Clearing the Cloud Part II – A Ray of Sunshine On A Cloudy Day
- On-demand self-service, based upon
- Ubiquitous network access, using
- Location independent resource pooling, feature
- Rapid elasticity and provide
- A Measured Service.
Figure 1: Jericho Forum’s Cloud Layers
- Infrastructure as a Service (IaaS)
- Platform as a Service (PaaS)
- Software as a Service (SaaS)
- Availability and
- Possession (or Control)
- Authenticity and
- Confidentiality: Typically, we handle confidentiality through the usage of technologies such as Encryption and access Control. We can still encrypt, but imagine what happens to a large data set. It has to be sent, or assembled, in the Cloud, remain there in an encrypted form, and be transferred to us, for processing.Once the data is at our location, we have to decrypt it, perform the operations needed, then re-encrypt and resend to the Cloud. Doable – yes. The performance tax here is huge. While today’s routers and servers no longer have their performance brought down to 1/6th by encryption (a loss of 84%), we still pay a heavy price.
Hi, Thank you for contacting Amazon Web Services. Our payment system is PCI compliant and it is an “alternative payment processing service” meaning your users re-direct to our platform to conduct the payment event using their credit cards or bank accounts. The benefit for you is that we handle all the sensitive customer data so you don’t have to. If you haven’t looked at it, I highly suggest you check out the features and functions of our Flexible Payment Service and our Payment Widgets ( http://aws.amazon.com/fps).
As for PCI level 2 compliance, that requires external scanning via a 3rd party, PCI-approved vendor. It is possible for you to build a PCI level 2 compliant app in our AWS cloud using EC2 and S3, but you cannot achieve level 1 compliance. And you have to provide the appropriate encryption mechanisms and key management processes. If you have a data breach, you automatically need to become level 1 compliant which requires on-site auditing; that is something we cannot extend to our customers. This seems like a risk that could challenge your business; as a best practice, I recommend businesses always plan for level 1 compliance. So, from a compliance and risk management perspective, we recommend that you do not store sensitive credit card payment information in our EC2/S3 system because it is not inherently PCI level 1 compliant. It is quite feasible for you to run your entire app in our cloud but keep the credit card data stored on your own local servers which are available for auditing, scanning, and on-site review at any time.
Amazon Web Services
Try the following as an example: Suppose you have a volume of credit-card bearing transactions that you must preserve for a period of one year. And let’s assume that the data is in SQL form. If so, the steps needed would include:
One other element within Confidentiality is the ability to destroy data. In a cloud, that we do not own, and on storage media that we do not control, there is high –probability that the same media be used for other purposes. These storage buckets are dynamic and the service/platform/application provider might allocate them to other users.
This sharing, and in many cases, repeated sharing, of storage media leads to the need for assured destruction. We must follow a strict regime that states how long is data to be kept, when and by whom destroyed, and how such destruction is verified. Since degaussing tapes and shredding CD’s is out of the question, we must employ more agile software- (or, dare we say – hardware?) based methods to assure that destruction.
Figure 7: Chercher les …données?
This question becomes infinitely more complicated when we consider that data at rest does not necessarily “rest” on a certain platen of a certain hard drive. The data can, and usually does, move between storage locations on the drives. The onus is still on us to assure confidentiality, but… we don’t manage the drives. The only practical solution here is to demand regular scouring of storage media from the service providers. Do we think that such a requirement is feasible?
- The next control we will deal with is Availability. When dealing with a Cloud-computing resource, we are at the mercy of the network, the remote server, and whatever controls are applicable along the way, be they host- or network-related.
Yes, we always were at the mercy of such risks, but we owned them before. When multiplying 99.5% by another, we quickly fall in our SLA capability to below 99%, and even further. At what point does the enterprise take notice? As we can see from recent, published outages at Google and elsewhere, users are very sensitive to the information they require, and rightly so.Figure 9: Rapidly Decreasing SLA’s(98.5% = 5 and a half days a year)Even when taking steps to “assure” access, which in reality translates into reducing exposure to this particular risk, we have typically resulted to building redundancy into the system. Here, that would presumably add lines, servers, networking equipment and personnel. Doable, but at what cost? What does the complexity of redundancy mean to an organization? What is the True Cost of operations?.
Let’s look at an example: we have a volume of data which stretches at times by a factor of ten, so cloud computing seems like the perfect solution. So here is what may happen:
- As for Integrity, we can detect changes after they were made. From hashing to redundancy checks, from digital signatures to trip-wiring we are able to ascertain that a change occurred. But… we can no longer prevent changes.
The bastion of defense in depth has crumbled when we talk about Cloud computing. We do not own the moats, the walls, or the doors (see my paper about the Evolution of Defense in Depth). Accepting data without verification should be unthinkable, verifying all inbound data will be complex and costly. Adding yet another layer to the mix of technologies and methodologies that we must rustle.Indeed, the Cloud unchecked could lead to a wave of new attacks aimed directly at data whose guardians (by virtue of possession) are not incentivized to protect it from change, only mostly to be able to speed it on its way.Cloud computing could be a gold rush to people designing man-in-the-middle attacks, too. While most hosting companies will boast of their monitoring and security, few, if any, can assure you that they have never been compromised. In fact, a provision of Cloud data, with its already built in doorway (or tunnel) to you, makes their life easier. They can now both alter the data AND assure that it, and associated payloads, make their way to the intended destination.
Here is one scenario. We have a university system who stores grade data on the cloud. “Pranksters” attack the datacenter and access student data, changing some grades, deleting some students.
Unless very carefully monitoring, either by using as-occurred instances or by comparing data to a “master” copy, such modified data runs a high probability of being recognized as the authoritative copy.
Worse yet, the data that was modified here has a known ownership. These malefactors can well insert, install, and even custom-design a payload to effect the specific environment and systems found at that university – while the data itself is treated by the university as owned, and therefore “blessed” data. This is a whole new definition of insider threat, isn’t it?
Figure 12: Know What Data You Are Getting
- Perhaps moving away a tad from the pure-security elements of C.I. and A., to the more “business” ones, the first we will discuss in the Hexad will be Possession (or Control).As recent developments in the realm of data-breach notification laws has shown us (see my article about the “new” version of Mass’ 201 CMR ), the United States, albeit one state at a time, is moving closer to the European, and indeed worldly, model of “Data Ownership”.
Data ownership is a time-tested term and function that has been used typically in the military realm for over fifty years. That term has slowly been filtering to the corporate world, and now to real-politick, The concept that every element of data has an owner is a simple one, really. Do allow me to explain here, for the sake of completeness, that most elements of data have at least a few owners, and perhaps many, many more.
The data, for example, can be owned by a person designated by the Enterprise, by the system administrator, and/or by the individual it is about (in the case of PII, or personally identifiable data, for example).
Data ownership can specify who is responsible for the data, who can sell the data, whom the data is about, or what is the legal status of the data. And frequently more than just one of these items.
- How do we comply with Breach notification laws?
- What happens if we have data regarding an EU national?
- What must we do when we disclose risk information to Auditors? To the SEC?
- How do we comply with rules relating to CALEA? E-Discovery? Data Forensics?
- If we remember the example we used above, in the University case, Authenticity of data is a problem that must be addressed. Sometimes seen as a combination of non-repudiation, integrity and accountability, Authenticity is a super-set that defines the reliability we assign and the trust we place, in our data.
Should data in/from a Cloud seen as less-trusted data? If so, is there any worth to it? Would Cloud end up being used only for data we could care less about? Only time would tell. But In the following article will offer some solution ideas.
Would you, for example, require a CRC-type check before you accept data? Would that make your life easier or harder? And what about the following, admittedly oversimplified, scenario:
Just how many problems do you see here? I see at least three:
- The sixth element of our Hexad is Utility. Utility is where Cloud Computing excels. If we can figure out the other five elements, we can be the Bruce Willis of this story. Cloud Computing is clearly an idea whose time is near. We cannot argue against the flexibility, MIPS-saving, Just-in-Time, CapEx efficient model of a Cloud. The elasticity and low(er) cost attached to such incredible advance in utility mandates that we solve the issues stated above. Not solving them will have the effect of putting data at an amazingly higher risk. Companies will put data in the Cloud; use the Cloud; and expand the Cloud in a tremendously accelerating rate, regardless of data security and privacy.
In the next article I will put forward some ideas on how to resolve issues defined in this and the previous articles. I will also attempt to show some of the security related benefits that we can garner from the usage of Cloud Computing, especially those that we could not, or could not easily, do before the advent of the Cloud.
- Cloud Security Article - 1st in a Series
- Cloud Security: Danger (and Opportunity Ahead)
- Clearing the Cloud Part II |A Ray of Sunshine On A Cloudy Day || Cloud Computing Security
- Clearing the Cloud Part III || How Do You Solve A Problem Like â€œA Cloudâ€? || Cloud Computing Security