1. Certified Authorization Professional Donald E. Hester
Understanding FISMA &
(ISC)2 CAP
Certified Authorization
Professional
Donald E. Hester
CISSP, CISA, CAP, CRISC, MCT, MCITP, MCTS,
MCSE Security, Security+, CTT+ 1

2. Beyond The Six Steps in the RMF
Categorize
Select
Implement
Assess
Authorize
Monitor

3. Federal Cloud Computing Strategy “Cloud First policy”
Image: NASA
Federal Cloud Computing Strategy, Vivek Kundra US CIO, 8 FEB 2011
Federal Cloud Computing Strategy “Cloud First policy”
Image: NASA

4. What is Cloud Computing?
The “Cloud”
Buzz word
Overused cliché
Ill defined
Many different definitions
Marketing term
All hype
The “unknown path”
Service provider “____-as-a-service”
Nebulous
Image: NASA

5. Definition
“..[a] model for enabling convenient, on-demand network access to a shared pool of configurable computing resources (e.g. networks, servers, storage, applications, services) that can be provisioned and released with minimal management effort or service provider interactions.”
NIST & Cloud Security Alliance
A utility model of technology delivery.
Photo by Donald E. Hester all rights reserved
NIST SP

6. Definition
According to NIST the cloud model is composed of five essential characteristics, three service models, and four deployment models.
Photo by Donald E. Hester all rights reserved
NIST SP

7. Essential Characteristics
On-demand self-service, customer driven utility
Broad network access, using standard networking
Resource pooling, economies of scale
Rapid elasticity, dynamic provisioning and releasing
Measured service, the ability to measure usage
Essential Characteristics:
On-demand self-service. A consumer can unilaterally provision computing capabilities, such as server time and network storage, as needed automatically without requiring human interaction with each service provider.
Broad network access. Capabilities are available over the network and accessed through standard mechanisms that promote use by heterogeneous thin or thick client platforms (e.g., mobile phones, tablets, laptops, and workstations).
Resource pooling. The provider’s computing resources are pooled to serve multiple consumers using a multi-tenant model, with different physical and virtual resources dynamically assigned and reassigned according to consumer demand. There is a sense of location independence in that the customer generally has no control or knowledge over the exact location of the provided resources but may be able to specify location at a higher level of abstraction (e.g., country, state, or datacenter). Examples of resources include storage, processing, memory, and network bandwidth.
Rapid elasticity. Capabilities can be elastically provisioned and released, in some cases automatically, to scale rapidly outward and inward commensurate with demand. To the consumer, the capabilities available for provisioning often appear to be unlimited and can be appropriated in any quantity at any time.
Measured service. Cloud systems automatically control and optimize resource use by leveraging a metering capability1 at some level of abstraction appropriate to the type of service (e.g., storage, processing, bandwidth, and active user accounts). Resource usage can be monitored, controlled, and reported, providing transparency for both the provider and consumer of the utilized service.
NIST SP

8. “____-as-a-service” (Service Models)
Software-as-a-Service (SaaS)**
Platform-as-a-Service (PaaS)**
Infrastructure-as-a-Service (IaaS)**
Communication-as-a-Service (CaaS)
Monitoring-as-a-Service (MaaS)
Security-as-a-Service (SECaaS)
Everything-as-a-Service (EaaS)
Anything-as-a-Service (XaaS)
Image: Microsoft Clip Art
Service Models:
Software as a Service (SaaS). The capability provided to the consumer is to use the provider’s applications running on a cloud infrastructure2. The applications are accessible from various client devices through either a thin client interface, such as a web browser (e.g., web-based ), or a program interface. The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, storage, or even individual application capabilities, with the possible exception of limited user-specific application configuration settings.
Platform as a Service (PaaS). The capability provided to the consumer is to deploy onto the cloud infrastructure consumer-created or acquired applications created using programming languages, libraries, services, and tools supported by the provider.3 The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, or storage, but has control over the deployed applications and possibly configuration settings for the application-hosting environment.
Infrastructure as a Service (IaaS). The capability provided to the consumer is to provision processing, storage, networks, and other fundamental computing resources where the consumer is able to deploy and run arbitrary software, which can include operating systems and applications. The consumer does not manage or control the underlying cloud infrastructure but has control over operating systems, storage, and deployed applications; and possibly limited control of select networking components (e.g., host firewalls).
** Defined by NIST

9. Cloud Flavors (Deployment Models)
Private Cloud
Operated solely for one organization
In-sourcing
Community Cloud
Operated for a group of similar organizations
Public Cloud
Outsourced
Multi-tenant
Hybrid Cloud
Combination of the above
Image: Microsoft Clip Art
• Private cloud. The cloud infrastructure is operated solely for an organization. It may be managed by the organization or a third party and may exist on premise or off premise.
• Community cloud. The cloud infrastructure is shared by several organizations and supports a specific community that has shared concerns (e.g., mission, security requirements, policy, and compliance considerations). It may be managed by the organizations or a third party and may exist on premise or off premise.
• Public cloud. The cloud infrastructure is made available to the general public or a large industry group and is owned by an organization selling cloud services.
• Hybrid cloud. The cloud infrastructure is a composition of two or more clouds (private, community, or public) that remain unique entities but are bound together by standardized or proprietary technology that enables data and application portability (e.g., cloud bursting for load-balancing between clouds).
This cloud model is composed of five essential characteristics, three service models, and four deployment models.

10. Image: Federal Cloud Computing Strategy, Vivek Kundra US CIO, 8 FEB 2011

11. Potential Spending on Cloud Computing
Image: Federal Cloud Computing Strategy, Vivek Kundra US CIO, 8 FEB 2011
“Cloud First policy. This policy is intended to accelerate the pace at which the government will realize the value of cloud computing by requiring agencies to evaluate safe, secure cloud computing options before making any new investments.” - Federal Cloud Computing Strategy, February 2011

12. Reasons Efficiency Agility Innovation
“Cloud First policy. This policy is intended to accelerate the pace at which the government will realize the value of cloud computing by requiring agencies to evaluate safe, secure cloud computing options before making any new investments.”
“…to be more efficient, agile, and innovative through more effective use of IT investments…”
Federal Cloud Computing Strategy, February 2011

13. Benefits Save time and money on provisioning new services
Less time spent on deployment
Move capital investment to operational expenses
Instant test bed
Enables IT systems to be scalable and elastic
Provision computing resources as required, on-demand
No need to own data center infrastructure (for public cloud service)

14. Benefits Energy saving (green) Better service
Increased utilization, less idle time
Cost based on usage
More effective use of capital resources ($)
Better service
Allows IT staff to focus on core competencies
Repurpose IT staff for more customer service
Outsource to esoteric experts
24/7 service and support
Economies of scale

15. Cloud Provider Benefits (NIST SP 800-144)
They will have specialized staff
The platform will typically be more uniform
They have the ability to scale and add redundancy
Better backup and recovery
May support a greater number of mobile devices
Data may be centralized and not on laptops

16. Benefits
Image: Federal Cloud Computing Strategy, Vivek Kundra US CIO, 8 FEB 2011

17. Cost Considerations Traditional Costs Cloud Costs Capital Expenses
Hardware (initial)
Software (initial)
Hardware repair/upgrades
Software upgrades
Staff costs
Energy costs
Training
Traditional Limits
Maximum load
Maximum up-time
Maximum users
MTTR
Dependencies
Cloud Costs
Operational Expenses
Cost per user
Cost by bandwidth/storage
Cost increase over time
Cost of additional services
Legal consultation costs
Staff costs
Training
Cloud limitations
Users
Bandwidth
Storage
Service Support
Dependencies
MTTR Mean-Time-To-Recover

18. Cost Benefit Analysis Example
Traditional Costs
TCO $21,000
Cloud Costs
TCO $22,850
This is somewhat similar to the ownership verse leasing calculation
Cloud Costs do not include the cost of Internet service or the cost if needed for more bandwidth
Savings in Up-front Costs

19. Cloud Risks Where’s My Data? The Bad Divorce Trust but Verify
“I thought you knew”
I didn’t think of that
Clarify
Consider
Expectations, Put it in Writing
Compatibility
Can you think of some risks not mentioned?

20. Where’s My Data? In the information age your key asset is information.
Some information requires protection
(Credit Card Data, Student Records, SSN, etc…)
Your information could be anywhere in the world
You may loss access to your data (availability)
ISP failure
Service provider failure
Failure to pay (service provider stops access)
Image: Microsoft Clip Art

21. The Bad Divorce “Vendor Lock” All relationships come to an end
Let you down, had a breach, SLA performance etc…
The company fails/gets sold
Introductory pricing or it goes up over time
Transition to new vendor or in-source
How will you get your data back?
Lack of Portability between PaaS Clouds
Example, something built for Google won’t work for SharePoint or Amazon
Get a prenup – get it in the contract up front
Image: Microsoft Clip Art

22. Trust but Verify Assurance
How do you know they are protecting your data?
Not everyone is treated the same by service providers
Disclosure concerning security posture
3rd party independent verification (audit/assessment)
SAS 70 / SSAE 16
SysTrust / WebTrust
ISO Certification
Audit / Assessment
MOU/MOA & ISA
Image: Microsoft Clip Art

23. “I thought you knew” Cloud systems are typically more complex
This may create a larger attack surface
Breach Notification
When do you want to know about a data breach?
(Data that you are legal obligated to protect)
Typical contracts give wide latitude for service providers
Actual verses possible breach
Timeliness of notification
Image: Microsoft Clip Art

24. I didn’t think of that Dependencies Other considerations
Infrastructure – Internet
Authentication management (SSO)
Operational budget
Greater dependency on 3rd parties
Other considerations
Complex legal issues
Multi-tenancy
Transborder data flow
Jurisdiction and Regulation
Support for Forensics
Image: Microsoft Clip Art

25. Clarify What do they mean by “Cloud”
Establish clear responsibilities and accountability
Your expectations
Cost of compensating controls
What will happen with billing disputes
Will your data be in a multi-tenant environment
What controls will you have
Image: Microsoft Clip Art

26. Consider The reputation of the service provider
Track record of issues
Large or small, likelihood of change
Vendor ‘supply chain management’ issues
The reliability of the service or technology
Is the technology time tested
Competency of cloud provider
Typically you have no control over upgrades and changes
Training for staff
Image: Microsoft Clip Art

27. Compatibility When will they upgrade their service?
Will they be ready when you are ready for an upgrade of dependent software
Will you be ready when they are ready to upgrade
Browser-based Risks and Risk Remediation
What software will be required on the client side?
Java
Flash
Active-X
Silverlight
HTML 5

28. New attack vectors Hypervisor complexity
Data leakage (multi-tenant environment)
Man in the Middle
Browser vulnerabilities
Mobile device vulnerabilities

29. Service Agreements Service Level Agreement (SLA) Terms of Service
Some are predefined and non-negotiable
Some are negotiable (typically cost more)
Terms of Service
May cover privacy
Breach notification
Licensing
Acceptable use (What you can and can’t do)
Limitations on liability (Typically in the favor of the service provider)
Modifications of the terms of service (Do you want this?)
Data ownership

30. Traditional risks no matter where you go
Insider threat,
Instead of your staff it is their staff
Access control
How can you control and monitor?
Authentication
Another logon or SSO
Data sanitation
Is your data really deleted?
Others????

31. What to do? Careful planning before engagement
Understand the technical aspects of the solution
Make sure it will meet your needs (security and privacy)
Maintain accountability
Define data location restrictions
Ensure laws and regulations are met
Make sure they can support electronic discovery and forensics
Follow NIST and Cloud Security Alliance guidance

32. Remember to specify Personnel (clear backgrounds)
Access control, account resource and management
Availability, including SLA and dependencies
Problem & Incident reporting, notification and resolution
Disclosure agreements
Physical controls
Network boundary protection
Continuity, Backup and Recovery
Assurance levels
Independent audit or assessment

33. Resources Cloud Security Alliance
cloudsecurityalliance.org
ISACA: Cloud Computing Management Audit/Assurance Program, 2010
NIST SP (draft)
NIST SP
NIST SP (draft)
Federal Cloud Computing Strategy, February 2011
Above the Clouds managing Risk in the World of Cloud Computing by McDonald ( )
Cloud Computing, Implementation, Management, and Security by Rittinghouse and Ransome ( )
Image: Microsoft Clip Art