Compliance Complexities Challenge Cloud Adoption

By Shawn R. Chaput

March 31, 2011

Cloud and infrastructure compliance expert, Shawn R. Chaput, lends his understanding of the range of regulatory and other constraints that affect a number of users of high-performance computing. This week he took a look at the challenges of compliance burdens and what to consider when weighing cloud computing options based on lessons learned during his compliance consulting experiences. Although not intended to provide a comprehensive listing of considerations, it should provide some guidance as to some of the more commonplace examples of items warranting specific attention.

In recent experiences helping decision makers evaluate infrastructure options, we’ve encountered several clients who have decided that, given the specific sensitivity of data, the related systems should be hosted by professional hosting organizations well versed in the security of systems.

As it turns out, these data centers offer private cloud infrastructure as a service, which seemed particularly desirable to them. One of the clients in particular was looking for a provider who could guarantee the data would continue to reside within Canada as prescribed by provincial legislation as the data in question was health-related. In this specific example, this requirement became so difficult to accomplish that all other requirements seemingly fell by the wayside.

Ultimately, they found a private cloud provider but the level of security (and ultimately the compliance associated with those systems) may be insufficient for their desires.

Requirements & Obligations

The first things to understand are your regulatory and legislative obligations. Depending on your industry or geographic location, you may be subject to a variety of different laws and agreements governing the way you do business. From a security perspective, some of the more obvious ones include Sarbanes Oxley, PCI DSS, NERC CIP, and a variety of privacy regulations. Don’t expect your cloud provider to explain to you which are applicable and which they adhere to by default. For the most part, the providers are competing on price and security is not typically something organizations are really willing to pay for (although nearly all organizations expect it).

Just because the provider is a massive organization with a good track record for security and has good reference clients doesn’t mean that they’re giving you the same service at the price you’ve been quoted. You need to formalize your requirements and ensure the quotes you solicit capture them all. This likely means you need to talk to your legal counsel to understand and document these obligations. If the price is remarkably lower than the others, you need to look critically at the differences in service and specifically security. 

Cloud Compliance

As I alluded, it is entirely possible that cloud services can be compliant with the obligations your organization has set forth but, by default, it’s probably good to assume the initial proposal provided by them will not be sufficient. It’s also realistic to assume that the more burdensome your requirements are, the more the solution will cost to implement and maintain. 

If we refer back to that example of the Canadian health care provider looking to use cloud services, the foremost requirement they had pertained to the physical location of the data and how it must reside within the province of British Columbia. This requirement alone immediately eliminates most of the very large cloud service providers and brings it down to a handful of local providers to choose from. It’s safe to assume that the price of the niche market players would typically be higher that the massive internationals but that requirement precludes the use of the cheaper providers. Similarly, if you’re looking for a PCI DSS compliant service provider, the list is relatively short and the prices not easily comparable to non-compliant service providers.

If you combine the two requirements (PCI DSS compliant and local BC company), it’s unlikely that list would be very large at all. In some cases, you may have to choose a local provider and help them to become PCI compliant, in the event that none of the companies fit both requirements. Clearly, the cost of that endeavour is not immediately comparable to posted monthly service charges from Microsoft or Amazon, as examples. Clearly, the organizational strategy of outsourcing to the cloud is not one to be taken lightly.

Information Security Organization

Ultimately, the success of your cloud compliance project hinges on your organization’s existing IT security and compliance maturity as well as how your organization manages third parties.  Although it could be argued that there is significant overlap between the two concepts, we’ll treat them as relatively mutually exclusive for the purposes of this discussion. 

With respect to the individual security elements pertaining to outsourcing to the cloud, there are a few basic principles which need specific consideration.

Data Classification

If you’re outsourcing anything, your organization needs to have a solid understanding of the type of data you’re sending outside of your organization’s physical premises. For example, in the event your organization is allowed to safeguard government classified documents at the level of Secret, you would not be able to have that data hosted anywhere that isn’t appropriate certified by the government for those purposes (and verified as such). This means you need to understand the sensitivity of the data to be hosted and the related obligations.

The exercise of data classification, system classification and labeling is intrinsic to the success and efficient use of resources for all information security programs and should be conducted long before you consider trusting a third party to host your data.

Ultimately, as data custodians, the cloud provider will do exactly whatever you tell them to do with the data and only that. They will not have the insight or capability to examine your data for sensitive information like credit card numbers then decide that that specific file or database should have an additional level of protection (unless, of course, you pay them to classify your data and systems for you as part of a consulting project). You need to identify the specific systems of concern and consider whether the costs associated with the protection of those systems in cloud are ultimately less than that you’re already spending. 

Access Control & Connectivity

Authentication and authorization are another two areas you need to understand with respect to outsourcing to the cloud.  Specifically you need to understand who owns and manages the authentication mechanism (such as LDAP, Active Directory, etc.) and who assigns the appropriate permissions to the individuals accessing the data or otherwise using the systems. 

We’ve seen cloud deployments use a variety of different methods from standalone servers which don’t have any central management, to an extension of your corporate Active Directory environment to a fully managed authentication LDAP directory. Each of these options has different concerns pertaining to how they’re secured (and who is responsible for that security). This all needs to be documented and formalized. From a documentation perspective, there are many procedures which would need to be reviewed including user provisioning and deprovisioning to fully ensure you understand what you’re getting.

Another specific area to ensure is considered is the accounting and auditing of users as required by specific compliance regulation. From a security perspective, logging and monitoring does not apply to just the service logs which are generated by default by the operating system. The way we view logging and monitoring is that it is a means to forensically recreate events which have occurred to understand where they came from, what happened and hopefully why. This means that your provider should have some sort of Security Information and Event Management System (SIEM) in place to consider the security events which may occur and not just whether a service has stopped running. This, again, is likely not a standard offering by the less expensive cloud providers but needs to be considered if you’re looking to sufficiently secure your hosted environment to meet compliance obligations. 

Additional considerations should include how the data stored in the cloud are secured as well as how that data is transmitted. Encryption tends to be the “easy answer” for questions about how the data gets from your office to the cloud using SSL or IPSEC. Data stored on hard disks may use full disk encryption or BitLocker or some other comparable technology but how often does the process by which the encryption keys are managed get mentioned? Rarely.  You need to understand if the keys used are unique? Does key rotation occur? Ultimately, without a solid understanding of cryptography principles as part of a mature security and compliance program, it’s unlikely you’ll capture the requirements sufficiently within the contract with the cloud provider. Its further doubtful that the cloud provider will volunteer this level of detail without you asking the question.

Segmentation and Separation

Considering the nature of cloud infrastructure, to maintain specific compliance obligations you may seek to validate how the logical Virtual Machines (VM) in your environment are separated and secured from other customer’s VMs. Even if the hosted environment is a “Private Cloud” or perhaps using “dedicated hardware”, it’s in your best interest to understand the methods and mechanism in place separating the provider’s customer systems (and data, if stored on shared storage) and evaluate whether those controls are sufficient to your needs. 

Ask for diagrams and evidence and don’t trust informal communications describing the environment. Further investigation into how the systems are managed (i.e. what access their staff has?) and what happens if the management consoles are compromised should also be considered. Additionally, from that perspective, the provisioning process of hypervisor users should be reviewed. Furthermore, how the hypervisor is secured or hardened should be considered and whether it is consistent with best practices such as NIST SP 800-125 Guide to Security for Full Virtualization Technologies.

Roles and Responsibilities

From a less technological perspective, another area warranting through review and formalization is a comprehensive responsibility matrix outlining who is responsible for what under each circumstance. This document needs to exist to ensure all parties are aware of their responsibilities under the contract and ensure aligned expectations. This goes for initial provisioning of virtual machines, patching and updating, log management, all the way through user management and incident response plan execution. Incident response is of specific importance for most organizations and, if you’re in one of the many jurisdictions subject to breach notification laws, you need to ensure that it’s well understood who is responsible for contacting your customers in the event your provider suffers a breach, as an example. 

Risk Assessments

As with any new endeavor or outsourcing effort, a variety of evaluations and assessments should be conducted to ensure the concept makes business sense. This means ensuring a capable individual or company conducts a business impact assessment and perhaps a privacy impact assessment, depending on the nature of the systems and data you’re considering sending to the cloud. Threat and risk assessments are also commonplace for evaluating whether a technical solution meets the business requirements stipulated and addresses all the non-negligible concerns. 

Due Diligence & Provider Contract Requirements

Really, when it comes down to any outsourcing deal, be it cloud computing related or not, contracts are the most important part of the arrangement and just like any other contract, due diligence should be conducted to ensure you are getting what you want.

As part of the diligence process, many organizations may mandate things like ISO/IEC 27001 compliance or PCI DSS service provider compliance. One must pay particular attention to the scope of the environments being assessed within each of these types of attestations to ensure the applicability to your potential environment. Just because an organization is ISO 27001 certified doesn’t mean the systems they intend to host for you will be within that certified environment.

Similarly, a lot of organizations use SAS70 type 2 audits to show they’re secure. SAS70 is in the process of being replaced by SSAE No. 16 with the intention of showing similar details about a service provider organization. These reports ultimately verify whether an organization follows the documented procedures they have, not whether they adhere to best practices or are inherently secure. When provided with one of these types of audits as evidence of security controls in place, review them carefully to ensure they cover the desired areas and procedures.

With respect to specific contract terms you should insist upon, clauses covering portability & interoperability should exist to ensure, in the event you want to retrieve your data and transfer it to a different provider or bring it back in house, it will be technically possible. Similarly, you should insist on the Right to Audit clause, which hopefully you’ll never use but should things go badly, you can exercise. And lastly, ensure you have a strong collection of metrics within the Service Level Agreement against which performance can be measured and tracked.

Conclusions

As you’ve probably discovered by now, cloud computing technology can easily extend your organization but many of the components security conscious organization consider “Standard” or expect may not be initially included in the contract and treated as a la carte. With that in mind, pricing associated with outsourcing data and systems subject to compliance obligations can considerably increase to the point that these specific costs should be thoroughly investigated prior to trying to outsource the responsibility of managing those systems.  Furthermore, placing those items in the cloud do not necessarily allow you to abdicate all responsibility associated with those systems and, in fact, can make things more difficult to manage if appropriate roles and responsibilities haven’t been formalized.  At any point, you’ll likely be obligated to validate that your service providers are compliant as part of your compliancy initiatives. 

Privity Systems Inc. (Privity) is a boutique-style Western Canada based Information security consulting practice with a focus on compliance matters and strategic planning. As a Payment Card Industry Qualified Security Assessor (PCI QSA) company, Privity provides guidance and assurance to its Canadian clients dealing with these complicated regulations.  Privity is a Microsoft Silver Partner with a competency in Identity & Security as well as Mid-Market Solutions. Privity is also a Symantec Silver Partner, Cisco Select Partner and VMWare Professional Service Provider. 

About the Author

Shawn R. Chaput, CISA, CISM, CGEIT, CRISC, CISSP, ISSAP, ISSMP, CIPP/C, CFE, CIA, PMP, ITIL, ABCP, MCITP, MCTS, CCDA, STS, QSA; Chief Architect & Executive Consultant, Privity Systems Inc.

Shawn R. Chaput is an Executive Security Consultant and Chief Architect for Privity Systems Inc., an information security services company in Vancouver, Canada.  With a past of working for large consulting firms like IBM, EDS and Accenture, he has over 16 year’s tenure in IT and more specifically within the information security and compliance professions.  

As a trusted business advisor to many large and well known organizations, Mr. Chaput tends to fill the role of a chief security strategist helping organizations overcome tremendous roadblocks affecting their IT compliance initiatives such as PCI DSS, FISMA, NERC and SOX. 

His role has lead him to advise executive management of some very large and well known organizations on how to effectively govern and manage IT risk; design enterprise security architectures, strategies and plans; develop cost-effective and sustainable security management policies and practices for governance frameworks.

An accomplished author, patent holder and public speaker, he has contributed to several articles and books as well as other formal academic publications. He participates in the Canadian Advisory Committee for the ISO SC27, which develops the ISO/IEC 27000 series Security Standards and is also a contributing member of many special interest groups within the PCI Community responsible for shaping the related official guidance and future versions of PCI DSS. A foremost expert on IT and security compliance, he was asked to author the inaugural “compliance” section of the Cloud Security Alliance’s “guidance” document and has managed all revisions since.  Since his participation in the founding of the CSA, he has been published several times and spoken at several large conferences on the topic.

Shawn holds a Masters of Business Administration, Management of Technology from the Beedie School of Business at Simon Fraser University and an Honours Baccalaureate in Economics and Political Science from the University of Winnipeg.  He also holds more than twenty industry certifications across multiple technical and best practices disciplines and is continually adding more.
 

Subscribe to HPCwire's Weekly Update!

Be the most informed person in the room! Stay ahead of the tech trends with industy updates delivered to you every week!

Scalable Informatics Ceases Operations

March 23, 2017

On the same day we reported on the uncertain future for HPC compiler company PathScale, we are sad to learn that another HPC vendor, Scalable Informatics, is closing its doors. Read more…

By Tiffany Trader

‘Strategies in Biomedical Data Science’ Advances IT-Research Synergies

March 23, 2017

“Strategies in Biomedical Data Science: Driving Force for Innovation” by Jay A. Etchings is both an introductory text and a field guide for anyone working with biomedical data. Read more…

By Tiffany Trader

HPC Compiler Company PathScale Seeks Life Raft

March 23, 2017

HPCwire has learned that HPC compiler company PathScale has fallen on difficult times and is asking the community for help or actively seeking a buyer for its assets. Read more…

By Tiffany Trader

Google Launches New Machine Learning Journal

March 22, 2017

On Monday, Google announced plans to launch a new peer review journal and “ecosystem” Read more…

By John Russell

HPE Extreme Performance Solutions

HFT Firms Turn to Co-Location to Gain Competitive Advantage

High-frequency trading (HFT) is a high-speed, high-stakes world where every millisecond matters. Finding ways to execute trades faster than the competition translates directly to greater revenue for firms, brokerages, and exchanges. Read more…

Swiss Researchers Peer Inside Chips with Improved X-Ray Imaging

March 22, 2017

Peering inside semiconductor chips using x-ray imaging isn’t new, but the technique hasn’t been especially good or easy to accomplish. Read more…

By John Russell

LANL Simulation Shows Massive Black Holes Break ‘Speed Limit’

March 21, 2017

A new computer simulation based on codes developed at Los Alamos National Laboratory (LANL) is shedding light on how supermassive black holes could have formed in the early universe contrary to most prior models which impose a limit on how fast these massive ‘objects’ can form. Read more…

Quantum Bits: D-Wave and VW; Google Quantum Lab; IBM Expands Access

March 21, 2017

For a technology that’s usually characterized as far off and in a distant galaxy, quantum computing has been steadily picking up steam. Read more…

By John Russell

Intel Ships Drives Based on 3D XPoint Non-volatile Memory

March 20, 2017

Intel Corp. has begun shipping new storage drives based on its 3D XPoint non-volatile memory technology as it targets data-driven workloads. Intel’s new Optane solid-state drives, designated P4800X, seek to combine the attributes of memory and storage in the same device. Read more…

By George Leopold

HPC Compiler Company PathScale Seeks Life Raft

March 23, 2017

HPCwire has learned that HPC compiler company PathScale has fallen on difficult times and is asking the community for help or actively seeking a buyer for its assets. Read more…

By Tiffany Trader

Quantum Bits: D-Wave and VW; Google Quantum Lab; IBM Expands Access

March 21, 2017

For a technology that’s usually characterized as far off and in a distant galaxy, quantum computing has been steadily picking up steam. Read more…

By John Russell

Trump Budget Targets NIH, DOE, and EPA; No Mention of NSF

March 16, 2017

President Trump’s proposed U.S. fiscal 2018 budget issued today sharply cuts science spending while bolstering military spending as he promised during the campaign. Read more…

By John Russell

CPU-based Visualization Positions for Exascale Supercomputing

March 16, 2017

In this contributed perspective piece, Intel’s Jim Jeffers makes the case that CPU-based visualization is now widely adopted and as such is no longer a contrarian view, but is rather an exascale requirement. Read more…

By Jim Jeffers, Principal Engineer and Engineering Leader, Intel

US Supercomputing Leaders Tackle the China Question

March 15, 2017

Joint DOE-NSA report responds to the increased global pressures impacting the competitiveness of U.S. supercomputing. Read more…

By Tiffany Trader

New Japanese Supercomputing Project Targets Exascale

March 14, 2017

Another Japanese supercomputing project was revealed this week, this one from emerging supercomputer maker, ExaScaler Inc., and Keio University. The partners are working on an original supercomputer design with exascale aspirations. Read more…

By Tiffany Trader

Nvidia Debuts HGX-1 for Cloud; Announces Fujitsu AI Deal

March 9, 2017

On Monday Nvidia announced a major deal with Fujitsu to help build an AI supercomputer for RIKEN using 24 DGX-1 servers. Read more…

By John Russell

HPC4Mfg Advances State-of-the-Art for American Manufacturing

March 9, 2017

Last Friday (March 3, 2017), the High Performance Computing for Manufacturing (HPC4Mfg) program held an industry engagement day workshop in San Diego, bringing together members of the US manufacturing community, national laboratories and universities to discuss the role of high-performance computing as an innovation engine for American manufacturing. Read more…

By Tiffany Trader

For IBM/OpenPOWER: Success in 2017 = (Volume) Sales

January 11, 2017

To a large degree IBM and the OpenPOWER Foundation have done what they said they would – assembling a substantial and growing ecosystem and bringing Power-based products to market, all in about three years. Read more…

By John Russell

TSUBAME3.0 Points to Future HPE Pascal-NVLink-OPA Server

February 17, 2017

Since our initial coverage of the TSUBAME3.0 supercomputer yesterday, more details have come to light on this innovative project. Of particular interest is a new board design for NVLink-equipped Pascal P100 GPUs that will create another entrant to the space currently occupied by Nvidia's DGX-1 system, IBM's "Minsky" platform and the Supermicro SuperServer (1028GQ-TXR). Read more…

By Tiffany Trader

Tokyo Tech’s TSUBAME3.0 Will Be First HPE-SGI Super

February 16, 2017

In a press event Friday afternoon local time in Japan, Tokyo Institute of Technology (Tokyo Tech) announced its plans for the TSUBAME3.0 supercomputer, which will be Japan’s “fastest AI supercomputer,” Read more…

By Tiffany Trader

IBM Wants to be “Red Hat” of Deep Learning

January 26, 2017

IBM today announced the addition of TensorFlow and Chainer deep learning frameworks to its PowerAI suite of deep learning tools, which already includes popular offerings such as Caffe, Theano, and Torch. Read more…

By John Russell

Lighting up Aurora: Behind the Scenes at the Creation of the DOE’s Upcoming 200 Petaflops Supercomputer

December 1, 2016

In April 2015, U.S. Department of Energy Undersecretary Franklin Orr announced that Intel would be the prime contractor for Aurora: Read more…

By Jan Rowell

Is Liquid Cooling Ready to Go Mainstream?

February 13, 2017

Lost in the frenzy of SC16 was a substantial rise in the number of vendors showing server oriented liquid cooling technologies. Three decades ago liquid cooling was pretty much the exclusive realm of the Cray-2 and IBM mainframe class products. That’s changing. We are now seeing an emergence of x86 class server products with exotic plumbing technology ranging from Direct-to-Chip to servers and storage completely immersed in a dielectric fluid. Read more…

By Steve Campbell

Enlisting Deep Learning in the War on Cancer

December 7, 2016

Sometime in Q2 2017 the first ‘results’ of the Joint Design of Advanced Computing Solutions for Cancer (JDACS4C) will become publicly available according to Rick Stevens. He leads one of three JDACS4C pilot projects pressing deep learning (DL) into service in the War on Cancer. Read more…

By John Russell

BioTeam’s Berman Charts 2017 HPC Trends in Life Sciences

January 4, 2017

Twenty years ago high performance computing was nearly absent from life sciences. Today it’s used throughout life sciences and biomedical research. Genomics and the data deluge from modern lab instruments are the main drivers, but so is the longer-term desire to perform predictive simulation in support of Precision Medicine (PM). There’s even a specialized life sciences supercomputer, ‘Anton’ from D.E. Shaw Research, and the Pittsburgh Supercomputing Center is standing up its second Anton 2 and actively soliciting project proposals. There’s a lot going on. Read more…

By John Russell

Leading Solution Providers

HPC Startup Advances Auto-Parallelization’s Promise

January 23, 2017

The shift from single core to multicore hardware has made finding parallelism in codes more important than ever, but that hasn’t made the task of parallel programming any easier. Read more…

By Tiffany Trader

HPC Technique Propels Deep Learning at Scale

February 21, 2017

Researchers from Baidu’s Silicon Valley AI Lab (SVAIL) have adapted a well-known HPC communication technique to boost the speed and scale of their neural network training and now they are sharing their implementation with the larger deep learning community. Read more…

By Tiffany Trader

CPU Benchmarking: Haswell Versus POWER8

June 2, 2015

With OpenPOWER activity ramping up and IBM’s prominent role in the upcoming DOE machines Summit and Sierra, it’s a good time to look at how the IBM POWER CPU stacks up against the x86 Xeon Haswell CPU from Intel. Read more…

By Tiffany Trader

Trump Budget Targets NIH, DOE, and EPA; No Mention of NSF

March 16, 2017

President Trump’s proposed U.S. fiscal 2018 budget issued today sharply cuts science spending while bolstering military spending as he promised during the campaign. Read more…

By John Russell

IDG to Be Bought by Chinese Investors; IDC to Spin Out HPC Group

January 19, 2017

US-based publishing and investment firm International Data Group, Inc. (IDG) will be acquired by a pair of Chinese investors, China Oceanwide Holdings Group Co., Ltd. Read more…

By Tiffany Trader

US Supercomputing Leaders Tackle the China Question

March 15, 2017

Joint DOE-NSA report responds to the increased global pressures impacting the competitiveness of U.S. supercomputing. Read more…

By Tiffany Trader

Quantum Bits: D-Wave and VW; Google Quantum Lab; IBM Expands Access

March 21, 2017

For a technology that’s usually characterized as far off and in a distant galaxy, quantum computing has been steadily picking up steam. Read more…

By John Russell

Intel and Trump Announce $7B for Fab 42 Targeting 7nm

February 8, 2017

In what may be an attempt by President Trump to reset his turbulent relationship with the high tech industry, he and Intel CEO Brian Krzanich today announced plans to invest more than $7 billion to complete Fab 42. Read more…

By John Russell

  • arrow
  • Click Here for More Headlines
  • arrow
Share This