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