Cloud Computing Risk Assessments Donald Gallien March 31, 2011

2 Overview Cloud Computing Refresher Assessing Cloud Computing Universe Completeness Using a Cloud Computing Risk Ranking Model Risk Ranking Case Study

3 Quiz What do the following have in common? –Paisley GRC –Salesforce.com –Amazon EC2 –Google Apps –Microsoft Business Productivity Online Suite (BPOS) –Rackspace –WebEx

Cloud Computing Refresher

5 Cloud Computing Basics Internet-based computing, whereby shared resources, software and information are provided to computers and other devices on- demand, like the electricity grid (Source: Wikipedia) Based on virtualization and abstraction of the underlying infrastructure IT Audit Risk is largely driven by: –Deployment Model –Service Model –Nature of Applications & Data in Cloud

6 Deployment Models ModelDefinitionExample PublicAvailable to the general public or a large industry group Google Apps (Free) CommunityShared by several organizations and supports a specific community that has shared concerns Google Apps for Government PrivateOperated solely for an organization Microsoft BPOS for a Business Source: NIST

7 Service Models ModelDefinitionExample Infrastructure as a Service (IaaS) Fundamental computing resources to deploy software, including OS and applications Rackspace Cloud Platform as a Service (PaaS) Applications based on programming languages and tools supported by the cloud provider Force.com Software as a Service (SaaS) Cloud provider applications running on a cloud infrastructure Salesforce. com (CRM) Source: NIST

8 Another Way to Look as Service Models SaaS PaaS IaaS WebEx BPOS Amazon EC2 Provider Control Example

9 Deployment Model Risk Profile HigherLower PublicPrivateCommunity Likelihood of Data Security, Privacy, and Control Breach

10 Service Model Risk Profile HigherLower IaaSSaaSPaaS Impact of Loss of Control & Security Breach

11 Cloud Refresher Summary Public clouds are inexpensive, but provide less security and service Private clouds are expensive, but align better with technology and security standards IaaS models are very broad in scope, but organizations maintain more control SaaS models are narrow in scope, but organizations relinquish almost all control What is the impact of cloud computing on the IT audit function?

12 But one thing never changes All IT Audit and Governance groups must: 1.Identify an Universe 2.Risk Rank the Universe 3.Provide Appropriate Coverage based on Risk

Assessing Cloud Computing Universe Completeness

14 The Cloud Universe Challenge Cloud DynamicFlexibleTransientAbstract Rapidly Deployed

15 Finding the Clouds Technology Governance Firewalls & Encryption Certificates Invoices / Time & Expense Reporting Process Walkthroughs Control Points

16 Technology Governance Oversight Technology Approvals Partner Approvals How does your organization promote controlled cloud computing?

17 Firewalls and Encryption Certificates Firewall & VPN Rule Changes Firewall Logs Encryption Certificate Requests Cloud computing environments are unlikely to stand-alone.

18 Invoices / T&E Reporting Vendor Master Invoice Lists T&E Reporting How much does it cost to deploy cloud based service at Google?

19 Process Walkthroughs Business Process Data Flow Technology Overview Has anyone discovered cloud based computing in a walkthrough meeting?

20 Summary – Universe Completeness Cloud computing can be difficult to identify Traditional technology governance, security, and procurement controls can be used to identify cloud computing Users and business analysts could be your best source of cloud computing information What else can you do to identify cloud computing?

Using a Cloud Computing Risk Ranking Model

22 A few thoughts before we start Risk models include elements of judgment and must fit the organization Some model assumptions may be completely wrong for your organization – We should have a lot of debate on this topic Risk ranking scores must drive governance requirements and audit activities

23 Cloud Risk Ranking Example

24 Potential Governance & Audit Requirements

25 Deployment Model Considerations HighMediumLow Deploy Model PublicCommunityPrivate - Security and privacy are not a priority - Service level agreements may not exist - Private environments provide adequate security and privacy - Service level agreements should exist Public Private

26 Service Model Considerations HighMediumLow Service Model IaaSPaaSSaaS - Issues may impact all hosted applications and data - No control over foundational general controls - PaaS - Impact limited to outsourced platform - SaaS - Impact limited to applications and data IaaS SaaS

27 Data Security Considerations HighMediumLow Security Level SecretRestrictedUnclassified - Difficult to enforce security standards when outsourcing - Difficult to demonstrate compliance with regulations like GLBA - Security and privacy is not a concern (good candidate for cloud computing) Secret Unclassified

28 Physical Hosting Site Considerations HighMediumLow Hosting Site UndefinedInternational Location Domestic Location - May result in cross border data protection regulatory issues - Difficult to demonstrate compliance with regulations like GLBA - Minimizes concerns about cross border data protection regulations Undefined Domestic Location

29 SOX Criticality Considerations HighMediumLow SOX Critical YesNo - SAS 70 reports may not cover SOX critical application controls - Business units may not have visibility or access to test SOX controls - Non SOX critical applications may be good candidates for cloud computing Yes No

30 Dependent Applications HighMediumLow Number of Apps Greater than 104 to 9Less than 3 - Implies complexity and greater organizational significance - Implies simplicity and less organizational significance > 10 < 3

31 Recovery Time Objectives (RTO) Considerations HighMediumLow RTO4 Hours7 days31 Days Implies increased business importance Cloud provider may lack geographic diversity Single points of failure may exist in network Implies lower business importance - good candidate for cloud computing 4 Hours 31 Days

32 Regions Supported Considerations HighMediumLow RegionEurope or Global United StatesAll Other - Strictest cross border data protection regulations – can be at odds with abstract cloud computing - “Other” countries may have less restrictive cross border data protection regulations Europe / Global All Other

33 Summary – Cloud Risk Ranking Models Cloud risk ranking attributes and scoring must vary based on environment and need Risk attributes and scoring require alignment with organizational standards What other risk attributes might you use, and how would your rank them on a high, medium, low basis?

Risk Ranking Case Study

35 Conclusions Business and technology leaders are embracing cloud computing - it is here to stay and growing Cloud computing standards and risk ranked cloud universes are foundational requirements for governance We must adjust our approach to remain relevant

36 Questions Contact Information: