovery solution replicates everything in real time, meaning everything is always up to date, down to the second, allowing you to achieve your Recovery Point Objectives (RPOs). CloudEndure provisions a very low-cost staging area in AWS, eliminating the need for duplicate resource provisioning. Should a disaster occur, automated orchestration combined with machine conversion enables you to achieve a Recovery Time Objectives (RTOs) of minutes and only pay for the cloud instances when actually needed.
Our Cloud Disaster Recovery service provides you a disaster recovery proof of concept for 100 machines in less than 30 days, while allowing you to continue to leverage your entire existing infrastructure. We apply our proven methodology to ensure your organization is getting optimal value from your existing infrastructure while allowing fast, easy, and cost-effective recovery in the AWS cloud.
Download our datasheet to learn more about our Cloud Disaster Recovery service.
-Dusty Simoni, Sr Product Manager
DevSecOps is a misnomer. Smashing Security in between Dev and Ops is the wrong way to think about optimizing your DevOps + Security pipeline. Some tend to believe security is a blocker to getting new applications out to production. Owned by some distant, unapproachable team, security can seem like the new deep divide with a ‘throw it over the wall’ mentality.
Security must be sprinkled throughout the DevOps cycle, taught from the beginning when developing best practices and automating compliant infrastructure and owned by both DevOps and Security, working together as a team.
We’ve said it before, and we’ll say again. A true DevSecOps Transformation includes an evolution of your company culture, automation and technology, processes, collaboration, measurement systems, and organizational structure.
A DevSecOps transformation can help you:
- Deliver software faster and more securely
- Enable collaboration with cross-functional teams
- Improve software and operations quality
- Create a culture of automated, secure processes
- Improve your cloud security posture
2nd Watch has developed a DevSecOps Assessment and Strategy solution to help you target the critical areas for DevSecOps improvement – people, processes, and technology – and develop a roadmap to kickstart your DevSecOps transformation. To learn more about this solution, download our datasheet for details.
-Victoria Geronimo, Product Manager, Security & Compliance
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.
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
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
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:
- 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.
- 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.
- 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