Cloud Automation for I.T. Governance, Risk, and Compliance (GRC) in Healthcare

It has been said that the “hero of a successful digital transformation is GRC.” The ISACA website states, “to successfully manage the risk in digital transformation you need a modern approach to governance, risk and regulatory compliance.” For GRC program development, it is important to understand the health information technology resources and tools available to enable long term success.

What is GRC and why it important?

According to the HIPAA Journal, the average cost of a healthcare data breach is now $9.42 million. In the first half of 2021, 351 significant data breaches were reported, affecting nearly 28 million individuals. The needs have never been more acute among healthcare providers, insurers, biotechnology and health research companies for effective information security and controls. Protecting sensitive data and establishing a firm security posture is essential.  Improving health care and reducing cost relies on structured approaches and thoughtful implementation of available technologies to help govern data and mitigate risk across the enterprise.

Effective and efficient management of governance, risk, and compliance, or GRC, is fast becoming a business priority across industries. Leaders at hospitals and health systems of all sizes are looking for ways to build operating strategies that harmonize and enhance efforts for GRC. Essential to that mission are effective data governance, risk management, regulatory compliance, business continuity management, project governance, and security. But rather than stand-alone or siloed security or compliance efforts, a cohesive program coupled with GRC solutions allow for organizational leaders to address the multitude of challenges more effectively and efficiently.

What are the goals for I.T. GRC?

For GRC efforts, leaders are looking to:

  • Safeguard Protected Healthcare Data
  • Meet and Maintain Compliance to Evolving Regulatory Mandates and Standards
  • Identify, Mitigate and Prevent Risk
  • Reduce operational friction
  • Build in and utilize best practices

Managing governance, risk, and compliance in healthcare enterprises is a daunting task. GRC implementation for healthcare risk managers can be difficult, especially during this time of rapid digital and cloud transformation. But relying on internal legacy methods and tools leads to the same issues that have been seen on-premises, stifling innovation and improvement. As organizations adapt to cloud environments as a key element of digital transformation and integrated health care, leaders are realizing that now is the time to leverage the technology to implement GRC frameworks that accelerate their progress toward positive outcomes. What’s needed is expertise and a clear roadmap to success.

Cloud Automation of GRC

The road to success starts with a framework, aligned to business objectives, that provides cloud automation of Governance, Risk, and Compliance. Breaking this into three distinct phases, ideally this would involve:

  1. Building a Solid Foundation – within the cloud environment, ensuring infrastructure and applications are secured before they are deployed.
  • Image/Operation System hardening automation pipelines.
  • Infrastructure Deployment Automation Pipelines including Policy as Code to meet governance requirements.
  • CI/CD Pipelines including Code Quality and Code Security.
  • Disaster Recovery as a Service (DRaaS) meeting the organization’s Business Continuity Planning requirements.
  • Configuration Management to allow automatic remediation of your applications and operating systems.
  • Cost Management strategies with showback and chargeback implementation.
  • Automatic deployment and enforcement of standard security tools including FIM, IDS/IPS, AV and Malware tooling.
  • IAM integration for authorization and authentication with platforms such as Active Directory, Okta, and PingFederate, allowing for more granular control over users and elevated privileges in the clouds.
  • Reference Architectures created for the majority of the organization’s needs that are pre-approved, security baked-in to be used in the infrastructure pipelines.
  • Self-service CMDB integration with tools such ServiceNow, remedy and Jira ServiceDesk allowing business units to provision their own infrastructure while providing the proper governance guardrails.
  • Resilient Architecture designs
  1. Proper Configuration and MaintenanceInfrastructure misconfiguration is the leading cause of data breaches in the cloud, and a big reason misconfiguration happens is infrastructure configuration “drift,” or change that occurs in a cloud environment post-provisioning. Using automation to monitor and self-remediate the environment will ensure the cloud environment stays in the proper configuration eliminating the largest cause of incidents. Since workloads will live most of their life in this phase, it is important to ensure there isn’t any drift from the original secure deployment. An effective program will need:
  • Cloud Integrity Monitoring using cloud native tooling.
  • Log Management and Monitoring with centralized logging, critical in a well-designed environment.
  • Application Monitoring
  • Infrastructure Monitoring
  • Managed Services including patching to resolve issues.
  • SLAs to address incidents and quickly get them resolved.
  • Cost Management to ensure that budgets are met and there are no runaway costs.
  • Perimeter security utilizing cloud native and 3rd party security appliance and services.
  • Data Classification
  1. Use of Industry Leading Tools – for risk assessment, reporting, verification and remediation. Thwart future problems and provide evidence to stakeholders that the cloud environment is rock solid. Tools and verification components would include:
  • Compliance reporting
  • Risk Registry integration into tools
  • Future attestations (BAAs)
  • Audit evidence generation

Where do you go from here?

Your organization needs to innovate faster and drive value with the confidence of remaining in compliance. You need to get to a proactive state instead of being reactive. Consider an assessment to help you evaluate your organization’s place in the cloud journey and how the disparate forms of data in the organization are collected, controlled, processed, stored, and protected.

Start with an assessment that includes:

  • Identification of security gaps
  • Identification of foundational gaps
  • Remediation plans
  • Managed service provider onboarding plan
  • A Phase Two (Foundational/Remediation) proposal and Statement of Work

About 2nd Watch

2nd Watch is a trusted and proven partner, providing deep skills and advisory to leading organizations for over a decade. We earned a client Net Promoter Score of 85, a good way of telling you that our customers nearly always recommend us to others. We can help your organization with cloud native solutions. We offer skills in the following areas:

  • Developing cloud first strategies
  • Migration of workloads to the cloud
  • Implementing automation for governance and security guardrails
  • Implementing compliance controls and processes
  • Pipelines for data, infrastructure and application deployment
  • Subject matter expertise for FHIR implementations
  • Managed cloud services

Schedule time with an expert now, contact us.

-Tom James, Sr. Marketing Manager, Healthcare

Why You Should Invest in Managed Cloud Security Services

Cloud adoption throughout all industries has become incredibly pervasive in recent years. With cloud management as a relatively newer concept, business organizations may struggle to understand each aspect that is required to effectively run a cloud environment. One aspect that should be involved at every layer of the cloud is security, yet many organizations fail to implement a strong security system in their cloud until an attack happens and it is too late.

A cloud environment and the controls necessary to orchestrate a robust security and governance platform is not the same as your traditional on-premises environment.

The State of Cloud Security Today

As beneficial as the public cloud is for companies globally today, lack of security in the cloud can be a major issue. A report from Sophos indicated that iMost of these attacks are simply from misconfigurations of these organizations’ cloud security. Thus, the attacks can be prevented if configured and managed properly. Orca Security’s 2020 State of Public Cloud Security Report revealed that 80.7% of organizations have at least one neglected, internet-facing workload – meaning the OS is unsupported or unpatched. Attackers can use one small vulnerability as leverage to move across an organization, which is how most data breaches occur.

Managed cloud security services help lay a strong foundation for security in the cloud that is automated and continuous with 24/7 management. With constant management, threats and attacks are detected before they occur, and your business avoids the repercussions that come with security misconfigurations.

What are managed cloud security services?

Managed cloud security services provide security configurations, automation, 24/7 management, and reporting from an external cloud security provider. If an attack should occur, the result is downtime and the loss of money and data. Additionally, the lack of a well-rounded security system can lead to regulatory compliance challenges.

Monitoring and maintaining strong security requires continuous attention to be effective. Employing a managed security service gives businesses the protection they need while simultaneously providing IT departments with additional time to focus on other business concerns. Redirecting cybersecurity efforts to an external provider not only provides IT departments with flexibility, but also reduces costs compared to handling cybersecurity in house. Managing cybersecurity independently creates costs such as staffing, software licensing, hardware, implementation costs, and management costs. All the costs and management required for effective security can be overwhelming and managed security services takes the weight of maintaining the security of your data off your shoulders.

What are the benefits of using cloud security services?

Implementing strong cloud security may seem like an obvious choice for a business to make, but many businesses may not want to devote the time, resources, or money to building and maintaining a strong cybersecurity system. Investing your resources into cloud security is imperative for your business and pays off in the long run.

Five different benefits resulting from a strong cloud security system include:

  • Automation: Once your configurations have been set up, there is reduced reliance on human intervention. This minimizes time spent managing security while also reducing the risk for error.
  • Efficiency: Cloud services improve the security of your data and maintain regulatory compliance through timely patching and automated updates with less downtime.
  • Safety: Data is well-protected with cloud security due to 24/7 monitoring and real-time threat detection.
  • Proactive Defense: Threats are identified quickly and treated proactively in the cloud should an incident occur.
  • Cost-effective: The cloud requires a unique approach to security. While managed cloud security services can seem costly upfront, they prove to be worthwhile in the long run by utilizing expertise that may not be available in-house. Additionally, cloud security services will ensure the safety of your workloads and data, and prevent the costs associated with a data breach.

2nd Watch Managed Cloud Security

At 2nd Watch, we understand cloud security is important at every step of your cloud journey. 2nd Watch has a dedicated Managed Security Team that monitors your cloud environments 24/7/365, remediating vulnerabilities quickly. Rather than putting security on the backburner, we believe security is a pillar of business, and building it into the foundation of a company is important to meet evolving compliance needs in a cost-effective manner.

Companies just getting started in the cloud can rely on 2nd Watch to get security right for them the first time. Even for companies already established in the cloud, we can take an in-depth look at security and compliance maturity, existing capabilities, and growth trajectory to provide a prescriptive security roadmap. No matter where you are in your cloud journey, we ensure your security is well-integrated into your cloud environments.

At 2nd Watch we are with you from beginning to end, monitoring your security even after implementation. At a glance, our end-to-end services include:

  • Security Review: Ensures the proper safeguards are utilized for your multi-cloud environments with a single point of contact for your security needs. Our security assessment and remediation offering can reveal how your cloud security posture stacks up to industry standards such as CIS, GDPR, CCPA, HIPAA, NIST, PCI DSS, and SOC 2.
  • Environment Monitoring: 24/7/365 multi-cloud monitoring protects against the most recent vulnerabilities.
  • Threat Analysis: Managed Reliability Operations Center (ROC) proactively analyzes and remediates potential threats.
  • Issue Resolution: Identified issues are quickly resolved providing enterprise class and proactive defense.

Other solutions we provide include:

Security should be integrated into every layer of your public cloud infrastructure. We can help you achieve that through our comprehensive suite of security services and a team of experts that cares about your success in the cloud. To learn more about our managed cloud security services, visit our Cloud, Compliance, Security, & Business Continuity page or talk to someone directly through our Contact Us page.

-Tessa Foley, Marketing

Cloud Governance: Why It Is Critical to the Success of Cloud Adoption

According to a 2019 report by Unisys, 37% of all cloud adoption initiatives fail to realize their objectives.

The report, although disturbing, is not shocking by any measure. Although businesses continue to migrate to the cloud, many have failed to make it a core part of their business strategy. The reasons for this vary – poorly trained staff, inability to utilize cloud resources effectively, or the absence of a strategy that leverages the power of cloud.

For these reasons and many others, businesses incur unexpected costs, unproductive workflows, and cybersecurity risks to their data on the cloud. These organizations need a set of protocols for utilizing cloud resources efficiently, effectively, and securely. In short, they need a cloud governance framework that enables them to extract the benefits of the cloud.

Organizations can fully realize these benefits only when their cloud policies are designed to leverage them. Therefore, a well-designed cloud governance framework is critical to the success of cloud adoption. What is cloud governance and how does it lay the foundation for the success of your cloud adoption?

Download our white paper to learn about the role of cloud governance in successful cloud adoption.

-Mir Ali, Field CTO

3 Security and Compliance Must-Haves to Meet Any Regulation

The security processes and controls you put in place must meet the compliance standards required for your industry. Whether it’s GDPR, CCPA, or any other state, federal, or industry specific regulation, there are at least three things you need to do to meet the minimum requirements. Of course, each regulation comes with its unique conditions, but these are the first steps to take when moving toward a more secure and compliant environment.

1. Data discovery and data mapping

Most of the compliance standards today surround the data an organization collects from consumers. The first step to understanding your data, for both compliance and to inform decision making, is to collect and analyze all of your data from the various sources it originates. In addition to data discovery, you need to have a process for data mapping as well. Data mapping matches the data fields of data from one database to another.

It’s important to have data flows so you know how your data gets to you, how it’s entered into various systems, what resources it hits, and where it finally ends up. Knowing, at every point, were your data lives is the key first step, regardless of which law you need to comply with.

A strict tagging strategy that is uniform and specific across departments aids in ongoing data mapping. Review your strategy regularly to make sure your teams are following it and it still works as expected with any advancements made in the data you’re collecting. You can also use the tools available through cloud providers to help with these governance tasks. Some recommended tools include Amazon Macie and AWS Config, as well as Azure Security Center.

2. Notification and purge mechanisms with identity validation and an audit trail

A person’s data belongs to them, regardless of which company holds it. In order to field data requests from consumers, you need to have some sort of notification mechanism that allows you to understand and deliver what the consumer wants. They may want to know what data you have and how it is being used. People may want to update inaccurate data or, depending on the regulations in your area, they may request that it be deleted.

In order to fulfil a consumer’s request to delete or update data, you need a purge mechanism. A purge mechanism clears data once such action has been approved. In order to complete any data request, you must first validate the identity of the requesting consumer.

While this step is necessary, there is not yet an industry gold standard on how best to verify data without threatening the personal information provided. Additionally, data requests need to be checked against any compliance exceptions that may complicate your ability to do what the consumer wants. You may need the data because the person is still using your services, or, depending on the compliance standards you adhere to, you may be required to maintain certain pieces of data for a set period of time.

Meeting consumer requests for data management can be tricky depending on the compliance standards in your location and industry. A proper audit trail that proves your best attempt at compliance is critical, should a lawsuit or formal complaint ever come your way. Hopefully all of these processes will be automated through machine learning one day, but for now, notification and purge mechanisms, identity validation, and a comprehensive audit trail are the most important factors in proving compliance.

3. Encryption

Data is the life blood of most organizations and it needs to be protected. Simply put, encrypt everything! Additionally, make sure your identity and access management (IAM) policies are up to date. The most common vulnerabilities are problems with an organization’s IAM. There might be an abundance of keys spread across the business or keys might not have been rotated regularly. Unauthorized employees might have admin credentials, or there’s no incident response policy in place.

If your data is breached, either by cyber attack or human error, you need a process to get servers back up and running again as soon as possible. You also need to preserve the evidence of the attack, or accidental deletion, in order to prevent a recurrence. Don’t assume your data is safe, instead, be ready to quickly recover from data loss.

While these three necessities are required for most compliance standards, there are certainly more you need to be following. Let 2nd Watch provide a prescriptive security roadmap to ensure compliance no matter where your business is going. You can also take advantage of our four-phased security assessment that runs an automatic skim of your environment to identify vulnerabilities. Contact Us to make sure the next step you take in your cloud journey is a compliant one.

-Chris Garvey, EVP of Product

Cloud Crunch Podcast: Unraveling Cloud Security, Compliance and Regulations

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.

Cloud DR: Recovery Begins Well Before Disaster Strikes

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

Your Gameplan for Uniting DevOps and Security

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

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

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

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