Certified Cloud Security Professional (CCSP) : Study Guide
Certified Cloud Security Professional (CCSP) : Study Guide
Certified Cloud Security Professional (CCSP) : Study Guide
Bob Salmans
[email protected]
September 2019
Study Guide | Certified Cloud Security Professional (CCSP)
Contents
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Study Guide | Certified Cloud Security Professional (CCSP)
B. Describe the Secure Software Development Life Cycle (SDLC) Process 111
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Study Guide | Certified Cloud Security Professional (CCSP)
A. Implement and Build Physical and Logical Infrastructure for Cloud Environment 129
A. Articulate Legal Requirements and Unique Risks within the Cloud Environment 156
C. Understand Audit Process, Methodologies, and Required Adaptations for a Cloud Environment 166
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Study Guide | Certified Cloud Security Professional (CCSP)
• The business drives security. Security does not drive the business:
• IT supports the business and its goals.
• Security hinders a business's efficiency.
• Business needs drive security, security does not drive the business.
Ex.: If a business wants to process credit cards and manage cardholder data, it must become PCI compliant.
It doesn't make sense for a business that doesn't handle cardholder data to spend money on becoming PCI
compliant just because someone in IT feels it would be a good idea.
• Information security professionals need to understand how the business operates in order to be more
effective at their role:
• If IT wants to deploy geo-blocking technologies, they can't simply block traffic from all countries. IT must
understand how the business works and who they work with before deploying security technologies, or they
will hinder the business's progress.
• IT cannot provide advanced audit capabilities for sensitive data if they don't take the time to communicate with
data owners to identify what data is sensitive and
where it resides.
• Functional requirements: Services required for a person of the business to accomplish their job:
• Ex.: Sales cannot effectively communicate with customers unless they have remote access to email.
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Study Guide | Certified Cloud Security Professional (CCSP)
• Nonfunctional requirements: Services not required for a person of the business to accomplish their job:
• Ex.: Sales cannot effectively communicate with customers unless they have remote access to encrypted email.
• Understand the difference between functional and non-functional requirements.
• Jane needs reliable transportation to her job: Jane needs a car. (Functional)
• Jane needs reliable transportation to her job: Jane needs a stretch limousine and driver. (Non-functional)
• CapEx:
• Capital expenditure (CapEx) is an upfront investment of a sum of money into a business requirement, such as a
building, server farm, network environment, or network operations center (NOC).
• OpEx:
• An OpEx is an operational expenditure where you are paying for a service on a schedule. An example of this
would be a building lease or utilities. However, this applies to services as well, such cloud services or hosting
services.
• CapEx vs. OpEx:
• Businesses may not have large amounts of capital at their disposal, so instead of building out an on-premises
compute solution that could cost large amounts of money, they may instead look into a cloud solution. If the
business stands up their compute needs in the cloud, they are paying month to month on only what is needed.
Whereas, if they built out their on-premises solution, they would have to invest large amounts of capital upfront
and then pay for ongoing costs, such as electricity, warranties, support contracts, and eventually replacement.
• Anything as a Service (XaaS): The understanding that there is a vast amount of services available across the
internet so you don't need to stand up an on-premises solution.
• Apache CloudStack: An open-source cloud computing software for creating, managing, and deploying
infrastructure cloud services. A management layer for managing hypervisors and their abilities.
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Study Guide | Certified Cloud Security Professional (CCSP)
• Business Continuity (BC): The capability of a business to continue delivery of services or products to its customers
following a loss of service. Focuses on how the business will continue to serve customers during the incident, not
how it will get IT back up and running, which is the focus of disaster recovery (DR).
• Business Continuity Management: Management process that builds a framework based on potential threats and
their impact on business operations. This framework provides resilience to the business and safeguards the
interests of key stakeholders.
• Cloud app: A cloud application accessed across the internet, not installed locally.
• Cloud Application Management Platform (CAMP): A specification designed to ease management of applications
across public and private cloud platforms.
• Cloud computing: A type of computing that shares computing resources of remote environments to accomplish
work, instead of using local servers.
• Cloud database: A database accessible to clients across the internet. Also refers to Database as a Service (DBaaS).
These cloud databases use cloud computing to achieve optimization, scaling, high availability, and multi-tenancy.
• Cloud enablement: Making cloud services available to a client.
• Cloud management: Software and technology used to monitor and operate cloud environments. These tools help
ensure cloud resources are working optimally.
• Cloud OS: A phrase used in place of Platform as a Service (PaaS) to identify an association with cloud computing.
• Cloud portability: The ability to move applications and data between different cloud service providers (CSPs) or
between public and private cloud environments.
• Cloud provisioning: The deployment of cloud services to meet a need.
• Cloud service provider (CSP): Company providing cloud services to customers.
• Desktop as a Service (DaaS): A virtual desktop infrastructure (VDI), also called a hosted desktop service. Simply a
desktop in the cloud you connect to and use with applications installed on it.
• Enterprise application: Applications or software used by large organizations. Generally refers to large-scale
applications not suited for small business or individual needs.
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Study Guide | Certified Cloud Security Professional (CCSP)
• Eucalyptus: Open-source cloud computing and IaaS platform for enabling AWS-compatible private and hybrid
clouds.
• Event: A change of state that has significance for the management of an IT service. Sometimes referred to as an
alert or notification.
• Hybrid cloud storage: A combination of public and private cloud storage. Sensitive data will reside in the private
cloud, while other data or applications may reside in the public cloud.
• Infrastructure as a Service (IaaS): A computer infrastructure being delivered as a service. This includes compute,
storage, network, and internet access. Simply a fully functional virtual environment on which customers provision
virtual hosts.
• Managed service provider (MSP): Managed service providers (MSPs) provide various IT services to customers such
as monitoring, patching, help desk, and network operations center.
• Mean time between failures (MTBF): Measure of the average time between failures of a component or system.
• Mean time to repair (MTTR): Measure of the average time it should take to repair a component or system failure.
• Mobile cloud storage: Cloud storage used to store a customer's mobile device data in the cloud providing access
from anywhere.
• Multi-tenant: Having multiple customers using the same public cloud. Data is logically separated by security
controls but still runs on the same shared underlying hardware.
• On-demand services: Service model allowing customers to scale their consumed resources without assistance
from the provider in real time.
• Platform as a Service (PaaS): A cloud-based platform on which clients deploy their applications. The CSP will
manage all underlying infrastructure, including operating system, compute hardware, and network. The customer
is only responsible for managing their application code.
• Private cloud: Also known as internal or corporate cloud, this cloud compute platform is protected by the
corporate firewall under the control of the IT department, not a CSP. Allows the IT department to control the
security of the data and meet regulatory compliance. May be a corporate-owned data center referred to as a
corporate cloud or can also be provided by a CSP offering isolated cloud services.
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Study Guide | Certified Cloud Security Professional (CCSP)
• Public cloud storage: Cloud storage in which the enterprise and storage services provider are separate and the
data is stored outside the enterprise data center.
• Recovery point objective (RPO): Helps determine how much information must be restored from backups after an
event. "How much data is the company willing to lose?"
• Recovery time objective (RTO): How fast you need individual systems to be back up and running after a disaster
or critical failure, generally measured in hours. For example, the RTO for a business-critical application may be four
hours.
• Scalability: The ability to increase resources to meet demand in near real time.
• Software as a Service (SaaS): Cloud-based software offered to clients accessed across the internet, most often as a
web-based service. Think web-based applications you log in to and use.
• Vertical cloud computing: The optimization of cloud computing and services for a specific industry. An example
would be cloud resources for the entertainment industry, which may have GPUs available to increase compute
power for rendering of images and video.
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Study Guide | Certified Cloud Security Professional (CCSP)
• On-demand self-service: The ability for cloud service customers to provision new cloud services or increase
existing services on demand. This can be dangerous, as these services don't require approval from finance or
another process — they simply require access to a management console and a few button clicks.
• Broad network access: You should never experience network bottlenecks due to use of technologies such as
routing, load balancers, multiple sites, etc.
• Resourcing pool: Provider owns a large pool of resources (compute, storage, network, etc.), and customers each
get an amount of these "pooled" resources. By having a "pool," the vast majority of these resources are shared and
not dedicated. This means the provider can spend less money on resources as they are getting more use out of
each resource as opposed to dedicated physical servers.
• Elasticity: The ability to scale back resources as needed so you are not paying for unused resources.
• Metered or measured service: Customer is charged only for what resources they use. Also allows for
organizations to charge individual departments within the organization for resources used by that department.
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Study Guide | Certified Cloud Security Professional (CCSP)
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Study Guide | Certified Cloud Security Professional (CCSP)
• Application capability
• The cloud service customer uses the cloud service provider's
applications.
• Infrastructure capability
• The cloud service customer can provision and use processing,
storage, or networking resources.
• Platform capability
• The cloud service customer can deploy, manage, and run their own applications using one or more
programming languages and one or more execution environments supported by the CSP.
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Study Guide | Certified Cloud Security Professional (CCSP)
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Study Guide | Certified Cloud Security Professional (CCSP)
The cloud service customer can deploy, manage, and run their own
applications using one or more programming languages and one or
more execution environments supported by the CSP.
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Study Guide | Certified Cloud Security Professional (CCSP)
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Study Guide | Certified Cloud Security Professional (CCSP)
Provides cloud service customers the ability to provision and use processing resources needed to deploy and run
software
Provides cloud service customers the ability to provision and use data storage and related capabilities
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Study Guide | Certified Cloud Security Professional (CCSP)
Provides cloud service customers the ability to use transport connectivity and related network capabilities
• Public
• Private
• Hybrid
• Community
• Risk appetite
• Cost
• Compliance and regulatory requirements
• Legal obligations
• Business strategy
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Study Guide | Certified Cloud Security Professional (CCSP)
"The cloud infrastructure is provisioned for open use by the general public. It may be owned, managed, and
operated by a business, academic, or government organization, or some combination of them. It exists on the
premises of the cloud provider."
Key: Anyone can sign up with the cloud provider and use the resources.
• Easy and inexpensive to set up (provider has paid for the upfront startup costs)
• Easy to use
• Scalable
• Pay as you go, no wasted resources
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Study Guide | Certified Cloud Security Professional (CCSP)
"The cloud infrastructure is provisioned for exclusive use by a single organization comprising multiple consumers
(e.g., business units). It may be owned, managed, and operated by the organization, a third party, or some
combination of them, and it may exist on or off premises."
These are most often used in large environments with compliance or regulatory requirements.
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Study Guide | Certified Cloud Security Professional (CCSP)
"The cloud infrastructure is a composition of two or more distinct cloud infrastructures (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)."
Key benefits:
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Study Guide | Certified Cloud Security Professional (CCSP)
"The cloud infrastructure is provisioned for exclusive use by a specific community of consumers from
organizations that have shared concerns (e.g., mission, security requirements, policy, and compliance
considerations). It may be owned, managed, and operated by one or more of the organizations in the
community, a third party, or some combination of them, and it may exist on or off premises."
Key: Provisioned for exclusive use by a specific community of consumers. A group of like-minded organizations build
out their own cloud and share the cost.
Example: A group of doctors' offices come together to create a cloud solution that hosts their electronic medical
records (EMR) application. They all can access and use the EMR, and they share the costs associated with the cloud
resources.
Key benefits:
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Study Guide | Certified Cloud Security Professional (CCSP)
• Auditability: The capability of collecting and making available necessary evidential information related to the
operation and use of a cloud service for the purpose of conducting an audit.
• What logs are available to the customer without needing to request special access?
• What additional charges may be incurred for log access?
• Availability: The state of being accessible and usable on demand by an authorized user.
• Governance: The system by which the provision and use of cloud services is directed and controlled.
• Interoperability: The ability of a cloud service customer to interact with cloud services in a predictable manner, or
the ability for one cloud service to interact with another cloud service.
• Maintenance: Maintenance and upgrades can change the way services function, therefore it's important that
maintenance of services be subject to governance practices that are transparent to the customer.
• Notification of maintenance windows and scheduled upgrades
• Disclosure of roll-back practices
• SLA should document maintenance practices
• Versioning: Labeling of a service's version for easy identification of the version. If significant changes are being
made, both the old and new version should be offered in parallel to reduce impact to customers if there is an issue
with the new version.
• Performance: The cloud services meeting the metrics defined in the SLA. These metrics include availability,
response time, latency, data throughput, etc.
• Portability: The ability for a cloud service customer to easily migrate their data between cloud service providers.
This is a key factor to consider when considering a cloud service provider.
• Protection of personally identifiable information (PII): Cloud service providers "should" protect PII. This is
something to look for in SLAs.
• Resiliency: The ability of a system to provide and maintain an acceptable level of service during a system fault. This
is where monitoring and high availability come into play.
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Study Guide | Certified Cloud Security Professional (CCSP)
• Reversability: This goes two ways. The first is the ability for a cloud service provider to recover cloud service
customer data and application artifacts in the event of deletion. The second is the ability of a cloud service provider
to delete all cloud service customer data after an agreed-upon date (right to be forgotten).
• Security: This includes many capabilities, such as access control, confidentiality, integrity, and availability (CIA
triad). This also includes management and administrative functions.
• Service-level agreement (SLA): Representing measurable elements needed to ensure an agreed-upon quality of
service between the cloud service customer and provider. The key is "measurable." The SLA should specify
information related to the availability, confidentiality, and integrity of the services provided.
• Machine learning (ML) and artificial intelligence (AI): Using pattern recognition and computational learning to
make predictions
• Many cloud vendors are now offering ML and AI as a service.
• Cloud vendors have the resources to build out environments suited for this type of data analysis.
• Blockchain: A protocol that uses a decentralized framework to maintain integrity within the data
• Cloud was originally the offloading of service from on-premises to a cloud vendor's premises where customers
use resources from one or more data centers.
• Blockchain could be used to manage globally distributed workloads between data centers so that the data
resides in multiple data centers at once.
• Not only would this allow for a new type of decentralized cloud, but it would also be used to guarantee integrity
of the data.
• Internet of Things (IoT): IoT devices are generally sensors or other simple devices with simplified tasks. The
"internet" of IoT indicates these devices are internet-connected and upload data to a destination somewhere
online.
• Many cloud vendors offer IoT services, including creating images for individual devices, cloud-based data
analysis, and the integration of AI.
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Study Guide | Certified Cloud Security Professional (CCSP)
• Containers: Containers are small packages of code that include an application, its dependencies, and libraries.
That's it! It then uses the underlying container operating system on which it runs for other services, such as
networking. Containers are like a stripped-down version of virtualized virtual machines (VMs).
• Containers are very small and generally require very little resources, hence they start up very quickly and cost
very little to run. A great alternative to a full-blown VM instance.
• They can scale very quickly.
• They are designed to do only a single job, such as a web service that allows you to separate each service into its
own container. This increases resiliency and security.
• Quantum computing: Quantum computing gets its massive compute power by tapping into quantum physics and
not the use of micro-transistors. Traditional computing uses the values of 0 and 1 in bits, but quantum computing
can store multiple values in qubits.
• Vendors such as Rigetti, Google, IBM, and Microsoft have made quantum CPUs, but they are still in the infancy
of the projects and are working to build applications that can take advantage of the processing power so they
can measure the processing power.
• Eventually, cloud service providers will offer quantum computing services to their customers. We can only
imagine that with the shared resource framework, providers will be able to offer quantum computing services
at a much more affordable rate than attempting to purchase a quantum computing server.
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Study Guide | Certified Cloud Security Professional (CCSP)
Confidentiality: Controlling authorized access to data in order to protect the privacy of the data
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Study Guide | Certified Cloud Security Professional (CCSP)
Data at Rest
Key Management
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Study Guide | Certified Cloud Security Professional (CCSP)
• Client-Side Key Management: CSP provides the KMS, but it resides on customer premises. Then customer
generates keys, encrypts data, and uploads to the cloud.
Access control has evolved to work with other services such as single sign-on (SSO), multi-factor authentication (MFA),
and other authentication and authorization services, and is now generally known as identity and access management
(IAM).
IAM works with people, processes, and systems to control access to resources.
• Validate identity
• Grant level of access to data, services, applications, etc.
• Generally uses a minimum of two factors of authentication to validate a user's identity.
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Study Guide | Certified Cloud Security Professional (CCSP)
Time-bound rules
Geo-based rules
Audit capabilities
Notification capabilities
Forcing use of MFA
• IAM should use features of PIM for administrative access accounts
MFA should always be used on administrative accounts
• Trust and confidence in the accuracy and integrity of the directory service is paramount
• Privileged user management
• Privileged accounts carry the highest risk and impact
• Key components as it pertains to privileged accounts are:
Usage tracking
Authentication success and failure tracking
Authorization date and times
Reporting capabilities
Password management (complexity, length, MFA)
• Requirements should be driven by organizational policies and procedures
• Authorization and access management
• Authorization determines a user's right to access a resource
• Access management is the process of providing access to resources once a user is authorized to access it.
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Study Guide | Certified Cloud Security Professional (CCSP)
• The ability to remove all data from a system is critical to ensuring confidentiality in the cloud. We can't have
data remnants remaining for someone else to find at a later point.
• If a vendor is not in compliance with standards requiring the provider to have a solution for securely
removing data, how can we ensure it's actually being wiped?
• Cryptographic erasure: Erase, overwrite with pattern, erase again
• Data overwriting: Simply overwriting data may be sufficient for some data but not sensitive data (PII, PCI,
HIPAA, IP)
• Remember: Deleting files only makes them invisible to the user; the files are still there until overwritten by the
operating system with other data.
• Key destruction of an encryption key is not sufficient, as the key could be recovered forensically and used to
access data that has not been wiped properly.
Other than degaussing media or complete physical destruction, an attacker who has enough
resources and time can access data that has been written over and erased several times. These
types of destruction are merely a deterrent.
The perimeter of a CSP can be hard to identify as it may simply be a carrier's trunk into a building or it could be a series
of micro instances running as load balancers.
VM Attacks
Once a VM is compromised, the attacker has access to the shared services of that VM.
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Study Guide | Certified Cloud Security Professional (CCSP)
Hypervisor Attacks
• Hypervisors are a great target because they provide control over hosted VMs and access to shared
resources.
• Common hypervisor attacks are known as hyperjacking in which an attacker will hijack a hypervisor using a
Virtual Machine Monitor (VMM) such as:
• SubVirt
• Blue Pill: Hypervisor rootkit using AMD Secure Virtual Machine (SVM)
• Vitriol: Hypervisor rootkit using Intel VT-x
• Direct Kernel Structure Manipulation (DKSM)
• VM Escape is another type of attack in which the attacker crashed the guest OS of a VM in order to run
attack code that allows them to take control of the hypervisor host.
• Virtual switches are vulnerable to some of the same attacks as physical switches, such as:
• VLAN hopping
• ARP table overflow
• ARP poisoning
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Study Guide | Certified Cloud Security Professional (CCSP)
The hypervisor allows multiple operating systems to share a single hardware host. The hypervisor is the single most
critical component in virtualization.
Types of hypervisors:
• Type 1 hypervisor: Bare metal hypervisors that run directly on the hardware using a hypervisor operating system
(e.g., VMware ESXi and Citrix XenServer)
• Relate to hardware security
• Has a reduced attack surface compared to Type 2 hypervisors
• Vendor controls all software on the hypervisor OS
• Increased reliability and robustness over Type 2 hypervisors due to closed environment
• Type 2 hypervisor: Run on a host OS and provide virtualization services (e.g., VMware Workstation and Virtual Box)
• Relates to OS security
• More attractive to attackers because they can use vulnerabilities of the host OS and any other applications
installed on the machine
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Study Guide | Certified Cloud Security Professional (CCSP)
Data Breaches
Data Loss
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Study Guide | Certified Cloud Security Professional (CCSP)
• This type of hijacking is frequently done via social engineering attacks (phishing of some sort).
• Some attacks use sniffing to capture credentials.
• Newer attacks use communications from a compromised third party that is a trusted organization, such as a
vendor.
• Awareness is key to thwarting these attacks.
• MFA should be used on all services accessible from the internet.
Denial of Service
• Denial of Service (DoS) attacks prevent users from being able to access services
• DoS attacks can target:
• Memory buffers
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Study Guide | Certified Cloud Security Professional (CCSP)
• Network bandwidth
• Processing power
• And much much more
• Distributed DoS (DDoS) attacks are launched from multiple locations against a single target.
• Need to work to reduce single points of failure to limit effectiveness of DoS attacks.
Malicious Insiders
• Someone intentionally misuses access to data, which affects the confidentiality of that data.
• This someone could be a current or former employee, contractor, or other business partner.
• If willing to pay for resources, attackers can use cloud services for harm, such as:
• Dictionary attacks
• DoS attack
• Password cracking
• CSPs do watch for some of these activities (specifically DoS) and do work to mitigate them.
• Due diligence: The act of investigating and understanding the risks a company faces
• Due care: The development and implementation of policies and procedures to aid in protecting the company from
threats
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Study Guide | Certified Cloud Security Professional (CCSP)
As cloud is often a shared environment, meaning underlying hardware and technologies are shared, any vulnerabilities
that reside in that hardware or technology is also shared.
Cloud providers should use a defense-in-depth strategy and implement controls for each layer:
• Compute
• Storage
• Network
• Application
• User security enforcement
• Monitoring
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Study Guide | Certified Cloud Security Professional (CCSP)
Data should be managed across a lifecycle that includes the following six phases:
1. Create
2. Store
3. Use
4. Share
5. Archive
6. Destroy
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Study Guide | Certified Cloud Security Professional (CCSP)
D2. Cloud based Disaster Recovery (DR) and Business Continuity (BC) planning
• Business Continuity Management (BCM): The process of reviewing threats and risks to an organization as part
of the risk management process
• Disaster Recovery Planning (DRP): The process of creating plans to execute in the event of a disaster
• The goal of DRP is to quickly reestablish the affected areas of the business.
• Not all services are equal.
Revenue-centric services will be of more importance.
• Critical success factors for business continuity (BC) in the cloud are:
• Understand your responsibilities versus the CSP's
Customer's responsibilities
CSP's responsibilities
Interdependencies or third-party vendors such as application vendors
Order of restoration, what has priority
Right to audit capabilities to validate capabilities
Communications of any issues
Need for backups in a secondary location other than the CSP
• Document in the SLA what BCDR is handled by CSP and to what degree
Penalties for loss of service
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Study Guide | Certified Cloud Security Professional (CCSP)
RTO/RPO
Loss of integrity
Points of contact and escalation process
Failover capabilities
Communication of changes being made
Clearly defined responsibilities
Where third parties are being used by the CSP
• Cloud customer should be fully satisfied with the BCDR details prior to signing any agreements or accepting
terms. Once signed, future modifications may result in charges to the customer.
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• Resource pooling: CSPs offer pooled resources that keep cost down, and that savings is passed on to the
customers.
• Shift from CapEx to OpEx: Why not use a "pay as you go" model instead of a large upfront investment?
• Factor in time and efficiencies: Cloud is easy to manage and has much automation built in.
• Include depreciation: By using cloud, there is no company owned to depreciate off the books.
• Reduction in maintenance and configuration time: CSPs handle a large portion of this.
• Shift in focus: Allows for more focus on the business as less labor is required to manage a cloud environment.
• Utility costs: No need to pay for added electricity and cooling of on-premises hardware.
• Software and licensing cost: CSPs can provide great pricing on licenses as they purchase in bulk, and this cost is
often included in the services being purchased.
• Pay per usage: Only pay for what you use and the ability to track usage so individual users/departments can be
billed internally.
Other things to consider when calculating the total cost of ownership (TCO):
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• Functional requirements: Services required for a person or the business to accomplish their job
• Does cloud meet your functional requirements?
• Does a specific cloud vendor meet your functional requirements?
• Vendor Lock-In: A situation in which a customer may be unable to leave, migrate, or transfer from one CSP to
another
• Contract and SLA review is a must.
• Interoperability: The ability of a cloud service customer to interact with cloud services in a predictable manner, or
the ability for one cloud service to interact with another cloud service
• Avoid proprietary formats and technology.
• Regularly review legal and regulatory requirements.
• Portability: The ability for a cloud service customer to easily migrate their data between cloud service providers.
This is a key factor to consider when considering a cloud service provider.
• Ensure favorable contract terms for portability.
• Have an exit strategy from day one.
• Avoid proprietary formats and technology.
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Study Guide | Certified Cloud Security Professional (CCSP)
OWASP Top 10: A list of the 10 most common web application security risks
Key Thought:
How can we evaluate cloud vendors effectively? Surely there's a tool out there to
help with this! Well, there are several. Here are the two main tools:
• Cloud Certification Schemes List (CCSL): Provides an overview of different cloud certification schemes
(certifications) and shows the main characteristics of each scheme
• CCSL answers questions such as:
What are the underlying standards?
Who issues the certification?
Is the CSP audited?
Who performs the audits?
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• CSA Security, Trust, and Assurance Registry (STAR): Created in 2011 as there was a need for a single consistent
framework by which cloud vendors could be evaluated. STAR is now managed by the Cloud Security Alliance (CSA).
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These tools help us better grasp standards (schemes/certifications) criteria and identify which ones we should look to
abide by.
There are many standards out there, and they each have their own way of looking at security. Let's take a look at a few
of them:
• ISO 27001: Most widely known and accepted information security standard. ISO 27001:2013 consists of 114 security
controls across 14 domains of security. It doesn't specifically address cloud security, so it cannot be used as a single
source for cloud security.
• ISO/IEC 27002:2013: Provides guidelines for security standards but isn't certified against like 27001 is; it's more
used for reference.
• ISO/IEC 27017:2015: Offers guidelines for information security controls for the provisioning and use of cloud
services for both CSPs and cloud customers.
• SOC 1/SOC 2/SOC 3: The Service Organizational Control (SOC) is a security control certification program.
• SOC 1: Focuses on service providers and is related to financial statements.
Type 1: Auditors' findings at a point in time
Type 2: Operational effectiveness over a period of time (six months to one year)
• SOC 2: Meant for IT service providers and cloud providers. Addresses the five Trust Services Criteria (Security,
Availability, Processing Integrity, Confidentiality, Privacy), providing a detailed technical report. Also uses a Type
1 and Type 2 report scheme like SOC 1.
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• SOC 3: Covers the same content as SOC 2, but the report only identifies success or failure of the audit and
doesn't contain sensitive technical information like the SOC 2 report would.
• SOC reports are performed in accordance with Statement on Standards for Attestation Engagements (SSAE) 16
(which replaced SAS 70).
• NIST SP 800-53: Used to ensure the appropriate security requirements and controls are applied to US federal
government information systems. Risk management framework.
• PCI DSS: A security standard with which all organizations that accept, transmit, or store card data must comply.
There are four merchant levels based on the number of annual transactions which define the level of compliance
required and the amount of audits each must conduct. As a processor, you can never store the credit card
verification (CCV) number. There are over 200 controls in the standard.
Why do we need to verify cloud vendor systems are certified against standards?
• Our data resides on the vendor's systems, and we must "trust" the vendor to maintain confidentiality, integrity, and
availability (CIA) of our data.
• Cloud vendors that meet standards are more likely to provide us with the CIA we require, which reduces our risk.
• Imagine using a cloud vendor that has no certifications.
• We know nothing about their capabilities — only what they tell us.
• No third-party audits have taken place to validate the vendor's claims.
• Trusting this vendor would be a high-risk decision.
Common Criteria (CC) Assurance Framework (ISO/IEC 15408-1:2009): International standard designed to provide
assurances for security claims by vendors
• Primary goal is to ensure customers that products have been thoroughly tested by third parties and meet the
specified requirements.
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FIPS 140-2: A NIST document that lists accredited and outmoded crypto systems
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• Location: Data moves around between locations. Services are designed to replicate data across geographic regions
to guarantee availability. Important data should always be stored in multiple locations for redundancy.
• Storage slicing/data dispersion: This is a newer technology in which data is broken into chunks and encrypted,
and adds extra bits (erasure coding) used for redundancy, similar to the way RAID works on hard drives. Then the
blocks are stored across geographic regions. This allows for retrieval of data in the event multiple data locations go
offline.
• Automation: Allowing for data to be dispersed automatically. This is why policies surrounding data dispersion is
critical. (Ex.: Intellectual property [IP] data cannot leave the continental US.) Also, consider the cost of accidentally
replicating terabytes of data across multiple geographical regions. This is another reason dispersion policies are
important.
• IaaS: Providers offer different classes of service that automatically replicate data across geographically disperse
locations.
• PaaS/SaaS: Investigate prospective vendors to ensure they practice data dispersion. This may be an additional
feature, with additional costs, that is not enabled by default.
IaaS Storage
• Volume: A virtual disk attached to a virtual machine (e.g., VMFS, AWS EBS)
• Object: A storage pool like a file share (e.g., AWS S3)
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• Ephemeral: Temporary storage used while a system is up and running. Once the system shuts down, this storage
goes away with all data on it.
PaaS Storage
• Structured: Organized data, such as relational databases using tables, keys, rows (e.g., SQL)
• Unstructured: Data files such as text files, media files, or other files. Considered unstructured because it's not in a
traditional database format (e.g., AWS NoSQL).
• Raw storage: Raw device mapping (RDM) is an option within VMware virtualization that allows for direct mapping
to physical storage such as LUNs
• Long term: Data archival services such as Amazon Glacier
• Content Delivery Network (CDN): Content (files) are stored in geographically dispersed object storage, used to
improve user experience by increasing delivery speeds
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In a cloud environment, unless you have raw data storage (direct disk access), you cannot truly perform the
wipe actions as this requires disk access.
Most CSPs put the burden of sanitization on the customer.
Crypto shredding is the best option if you don't have raw disk access.
• Data in motion (DIM): IPSec can be used via VPN; SSL and TLS can be used across the web.
• Data at rest (DAR): Disk encryption or encryption managed by a storage system.
• Data in use (DIU): Information rights management (IRM) and digital rights management (DRM). DRM has been
used for the entertainment industry (e.g., CDs, DVDs, software, etc.); IRM is meant more specifically for documents.
Encryption Architecture
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• Key management is paramount. Whether the key resides with the CSP or the customer, both must protect the key
from unauthorized access.
• If the CSP must process encrypted data, there may be issues with indexing of metadata.
• Multitenancy due to shared resources such as RAM where encryption keys could reside temporarily.
• Most often must use software-based encryption, which is more vulnerable to attacks than hardware-based
encryption.
• Encryption can impact performance.
• Some solutions force all users and services to go through an encryption engine. This may be a single point of
failure and can cause performance issues.
• Data integrity can still be affected with file replacement or tampering. Digital signatures may need to be used to
protect file integrity.
• Basic storage-level encryption: Only protects from hardware theft or loss. CSPs may still have access to view the
data. (Ex.: AWS S3)
• Volume storage encryption: Encrypts a storage volume that is mounted and used by the customer through the
operation system. Protects against hardware theft or loss, snooping CSP admins, and storage-level backups that
could be taken anywhere and viewed. Does not protect against access through the operating system, such as an
attacker gaining access.
• Two methods to implement volume storage encryption:
Instance-based: The encryption engine resides on the instance itself.
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Proxy-based: Encryption engine runs on a proxy instance. This proxy handles encryption and key
management and storage. The proxy maps the volume data to the instance for secure access.
• Object storage encryption: Since using basic storage-level encryption is known to be less effective, it's best to use
external mechanisms to encrypt the data before sending it to the cloud.
• File-level encryption: Using an IRM or DRM solution will allow for individual file protection.
• Application-level encryption: The encryption engine resides in the application itself. The application pulls
encrypted data, decrypts and processes it, and then re-encrypts it before putting it back on the file system.
• Database encryption:
• File-level encryption: As previously discussed.
• Transparent encryption: The encryption engine resides within the database itself. Database files are stored
encrypted and unencrypted by the database at time of use.
• Application-level encryption: As previously discussed.
Key Management
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• Keys should always remain in a trusted environment and never transmitted in plaintext
• Loss of keys equals loss of data
• Key management functions should not be done by the CSP to enforce separation of duties
• Internally managed: Keys are stored on the virtual machine or application where the encryption engine also
resides; protects against lost media.
• Externally managed: Keys are stored separate from the encryption engine and data. Must consider how key
management is integrated with the encryption engine.
• Managed by a third party: Key escrow services
• CSPs normally use software-based encryption to avoid costs associated with hardware-level encryption.
• Software-based encryption doesn't meet NIST's FIPS 140-2 or 140-3 specifications. Software encryption has a hard
time identifying tampering. May cause an issue if you work with US federal government agencies.
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C2. Hashing
Hashing: Using a one-way cryptographic function to create a new value that will replace sensitive data.
Hashing:
• Data obfuscation is the process of changing data so it doesn't appear to be what it is.
• Generally used to comply with standards by masking sensitive data (SSN, DOB, etc.).
• Sometimes used to turn production data into testing data by masking sensitive data points.
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C4. Tokenization
Tokenization: Replacing sensitive data with a non-sensitive piece of data known as a token. This token can map back to
the original sensitive information when it needs to be used.
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Data Loss Prevention (DLP): Security controls put in place to prevent certain
types of data from leaving the organizational boundaries
DLP Components
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DLP Architecture
• Data in motion (DIM): Network-based or gateway DLP. Monitors SMTP, HTTP, HTTPS, SSH, FTP, etc., for sensitive
data and prevents it from leaving the organization.
• Data at rest (DAR): Storage-based. Used for tracking and identification data as it's installed on the system where
the data resides. Generally needs another mechanism for any enforcement.
• Data in use (DIU): Client- or endpoint-based. Resides on users' workstations. Requires great amount of
management. Not easy to deploy and manage.
• Data movement (replication): Can be challenging for DLP systems to deal with
• Administrative access: Discovery and classification can be difficult in dispersed cloud environments
• Performance impact: Network or Gateway DLP solutions can impact network performance, while workstation DLP
solutions can slow down endpoints
• CSP approval: May need CSP approval to deploy a DLP solution. If it's a hardware solution, this would be hard to
get approval for. If it's CSP product, no approval is necessary. If it's software you're deploying into PaaS, then
approval is not likely necessary. If deploying a virtual image DLP into IaaS, it's best to check with the CSP.
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Anonymization: The process of removing direct and indirect identifiers. Can be done by sampling like data and
generalizing the data by ensuring the group shares the same value when it comes to sensitive data. This would make it
hard to identify a single individual because all the sensitive data is the same between all user data.
Example scenario: In a system, there is a list of addresses. If all the addresses are grouped by zip code, it would make it
difficult to pick out the single person who lives in Baltimore if all of the addresses include Baltimore zip codes.
k-anonymity: An industry term used to describe a technique for hiding an individual's identity in a group of similar
persons.
Identifier Types
• Direct: Data that directly identifies someone (name, address, DOB, SSN, etc.) and is usually classified as PII.
• Indirect: Data that indirectly identifies someone (events, dates, demographics, etc.). When combining several of
these data points, it may be possible to identify someone.
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• If we don't already know the answer to this question, we need data discovery.
• Maybe we know what data we have, but we want to get more use out of it.
Unstructured data: Data in an unstructured format, such as a file share (AWS S3, NoSQL)
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• Metadata: Information about the file (owner, size, create date, etc.)
• Labels: Labels assigned to data by the owner
• Content analysis: Analyzing data content, looking for keywords
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Classifications:
E1. Mapping
Mapping: Locating data and recording its location, data format, file types, and location type (database, volume, etc.)
E2. Labeling
Labels: Tags applied to data by the data owner which describe the data
Common Labels
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Sensitive Data
F1. Objectives
Information rights management (IRM): A form of security technology used to protect data by adding independent
access controls directly into the data
• Adds an extra layer of access controls on top of the data's inherent controls
• IRM's access controls are embedded into the data object and move with the data
• Can be used to protect data other than documents, such as emails, web pages, databases, etc.
• Often used interchangeably with DRM (digital rights management)
Data rights: Controlling access to data based on centrally managed policies. Who has the right to access the data?
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Provisioning
Access Models
• Mandatory access control (MAC): Grants access based on labels such as confidential or secret, according to
organizational policy. Most restrictive access model.
• Role-based access control (RBAC): Grants access based on the user's role or responsibility according to
organizational policy.
• Discretionary access control (DAC): The system or data owner controls who has access; it's at their discretion.
• Each individual resource must be provisioned with an an access policy (heavy management).
• Each user must be provisioned with an account and keys (look into automation of enrollment).
• Most IRM platforms require each user to install a local IRM agent for key management.
• When reading IRM-protected files, the reader software must be IRM aware.
• Mobile platforms have known issues with IRM compatibility.
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• Retention formats: What type of media is used, if it is encrypted, and the retrieval process
• Data classification: How specific data classifications will be stored and retrieved
• Archiving and retrieval procedures: Detailed instructions on this process
• Policy review and enforcement: How often the policy will be reviewed for effectiveness and who is responsible for
enforcing the policy
AWS Config is a service allowing you to assess, audit, and evaluate the configurations of your AWS resources. It provides
the ability to create retention policies for data and will auto-delete data based on policy rules.
Need to have a data disposal policy that outlines the procedures used to delete or sanitize cloud data.
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1. AWS uses techniques outlined in NIST 800-88, "Guidelines for Media Sanitization," when decommissioning
customer data.
2. Amazons EFS (Elastic File System) is designed in a way that once data is deleted, it will never be served again.
Data archiving: Process of identifying and moving inactive data from a production system into a long-term archival
storage system
Long-term cloud storage is less expensive than production system storage. It is less expensive because it may take
several hours to complete the data retrieval process (not instantly available like production data).
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If an organization is involved in litigation (pending legal actions), they may be notified of required compliance with a
litigation hold or legal hold.
• At this point, the organization must show good faith efforts in preserving any data related to the case until the
obligation no longer applies.
• Routine data retention and destruction procedures must be suspended until the legal hold is over.
• Organization may send out a "litigation hold notice" to internal departments.
• If the organization doesn't comply, they can be guilty of "spoliation," which is a failure to preserve evidence.
• Use a Vault Lock, which allows for a non-readable and non-rewritable format that meets several regulatory
requirements dealing with legal holds.
• Legal hold can be enabled on a Glacier Vault (long-term storage) by creating policy that denies the use of delete
functions.
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Event sources: These are what will be monitored to collect event data
• Since the organization is using the PaaS platform to develop on, the organization's development team will need to
be worked with to gain an understanding of what logs are available and how to access them.
• According to OWASP, the following application events should be logged:
• Input validation failures (protocol violations, unacceptable encoding, invalid parameter names and values)
Could be an attempted injection attack
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• Output validation failures (database record set mismatch, invalid data encoding)
• Authentication successes and failures
• Authorization (access control) failures
• Session management failures (cookie session ID value modification)
• Application errors and system events (runtime, connectivity, performance, file system errors, third-party errors)
• Use of high-risk functions (add/remove users, permission changes, privilege changes, assigning of tokens,
creation and deletion of tokens, use of sys admin privileges, use of encryption keys, access to sensitive data,
creation and deletion of objects, data import and export activities, etc.)
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Event attributes: Information about individual event entries in logs, such as:
• Timestamp
• Event ID
• Application ID (name and version)
• IP address
• Service name
• Geolocation data
• URL, form, web application name
• Code location
• Account involved
• Source address
• Severity
• Description
• Result
• Reason
• HTTP status code
• User type classification (authenticated, authorized)
AWS offers centralized logging built upon the Amazon Elasticsearch Service, which allows for collection and analysis of
AWS services logs.
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Security information and event management (SIEM): A system that collects logs from many systems and provides
real-time analysis of the data, providing alerting and reporting for specific events. SIEMs are sold as software,
appliances, or as a managed service.
• Data aggregation: Bringing many logs from operating system, network devices, and applications together for
analysis
• Correlation: Looking for common attributes within the logs that may be used to chain together events
• Alerting
• Dashboards: Much quicker than reading through reports
• Compliance: Can generate compliance reports based on event log data
• Retention: Long-term storage
• Most SIEMs don't provide long-term storage in an active manner. They tend to offload events after a certain age
to an internal archival area. This is due to the fact that you could end up with billions upon billions of events
over time, and most systems cannot manage that much data efficiently.
• Forensic analysis: Searching through logs from many systems by specific date, time, or other criteria
Chain of custody: The protection and preservation of evidence throughout its life
Documentation should exist that shows the following information for evidence:
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• Where evidence is located, at what dates, and who placed it there (for storage of evidence)
• Transfer of evidence
• Any access to the evidence
• Any analysis performed on evidence
The chain of custody form should be used for transfer of evidence between individuals.
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Infrastructure Security
Shared responsibility: The idea that the CSP is not wholly responsible
for security, but it is shared responsibility between the customer and
the CSP
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Network Functionality
Software-defined networking (SDN): Allows for networking to become completely programmable and the underlying
hardware is simply commodity hardware. The goal is to make networking more agile, flexible, and centrally managed.
A3. Compute
• Number of CPUs
• Amount of memory
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Shares: Each guest is assigned a number of shares and when contention occurs, those shares determine the amount of
the available resources that guest receives
A4. Virtualization
Capacity monitoring is used to ensure fair, policy-based resource allocation is being provided to tenants of the virtual
environment.
Hypervisor: Software, firmware, or hardware that makes the guest OS think it is running directly on physical hardware
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A5. Storage
The primary protection of data at rest is encryption, which helps ensure confidentiality.
Block Storage
Primary role of storage is to group disks together into logical volumes ( LUNs, virtual disks, generic volume storage, and
elastic block storage)
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Key role of the management plane is to create, provision (create), start/stop VM instances, and live migration of VMs.
Customers have access to part of the management plane via a web management portal, a command line interface, and
APIs.
The management plane is very high risk due to the possibility of software vulnerabilities being present, and a
vulnerability could lead to access across multiple tenants.
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Data center provides many basic services known as "Power, Pipe, and Ping," which relates to:
• Electrical power
• Pipe refers to air conditioning
• Ping refers to network connectivity
• Power and pipe limit the density of servers in a data center
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Multitenancy
Monitoring Capabilities
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Use of Automation
Access Control
Service Models
• Logging abilities
• Retention periods
• Reporting capabilities
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Location
• May impact customer's ability to meet legal and regulatory compliance due to the physical location being in a
different jurisdiction
• Must have a clear understanding of all compliance requirements ahead of time
Design Considerations
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• Telecommunications
• Clean water
• Clean power
• Accessibility
Protection
• Fences
• Walls
• Gates
• Electronic surveillance
• Ingress and Egress monitoring for audit purposes
Buy or Build
• Building Industry Consulting Service International (BICSI): ANSI/BICSI 002-2014 standard covers cabling design and
installation.
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• International Data Center Authority (IDCA): Infinity Paradigm covers data center location, facility structure, and
infrastructure and applications.
• National Fire Protection Association (NFPA): NFPA 75 and 76 specify how hot or cold aisle containment should be
done. NFPA standard 70 requires implementation of emergency power-off buttons to protect first responders.
• American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE) Technical Committee 9.9
provides guidelines for data center temperature and humidity.
• Temperature: 64.4-80.6°F, 18-27°C (at equipment intake)
• Humidity: 40% @ 41.9°F (5.5'C) to 60% @ 59°F (15°C)
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HVAC Considerations
Air Management
• Work to prevent any mixing of incoming cool air and exhaust hot air
• Prevents heat-related outages
• Reduces power consumption
• Reduced cooling costs
• Key design issues:
• Configuring equipment intake and exhaust ports
• Location of supply and return
• Large-scale airflow patterns in rooms
• Set temperature of the airflow
Cable Management
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Types of Risks
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• Legal risks
• Data protection: Customer is ultimately responsible for protecting sensitive data such as PII.
• Jurisdiction: In the cloud, your data may reside in different jurisdictions, affecting regulatory compliance.
• Law enforcement: If a tenant is mandated to hand over data to law enforcement, it's possible that tenant could
inadvertently expose other tenant's data.
• Licensing: If a customer moves an application to the cloud, the licensing agreement must be reviewed for
legality and any cost consequences (per CPU licensing).
• Data ownership: It's possible a cloud vendor could try to take ownership of data created in the cloud by stating
it was created on their platform, therefore they own it. Contractual wording should be used to prevent this.
Cloud-Specific Risks
• Management plane breach: Most important risk because this would give the attacker access to the entire
infrastructure.
• Resource exhaustion: Oversubscription by the CSP may result in a lack of resources for your cloud services, which
may cause an outage
• Isolation control failure: When one tenant is able to access another tenant's resources or affect another tenant's
resources.
• Insecure or incomplete data deletion: Be sure to use crypto shredding.
• Control conflict risk: Implementing excessive controls can cause a lack of visibility.
• Software-related risk: Software is prone to vulnerabilities and must be kept up to date.
• Man-in-the-middle attacks: Cloud solutions increase the risk of man-in-the-middle attacks.
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Virtualization Risk
Compensating Controls
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Access Controls
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• PCI DSS
• HIPAA
• NERC CIP (critical infrastructure protection)
• Policies and procedures dictate how we implement and manage security controls
• Physical access
• Physical perimeter security (fences, walls, barriers, gates, electronic surveillance, guards)
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• Multiple layers
• Guard at gate
• Badge at gate
• Badge at main door
• Guard at main door
• Biometric check plug badge at each zone with mantrap
• Redundant services (power, cooling, HVAC, etc, networking, etc.)
CSP Personnel
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Trust zones can be used to segregate network traffic as they are used
to control how data is permitted to flow.
Trust zones control access in both directions (in/out) and protect data's
confidentiality and availability.
• VLANs can be used to separate data, which helps provide data confidentiality and integrity. VLANs also help reduce
resource contention and are very often mandated by compliance standards.
• Encryption is another way to protect encryption in motion by using:
• VPNs (IPSec)
• SSL/TLS (HTTPS)
• Within the network, other security controls are available, such as:
• Firewalls or security groups (access lists)
• DLP
Data backups:
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• To a secondary CSP
• Avoids provider lock-out
Snapshotting of images should be considered for use with incident response and any forensic work that needs to be
done.
Identity federation: Trust relationship between multiple identity management platforms at different organizations to
provide identity services
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Identity Providers
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Purpose of a risk audit is to provide assurance that proper risk controls are in place and functional.
Cloud Security Alliance Cloud Controls Matrix (CCM) provides a framework for CSPs to demonstrate adequate risk
management.
Compliance audits will need to be conducted by a representative (regulator) from the industry or organization when the
compliance requirements are set.
Audits of the cloud don't generally include physical access, so the reports may be less complete than an on-premises
audit.
Audits of cloud vendor data centers can sometimes be considered less trustworthy because of the reliance on third
parties to verify data.
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• BCDR strategies normally include high availability solutions, which are more complicated to manage and can lead
to a lack of technical skills
• Equipment failure
• Geographically diverse locations used in BCDR may have network congestion issues
• Regulatory compliance issues if a DR location is in a separate jurisdiction
• Poor encryption key management
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• Are all of the same CSP services available in the failover zone?
• Have the CSP's capabilities been tested?
Recovery Time Objective (RTO): Acceptable amount of downtime for business-critical applications before they need to
be functional again after an event
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Recovery Point Objective (RPO): Acceptable amount of data the organization is willing to lose if restoration is required
after an event
• Data replication occurs every four hours, so the most the organization would lose is four hours.
• How to lose less?
• Replication more often
Increased bandwidth needed
Licensing requirements
Recovery Service Level (RSL): A percentage (0–100%) of the amount of resources (compute) needed during a disaster
based on the service revived during that period
Cloud providers often offer proprietary BCDR technologies that can keep RTO/RPO to near zero.
Location
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Data Replication
• Block-level replication protects against data loss but not database corruption
• Look at other options for data types, such as databases
• Must keep in mind storage and bandwidth limitations
Functionality Replication
Other Considerations
• Using a second CSP to replicate to, which may reduce the risk of using a single CSP
• Personal safety is the most important thing
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• Cluster managers
• Load balancers
• DNS changes
• Ensure these are not single points of failure
• Invoking of a BCDR action depends on the contract with the CSP
• Could be the client or the cloud provider
Return to Normal
• Define a scope
• Roles (who will do what)
• Risk assessment
• Policies (determine what constitutes declaring an emergency)
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• Plan design
• Establish and validate architected solution
• Include procedures and workflows
• Define owner(s)
Technical (deployment and maintenance)
Declaring emergency
Communications to customers
Internal communications
Decision makers in the event of issues
• How will BCDR plans be tested?
Enterprise-wide testing plans should address every business-related service
Should be fully tested annually with semi-annual training (walkthrough) or when significant changes occur
within business operations
Each line within the business should be fully tested to ensure it will survive
Testing of any external dependencies
• Testing policy
• RTO/RPO must be measured to ensure attainability
• Testing objectives should start simple and expand to encompass the entire plan
Test individual services
Test internal dependencies
Test external dependencies
• Should include test planning
Scenarios
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It's recommended to use the word "exercise" and not "test" when carrying out BCDR validation.
Tabletop Exercises
• Designed to ensure critical personnel are familiar with BCDR and their roles
• Participants follow a pre-planned response
• Not the preferred testing method
• Consists of:
• Attendance of key personnel
• Discussion about each person's responsibilities
• Walkthrough of each step of the procedure
• Problems identified during testing
• Provide each participant with a copy of the BCDR plan
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Full-Interruption/Full-scale test
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In most cloud environments, APIs are used to access application functionality, and they use tokens instead of traditional
username and password for authentication.
• Representational State Transfer (REST): Consists of guidelines and best practices for creating scalable web
services
• Simple Object Access Protocol (SOAP): Protocol for exchanging structured information as part of a web service
• REST supports many formats such as JSON, XML, and YAML, whereas SOAP only supports XML.
• REST uses HTTP/HTTPS for data transfer; SOAP uses HTTP/HTTPS/FTP/SMTP to transfer data.
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• REST has good performance and is scalable; SOAP is slower and scaling is complex.
• REST is widely used; SOAP is used when REST is not possible.
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Identifying who is responsible for security controls is imperative. Creating a responsibility matrix can be helpful in
identifying who is responsible for which security controls.
The most common cloud vulnerabilities are identified in the OWASP Top 10, which we will cover later in this section.
Business requirements are included in the first phase of the SDLC where we attempt to identify business needs of the
application (accounting, database, customer relations, etc.).
Refrain from identifying technologies at this point — concentrate on the needs of the business.
Following a software development lifecycle (SDLC) is critical when developing applications for the cloud. ISO/IEC 12207
is one example of an SDLC.
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• Defining
• Document all requirements and get a signoff by the customer
• Designing
• Design of the application, which impacts architecture and hardware
• Threat modeling and secure design elements should be discussed here
• Developing
• Coding starts, and this phase takes the longest
• Code review, testing, and static analysis is performed
• Testing
• User acceptance testing (end user approval)
• Testing any integrations
• Maintenance
• Fixing bugs
• Patching identified vulnerabilities
Once an application goes into production, it enters the secure operations phase.
When the application is no longer needed, it's time for a disposal phase.
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ISO has developed the ISO/IEC 27034-1 "Information Technology - Security Techniques - Application Security," which
defines concepts, frameworks, and processes to help integrate security into software development lifecycles.
The ISO/IEC 27034-1 is one of the most widely accepted set of standards and guidelines for secure application
development.
Part of this standard outlines the organization normative framework (ONF), which consists of:
• Business context: Application security policies, standards, and best practices used by the organization
• Regulatory context: Standards, laws, and regulations the organization must abide by
• Technical context: Required and available technologies that can be used
• Specifications: IT functional requirements and solutions to meet the requirements
• Roles, responsibilities, and qualifications: Individuals and their roles
• Processes: Processes related to application security
• Application Security Control (ASC) Library: Contains a list of controls used to protect the application and its data
Application normative framework (ANF): Used in conjunction with the ONF and is created specifically for an
individual application. The ONF to ANF is a many-to-one relationship.
Application security management process (ASMP): Process to manage and maintain each ANF. Consists of five steps:
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Injection
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• When a web application accepts untrusted data and sends it to a web browser without proper validation, which can
allow an attacker to execute scripts in the victim's browser. Scripts can be posted in a forum, and visitors' browsers
will execute the scripts.
• Prevention: Use "escaping," which is the process of validating code before passing it to an application (making
sure it's not malicious).
• Prevention: Validate inputs to verify the data is not malicious and is expected data.
• When a developer exposes an internal object, such as a file, directory, or database that can be accessed without
authentication.
• Prevention: Use indirect object referencing where a value is used to represent an object and acts as a go-
between so the object itself is never exposed.
Security Misconfiguration
• Lack of security controls around sensitive data such as credit card data or PII.
• Prevention: Use proper security controls, such as encryption, to protect sensitive data.
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• Lack of access control surrounding functions of a web application can allow an attacker to forge requests to gain
access to these functions.
• Prevention: Ensure all functions are accessed via an authorization module, and set a global rule to deny access
by default.
• Where an attacker uses an authenticated user's browser to send forged HTTP requests on behalf of the attacker.
• Prevention: Anti-forgery tokens can be used to prevent CSRF from being successful.
• Frameworks, libraries, and other software modules can contain vulnerabilities that flow through into any
application they're used in.
• Prevention: Check all components being used for known vulnerabilities, and don't use any vulnerable
components.
• Web applications sometimes use redirects and forward users to other websites. Without validating these
destinations, attackers can cause users to be redirected to malicious websites.
• Prevention: Avoid using redirects and forwards if possible. If you must use them, avoid involving user
parameters in redirecting to the destination.
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To identify and address these vulnerabilities, organizations should have an application risk-management program
consisting of three parts:
One popular risk management framework is the NIST Framework for Improving Critical Infrastructure Cybersecurity.
• Encryption, because it may need to be built into the application depending on the CSP's architecture.
• Logging may be difficult.
• Ensure applications are using proper access controls.
• PaaS may not offer granular security.
According to the Cloud Security Alliance's "The Notorious Nine: Cloud Computing Top Threats in 2013," the following
are the top nine cloud-specific risks:
• Data breaches
• Data loss
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• Account hijacking
• Insecure APIs
• Denial of service (DoS)
• Malicious insiders
• Abuse of cloud services
• Insufficient due diligence (on behalf of the customer)
• Shared technology use
Validating quality assurance requires measuring variables to ensure quality is being met. These variables include:
• Availability
• Mean time between failures
• Outage duration
• Performance
• Reliability
• Capacity
• Response time
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• Spoofing
• Tampering
• Repudiation
• Information disclosure
• Denial of service
• Elevation of privilege
Proper software configuration management and versioning is an essential part of application security. Two popular
tools used for versioning are:
• Chef: Used to automate building, deploying, and managing infrastructure components. Configs and policies are
stored as recipes. The Chef client is installed on each server, and they poll the Chef server for the latest policy and
update their configs automatically based on the Chef server policies.
• Puppet: Allows you to define the state of your infrastructure and then enforces the correct state.
The goal of these tools is to ensure configurations are up to date and consistent based on the version of policy or
config.
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Validates that business requirements have been met and the application operates as expected without errors.
• Static Application Security Testing (SAST): Considered a white-box test where the test performs an analysis of the
source code and binaries without executing the code.
• SAST is used to identify coding errors that may be an indication of a vulnerability.
• SAST can be used to find XSS, SQL injection, buffer overflows, and other vulnerabilities.
• Because it's a white-box test, the results are more comprehensive than dynamic testing.
• Often run early in the development lifecycle.
• Dynamic Application Security Testing (DAST): Considered a black-box test where the tool must discover
vulnerabilities while the application is running. DAST is most effective when testing exposed HTTP and HTML web
application interfaces.
SAST and DAST play different roles in application security testing. Where SAST is used early on in development to detect
coding problems, DAST is used to identify vulnerabilities of the application while it's running.
Vulnerability assessment: Scanning of an application by a vulnerability scanner or assessment tool, such as BURP or
OWASP ZAP. These applications look for well-known vulnerabilities and allow for automated scanning. Often run as a
white-box test.
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Penetration test: Process to collect information about a system and use that to actively exploit any vulnerabilities to
gain access to the system or its data. Penetration testing is often considered black-box testing in which the tester has
no knowledge of the application.
When performing security testing in a cloud environment, you must receive permission from the CSP in writing prior to
performing the testing. Some CSPs provide this on their website while others may require a formal written process.
OWASP has created a testing guide that recommends nine types of testing categories:
• Identity management
• Authentication
• Authorization
• Session management
• Input validation
• Testing for error handling
• Testing for weak cryptography
• Business logic
• Client-side
Application programming interfaces (APIs) are used to expose functionality of an application. APIs provide the following
benefits:
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• Automation
• Integration with third-party tools
APIs are components that must be validated for security just as every other component used in the creation and use of
applications.
External APIs used by the organization must also go through the same approval process to limit exposure to the
organization.
More and more software is being created by third parties and consumed by the masses to build applications and
services.
We must keep this in mind and validate all pieces of third-party software being used.
All third-party software should be validated and checked for vulnerabilities before use.
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Open-source software is considered by many to be rather secure simply because the source code is open and available
for anyone to view.
• This provides for much scrutinization of the code for best practice and functionality.
• Third-party software is often created in a closed environment with minimal review and testing because time is
money.
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• Firewalls
• Provide filtering capabilities
• API Gateway
• Filters API traffic before it's processed
• Can provide access control, rate limiting, logging, metrics, and security filtering
F2. Cryptography
When accessing data in the cloud, you are accessing the data across trusted and untrusted networks, so we need to
always protect data. One way to do that is by using encryption.
Transport Layer Security (TLS): TLS ensures data privacy and integrity between applications.
Secure Sockets Layer (SSL): The standard technology for creating an encrypted connection between a browser and
web server. All data passed is kept private and integral.
Virtual private network (VPN): Encrypts data between two endpoints. These endpoints can be firewalls, VPN
concentrator devices, agents installed on a workstation.
Whole instance encryption: Used to encrypt everything associated with a virtual machine, such as its volumes, disk IO,
and snapshots.
Volume encryption: Used to encrypt a volume on a hard drive. The entire disk is not encrypted, only the volume
portion. Full disk encryption should be used to protect the entire hard drive.
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F3. Sandboxing
Allows for analysis of applications and data in a secure environment without risk to the production environment.
Application virtualization is used to test applications while protecting the underlying OS and other applications on the
system. It's a form of sandboxing an individual application on a host. Example solutions are:
Federation Standards
• Security Assertion Markup Language (SAML): The most common federation standard.
• SAML is an XML-based framework used for federated communications.
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• WS-Federation: Defines mechanisms to allow different security realms to federate between each other.
• OpenID Connect: Lets developers authenticate their users across websites and apps without having to own and
manage password files; doesn't use SOAP, SAML, or XML.
• OAuth: Widely used for authorization services in web and mobile applications.
• Shibboleth: Heavily used in the education space.
Single sign-on (SSO) allows a user to authenticate once and access several
resources, preventing the need to authenticate while accessing each individual
resource.
SSO works by having the user log in to an authentication server, and then each
resource the user attempts to access checks with the authentication server to verify the user has successfully logged in
already.
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SSO makes the user experience more pleasant, and all of the SSO happenings
are transparent to the end user.
One-time passwords fall under MFA and are highly encouraged for use with
first-time logins.
Step-up authentication is also used for MFA when accessing a high-risk transaction or violations have occurred in the
transaction:
• Challenge questions
• Out-of-band authentication (SMS, text, phone call, etc.)
• Dynamic knowledge-based authentication (question unique to the individual, previous address, etc.)
CASB: A trusted third-party identifier that takes on the role of identity provider.
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When multiple parties operate in federated identity management (a federation), they must decide to trust each other.
This can be done in two ways:
• Web of trust model: Each organization has to review and approve each other's members for inclusion in the
federation. Can be time-consuming and tedious.
• Outsource to a third-party identifier, such as CASB.
Red Hat Satellite: An infrastructure management product that allows you to manage multiple hosts and environments
from a single dashboard. Satellite allows for integration with other Red Hat products such as Insight, which we'll take a
look at in just a little bit.
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For Servers
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Extremely important to properly configure virtualization management tools. If compromised, the attacker may have
unlimited access to the virtual environment.
The virtualization vendor will determine what tools are available for use.
Best Practices
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Installation of the virtualization toolsets is one of the most important steps when setting up a cloud environment.
Physical access should be limited, and those who manage physical hardware should not have other types of
administrative access (separation of duties).
• Isolated data channels: Each channel connects to only one host so no data can be transferred between connected
computers through the KVM
• Tamper warning labels on each side of the KVM: Indicate tampering
• Housing intrusion detection: Cause the KVM to be inoperable once the housing has been opened
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• TLS uses x.509 certificates to authenticate a connection and exchange a symmetric encryption key used to securely
transmit data between endpoints.
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DNSSEC
Threats to DNS
• Footprinting: An attacker attempts to gather all DNS records for a domain via domain transfer in order to map out
the target environment.
• Denial of Service (DoS): Flooding of DNS servers can prevent the server from responding to DNS requests.
• Redirection: An attacker redirects queries to a server under the attacker's control.
• Spoofing: Also known as DNS poisoning where the attacker provides incorrect DNS information for a domain to a
DNS server, which will then give out that incorrect information.
IPSec
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Configuration management tools such as Puppet and Chef can ensure OSes are hardened according to a baseline or
policy.
It is important to monitor hosts for baseline compliance and remediate anything out of compliance. To do this, we need
to:
Business requirements may indicate the need for a stand-alone host in a cloud environment.
• Lack of elasticity
• Lack of clustering benefits
• Increased cost
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• Isolation
• Dedicated host
• More secure as it's not on a multitenant host (dedicated server)
• Regulatory issues
• Data classification
• Contractual requirements
• Current security policies
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• Secure access without opening extra ports and increasing the attack surface
• Isolation between the connecting user's desktop and the host being connected to (Virtual Desktop Infrastructure-
VDI)
The goal is to ensure real-time monitoring of OS configurations and baseline compliance is happening within the cloud.
Monitoring data should be centrally managed and stored for audit purposes.
The process of identifying, acquiring, installing and verifying patches for products, applications, and systems.
• Vulnerability detection
• Vendor patch notifications
• Patch severity assessment by the organization
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• Change management
• Customer notification if required
• Verification of successful patching
• Risk management in case of unexpected outcomes after applying patches (fallback plan)
In some cases, organizations may give blanket pre-approval for applying patches that address imminent risks, allowing
these patches to bypass standard change management process. Change management will happen after the fact.
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In a virtual environment, everything still runs on underlying hardware and it needs to be monitored:
• Environmental temperature
• Temperature within the hardware (motherboard/CPU)
• Fan speed
• Failed drives or drive errors
• Hardware components (CPU, memory, expansion cards, etc.)
• Network devices as well, not just servers
C6. Configuration of Host and Guest Operating System (OS) Backup and Restore
Functions
Host configuration data should be included in any backup plans in the cloud.
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The biggest challenge with backup and recovery is understanding the extent to which you have access to the hosts and
what configurations can be changed.
• Control: In the cloud, we make changes through a management interface, but we don't see what happens in the
background. We must be confident the changes we make are the only changes occurring.
• Visibility: Ability to monitor data and how it's being accessed.
• Vulnerability assessments
• Network security groups (access lists)
• VLANs
• Access control
• Use of secure protocols, such as TLS and IPSec
• IDP/IPS systems
• Firewalls
• Honeypots
• Zoning of storage traffic (like VLANs for storage data)
• Vendor-specific security products (VMware vCloud Networking and Security or NSX products)
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ISO 9001 - Quality and change management: Allows organizations to manage and control the impact of changes to
the environment
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ISO 22301 - Business continuity: Focuses on planning the necessary procedures for restoring a business to
operational state after an event occurs
This list is created through a business impact analysis (BIA) which will identify those systems and services critical to the
business
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• Security policies
• Security management
• Asset management
• Physical security
• Access control
• Information systems development, maintenance, and acquisition
ISO 9001 Continuous improvement // ITIL CSI (continuous service improvement): Metrics of all services should be
collected and analyzed to look for areas of improvement
The ITIL framework is one resource that can be used to help with this.
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ISO 20000 - Problem management: Goal is to minimize impact on the organization by identifying the root cause and
implementing a fix or workaround
A system should be in place to track problems and document root causes and workarounds.
ISO 20000 - Release and deployment management: Includes planning, scheduling, and controlling the movement of
releases to test and live environments
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ISO 20000 - Service-level management: Negotiate agreements with parties and design services to meet agreed-upon
service-level targets
Legal department should be included in contract creation, as they can have a financial impact on the provider if SLAs
are not met.
ISO 20000 - Availability management process: Define, analyze, plan, measure, and improve availability of IT services
The use of high availability (HA) and failover solutions help ensure availability.
ISO 20000 - Capacity management: Ensures the business IT infrastructure is adequately provisioned to meet SLAs in a
cost-effective manner
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Capacity must be monitored to ensure an over capacity event doesn't occur that will impact performance and meeting
goals.
The Process
• Data collection
• Develop a plan that prioritizes sources to be collected and in which order they are to be collected:
Value: Relative likely value of data sources (from past experiences)
Volatility: Data lost on a system once powered off or after a period of time (page file, memory, logs
overwritten by new events, etc.)
Amount of effort required: Collecting data from an on-premises host versus a cloud vendor's hypervisor.
Balance of effort and likelihood data will be valuable.
Chain of custody should be implemented
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Examination
Analysis
• Identify people, items, places, data, and events in an effort to piece together a conclusion.
• Use various systems like firewalls, IDS, security management software can help identify events.
Reporting
• There may be more than one possible explanation; be prepared to support all.
• Know your audience: Law enforcement will want details, whereas executives may simply want to know if anything
was determined by the evidence.
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• Actionable information may be identified that will lead to the need to collect additional information or may be used
to identify a way to prevent future events.
• Seizure of servers that may contain multiple tenants' data creates a privacy issue.
• Trustworthiness of evidence is based on the CSP.
• Investigations rely on CSP's cooperation.
• CSP technicians collecting data may not follow forensically sound practices.
• Data may be in unknown locations.
Network forensics (capturing of packets) may be necessary to help with a cloud-based investigation.
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When collecting evidence, be sure not to collect evidence outside the scope of the event.
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There are many standards covering the collection, acquisition, and preservation of digital evidence:
• ISO/IEC 27037:2012 — Guide for collecting, identifying, and preserving electronic evidence
• ISO/IEC 27042:2015 — Guide for digital evidence analysis
• ISO/IEC 27050-1:2016 — Electronic discovery
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There should be a clearly defined on-boarding process for partners, including granting access to systems. Don't forget
an off-boarding process as well.
F2. Customers
F3. Regulators
• Geography
• Business type
• Services offered
• Data type
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It's imperative a CCSP understand all regulatory compliance needs prior to planning a cloud environment to ensure
they can all be met.
A security operations center (SOC) is a command center facility for IT personnel specializing in security. From the SOC IT
professionals:
Most SOCs operate 24/7 and allow for more effective communications between IT security professional working
together on a team.
Once security controls are configured and deployed, they must be monitored:
• Firewalls
• IDS/IPS
• Honeypots
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• Vulnerability assessments
• Network security groups
All of these security controls create logs that must be captured and analyzed.
Various tools are available to collect and analyze log data from (event sources):
• Host servers
• Guest OSes
• Network devices
Security information and event management (SIEM): Used to centrally collect and analyze logs.
Logs must be managed or they will overwrite themselves and data may not be available when it's needed.
• Best to offload logs to a centralized log server, such as a SIEM or syslog server
• In the event of a breach, many attackers will wipe system logs to clear their tracks. A SIEM or syslog server will keep
a safe copy of the system logs for analysis
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Compliance
Cloud computing introduces many legal challenges for the security professional:
International law: Rules that govern relations between states or countries comprise:
State law: Refers to each US state's local laws within the state court
Copyright and piracy law: Protects the sharing of copyright material with others who are not the legal owners of said
material
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Enforceable governmental request: An order or request capable of being carried out on behalf of the government
(where there is jurisdiction)
Intellectual property (IP) right: Gives the person who created an idea the exclusive right to that idea. Patents,
trademarks, and copyrights are legal ways to protect the IP.
Privacy law: Recognition of a person's right to determine what personal information will be released to the public and
when that personal information must be destroyed (when it's no longer needed)
The doctrine of the proper law: When a conflicting of laws occurs, this determines the jurisdiction under which the
dispute will be heard. Generally based on contractual language through the choice-of-law clause.
Criminal law: A group of rules and statutes to protect the safety and wellbeing of the public
Tort law: These rules and regulations seek out relief for personal suffering as a result of wrongful acts.
• Compensates victims
• Shifts the cost of injuries to the offender
• Discourages careless and risky behavior
• Vindicates interests and rights that have been compromised
Restatement (second) conflict of laws: These are judge-made laws, not legislative-made laws, that come into play
when there are regions or states with conflicting laws. The judges must determine which laws are most appropriate for
the situation.
One risk is the loss of control of your data in the cloud due to an investigation or legal action being carried out against
your organization. To protect yourself, you should:
• Ensure your contract with the CSP states it is to inform you of any such events.
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• Ensure the contract states you are to be in control of making decisions about your data and how it's handled in
response to a subpoena or similar actions.
ISO/IEC 27017:2015 - Information technology - security techniques: Covers the use of security controls to protect
cloud data and services.
Organization for Economic Cooperation and Development: Privacy and Security Guidelines: The OECD published
guidelines governing the privacy and protection of personal data flowing across borders. Focused the need on global
privacy protection.
Asia-Pacific Economic Cooperation Privacy Framework (APEC): With 21 member countries, it provides a regional
standard to address privacy as an international issue and cross-border data flows. The framework is built upon nine
principles:
• Preventing harm
• Notice
• Collection limitation
• Use of personal information
• Choice
• Integrity of personal information
• Security safeguards
• Access and correction
• Accountability
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EU Data Protection Directive: Provides regulation and protection of personal information within the European Union.
Designed to protect all personal data collected about European Union citizens. Its guidelines state:
General Data Protection Regulation (GDPR): Goal is to protect all EU citizens from privacy and data breaches.
Different from the EU Data Protection Directive in that:
• It applies to all companies processing data of EU citizens no matter the location (globally).
• Organizations in breach of the GDPR can be fined up to 4% of annual global turnover or 20 million pounds —
whichever is greater.
• Conditions for consent must not be full of legal jargon but must be in intelligible and easily accessible form.
• Breach notifications must be given within 72 hours.
• Right to be forgotten (data erasure): Entitles the subject to have his/her data erased at will.
• Data portability: The subject has the right to receive a copy of all data from a processor in a machine-readable
format and have the right to transmit that data to another processor (controller).
• Denying service because a person doesn't consent to data collection is not permitted.
ePrivacy Directive: Created by the European parliament for the protection of privacy for data for electronic data being
processed in the electronic communications sector
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• US federal laws:
• Gramm-Leach-Bliley Act (GLBA): Requires financial institutions to explain how they share and protect their
customers' data
• Health Insurance Portability and Accountability Act (HIPAA): Provides data privacy and security provisions for
safeguarding medical information
In order for two HIPAA-compliant organizations to share HIPAA data, they must have a Business Associate
Agreement (BAA).
• Children's Online Privacy Protection Act (COPPA): Created to protect the privacy of children under 13
• Federal Trade Commission (FTC) Requires specific security controls be implemented to protect data
• Sarbanes-Oxley Act (SOX): Holds company executives accountable for data accuracy in an effort to prevent fraud
and protect shareholders and employees
• US state laws: Typically a minimum requirement of security controls for contractual obligations
• Standards:
• ISO standards
• Payment Card Industry (PCI-DSS): Designed to protect cardholder information
• Silver platter doctrine: In criminal law, this was a doctrine that a federal court could introduce illegally or
improperly state-seized evidence, as long as federal officers had played no role in obtaining it.
For example: If an employee was stealing sensitive company data and selling it to a competitor and the
employer found out, they could collect the proof and hand it over to law enforcement, and that proof
could be used legally in court because law enforcement was not involved in collecting the proof.
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A4. eDiscovery
E-discovery: Any process in which electronic data is sought, located, secured, and searched with the intent of using it as
evidence in a civil or criminal legal case
E-Discovery Challenges
• SaaS-based e-discovery: Some packages may be available to help discover, collect, and preserve data in the cloud.
• Hosted e-discovery provider: You can hire a hosted service provider to perform the e-discovery for you.
• Third-party e-discovery: Outsourcing to an organization who specialized in cloud-based e-discovery practices.
Cloud forensics: Practices aimed to reconstruct past cloud computing events by collecting, preserving, analyzing, and
interpreting cloud data evidence
Cloud forensics can be difficult because you may not have access to required data and may need to work with a CSP to
access the data.
ISO 27050 - eDiscovery: Works to globally standardize the cloud forensic approach
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Legal responsibility for data processing falls to the customer who signs up for services with a CSP. The customer is
ultimately responsible for managing the safety of data it uploads to the CSP.
This includes personally identifiable information (PII) and falls under US privacy law.
PII is data that can be used to identify, contact, or locate a living individual (SSN, driver's license number, address,
phone number, date and place of birth, mother's maiden name, or biometric records).
• Contractual PII: Where an organization processes, transmits, or stores PII as part of its business or a service. This
data must contractually be protected by the business providing the service.
• Regulated PII: When PII must be protected due to legal and statutory requirements based on regulations such as
HIPAA and GLBA. Regulatory protection is to protect individuals from risk.
• Both must protect PII, but one is for contractual reasons while the other is for regulatory reasons.
• Another differentiator related to regulated PII is mandatory breach reporting.
• NIST 800-122 is a useful resource for ensuring requirements for contractual and regulated PII are being met.
• Scope of processing: Identify the types of processing performed with data and what the purpose of the processing
is.
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• Use of subcontractors: Understand where data processing, transmission, and storage of data will take place and
any subcontracting involved.
• Deletion of data: Verify the data deletion process meets organizational policies.
• Data security controls: Security controls should be the same level across the processing organization and any
subcontractors.
• Location of data: To meet compliance, regulatory, and legal requirements, the location of organizations and
subcontractors must be known in order to keep track of the physical location of data.
• Return of data: When a contract is terminated, data must be returned in a timely manner.
• Right to audit: The customer should have the right to audit the organization performing processing and any
subcontractors used in the process.
European Union: The EU has prohibited EU data controllers from transferring personal information data outside their
country to non-European Economic Area (EEA) jurisdictions that do not have an adequate level of protection.
• In order for companies to transmit EEA citizens' personal data outside their country, companies must abide by
Directive 95/46/EC in the EU, or the Safe Harbor program in the US.
Directive 95/46/EC: Focuses on the protection of individuals as it pertains to processing personal data and the human
right to privacy as referenced in the European Convention on Human Rights (ECHR).
EU General Data Protection Regulation (GDPR): Strengthens individual rights to protect their personal data. GDPR
introduces some new changes, such as:
• Concept of consent
• Data transfers abroad
• The right to be forgotten
• Establishment of a data protection office role
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• Access requests
• Increased sanctions
• Services cannot be denied simply because a person doesn't participate in data collection
The following are ways an entity outside of the EU can be allowed to gather/process privacy data belonging to EU
citizens, according to GDPR:
United States: There is no single federal law governing data protection. There are few restrictions on the transfer of
personal data outside the US, which makes it easy to use CSPs located outside the US. However:
• The Federal Trade Commission (FTC) and US regulators hold that the applicable US laws and regulations apply to
the data after it leaves the US and the US-regulated entities who send data abroad remain liable for:
• Data exported outside the US
• Processing of data by subcontractors outside the US
• Abroad subcontractors using the same level of protection for regulated data
Safe Harbor program: Developed by the US and EU to address concerns that the US does not have in place a
regulatory framework that provides adequate protection for personal data transferred from the European Economic
Area (EEA).
• As an alternative to the Safe Harbor program, US organizations can use contractual clauses regulating the transfer
of personal data from the EU. Managed by the federal trade commission.
Privacy Shield Framework: As of July 12, 2016, The EU reversed its decision on the legal adequacy of the US Safe
Harbor Framework. The US now has the Privacy Shield Framework in place, which the EU deems adequate for
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protecting personal information. The new Privacy Shield Framework replaces the Safe Harbor program and is managed
by the Federal Trade Commission.
Stored Communications Act (SCA): Provides privacy protection for electronic communication and computing services
from unauthorized access or interception
Cross-Border Data Transfers: Canadian regulations covering processing of Canadian citizen data outside of Canada
Many other countries such as Switzerland, Argentina, Australia, and New Zealand follow rules similar to the EU's as it
pertains to data privacy.
CCSPs should always engage with legal professionals in the area of local and international laws prior to engaging in
cloud services.
ISO/IEC 27018: Addresses the privacy aspect of cloud computing and has five key principles:
• Consent: CSPs may not use personal data they receive from customers for marketing or advertising without
customer consent.
• Control: Customers have full control over how CSPs use their data.
• Transparency: CSPs must inform customers where their data resides and disclose the use of any subcontractors
who will have access to PII.
• Communications: CSPs must keep record of any incidents, their response to it, and inform customers.
• Independent and yearly audit: To be ISO/IEC 27018 compliant, CSPs must subject themselves to annual third-
party audits.
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Generally Accepted Privacy Principles (GAPP): The AICPA standard that describes 74 detailed privacy principles, which
are very similar to the OECD and GDPR principles
General Data Protection Regulations (GDPR): Data privacy protection for EU citizens covered previously in depth
ISO 27001 Information Security Management System (ISMS): Internal audits should be part of every ISMS, and their
goal should be to reduce risks related to the availability, integrity, and confidentiality of data while improving
stakeholder confidence in the security posture of the organization.
• ISO 27001 is the most widely used global standard for ISMS implementation.
An organization's internal audits act as a third line of defense after security controls and risk management.
Internal audit scopes are directly linked to an organization's risk assessment findings.
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Things to Consider
• How do you know the underlying hypervisor you're auditing is the same one over time?
• How technically understanding is the CSP who's providing you data?
• We can only do our best and attest to what data is provided to us.
It's difficult to audit the underlying hypervisors and virtualization of many CCSPs, as they will not provide access to the
underlying systems.
Even if an auditor was given access, where would they start? There are thousands of instances, and a customers VMs
move around in the CSP's environment.
As a CCSP, we're concerned about verifying confidentiality, integrity, and availability of cloud services. SLAs will generally
cover availability but not necessarily confidentiality and integrity.
• Understand the virtualization environment, as it will help to plan the assessment and associated testing.
• Validate systems are following best practices when it comes to security.
• Validate configurations are done according to organizational policy.
We must use knowns (best practices, organizational policies, etc.) in our auditing to provide an accurate picture of the
cloud environment's compliance.
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• American Institute of CPA's (AICPA's) Service Organizational Control (SOC)1, 2, and 3 reports
• International Standard on Assurance Engagements (ISAE): The international equivalent of a SOC 1 report
• Agreed-Upon Procedures (AUP): Based on the Statement on Standards for Attestation Engagements (SSAE), AUP is
where an auditor is engaged to report on findings based on procedures performed by the audited party. The
auditor provides no opinion, only states identified facts, and the third party forms their own conclusion on the
report.
• Cloud Security Alliance (CSA): Created the Security, Trust, and Assurance Registry (STAR) program
Audit scope statement: Provides the level of information required for the organization being audited to fully
understand the scope, focus, and type of assessment being performed
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Audit scope restrictions: Parameters set to focus an auditor's efforts on relevancy and:
• Ability to meet SLA (uptime and performance data can be used to validate)
• Contractual requirements
• Industry best practice standards and frameworks such as:
• The International Standard on Assurance Engagements (ISAE), which is an internal control framework.
Statement on Standards for Attestation Engagements (SSAE): An auditing standard for service organizations that
supersedes SAS70
Gap analysis: Identifies gaps between an organization's environmental status and frameworks or standards with which
that organization is attempting to comply
Ex.: An organization is attempting to comply with PCI-DSS, but they do not have network segmentation for devices
handling cardholder information.
The gap analysis helps identify where an organization falls short of compliance so they can remediate those issues to
become compliant.
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• Adequate staff
• Adequate tools
• Schedule
• Supervision of audit
• Reassessment
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ISO 27001 Information Security Management System (ISMS): Internal audits should be part of every ISMS, and their
goal should be to reduce risks related to the availability, integrity, and confidentiality of data while improving
stakeholder confidence in the security posture of the organization.
• ISO 27001 is the most widely used global standard for ISMS implementation
Security controls are mapped to requirements identified through a formal disk assessment.
ISO 27001 covers several domains including but not limited to:
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The controls outlined by the ISMS should be used as a minimum acceptable level of security provided by a CSP.
ISMSes assist in standardizing and measuring security across an organization and to the cloud.
C10. Policies
Organizational policies affect the organization as a whole, such as "The organization will follow accepted standards to
protect client data."
Cloud computing policies are used to implement effective cloud security. Examples of cloud computing policies are:
• Password policy
• Remote access policy
• Encryption policy
• Third-party access policy
• Segregation of duties policy
• Data backup policy
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It's extremely important to involve relevant stakeholders from the beginning of a cloud computing discussion. These
stakeholders can help provide an overarching view of organizational processes and goals to ensure the approach to
cloud fits in and doesn't become a one-off.
• An understanding of current organizational services, operations, and layout must be understood to ensure cloud
solutions can meet the needs of each of them.
• Once this data is collected, you may understand the impact on services, people, cost, infrastructure, and
stakeholders.
Stakeholder Challenges
• Defining an enterprise architecture. Will need to take into consideration all services across the organization and
how they will interoperate.
• Selecting a CSP
• Getting information from persons who may no longer be required after a move to the cloud
• Identifying indirect costs, such as training, new tasks, and new responsibilities.
• Extending risk management to the cloud, as it's a new way of thinking about things
• North American Electric Reliability Corporation/Critical Infrastructure Protection (NERC/CIP): Specifies the
minimum security requirements for operating North America's bulk electrical system
• Health Insurance Portability and Accountability Act (HIPAA): Patient medical information
• Payment Card Industry (PCI): Credit cardholder data
• Over 200 controls in the standard
• Four merchant tiers within the PCI-DSS standard based on the number of transactions a merchant processes
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• Different merchant tiers dictate the amount of audits each must conduct
• For example, information used to come from a team of employees, and now it comes from members of that group
and from a CSP.
Bringing in a third-party consultant to assist with the convergence to a distributed model may be beneficial.
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Data owner: Holds legal rights and complete control of data and can define distribution of said data
Data controller: Person or organization who determines the purposes and the manner in which data is processed
Data custodian: Responsible for the safe custody, transport, storage, and implementation of business rules
surrounding data
Data processor: Anyone other than an employee of the data controller who processes the personal data on behalf of
the data controller (subcontractor)
• Cloud services are very convenient to consume and can easily cause undue risk due to uncontrolled consumption of
services.
Risk appetite: The level of risk an organization is willing to accept to reach its objectives
Many regulations require breach notification to those individuals whose information has been compromised. This
includes GDPR (within 72 hours) and HIPAA (no later than 60 days).
Many other regulations require transparency to those individuals whose personal data they maintain, such as GLBA,
SOX, and GDPR.
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• Avoidance: Simply avoiding risk, such as deciding not to use a specific service because it introduced more than an
acceptable amount of risk.
• Acceptance: Accept a risk and live with it. Implement security controls around the risk.
• Transference: Transfer the risk to another party by outsourcing or insuring against the risk.
• Mitigation: Implement a fix to get the risk down to an acceptable level.
Security controls are used to address and control risks. There are three main types of security controls:
• Physical: Limiting physical access, such as door locks, fire suppression, fences, guards, etc.
• Technical: Logical controls, such as encryption, access lists, firewall rules, etc.
• Administrative: Personnel background checks, separation of duties, mandatory vacations, etc.
• It does not address specific or legal requirements related to risk assessment or management.
• It provides a structured and measurable risk-management approach to assist with identifying cloud-related risks.
• It lists 11 key principles as a guiding set of rules.
• It focuses on risk identification, analysis, and evaluation through risk treatment.
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ENISA: Created "Cloud Computing: Benefits, Risks, and Recommendations for Information Security"
Metrics help identify the severity of a risk. Risk programs will use a scorecard to record the severity of specific risks:
• Critical
• High
• Moderate
• Low
• Minimal
Companies often associate a specific dollar amount with each level of risk in order to quantify the amount of risk.
What type of risk does the organization face? This depends on several elements:
• Service: What type of cloud services are being used and the risks associated?
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• Vendor: What is the vendor's reputation? What standards are they compliant with?
• Infrastructure: Is the infrastructure following best practices and meeting compliance?
Identify the business needs and requirements surrounding the consideration of moving to the cloud.
• Service-level agreement (SLA): Sets specific goals for services and their provisions over a timeframe.
• Master service agreement (MSA): A contract entered into by two parties outlining services to be provided.
Outlines generic terms, such as payment terms, warranties, intellectual property owners, and dispute resolution.
• Statement of work (SOW): Outlines work to be done as part of a project. Defines deliverables and timelines for a
vendor providing service to a client.
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As a CCSP, you must understand that part of dealing with a CSP (vendor) is understanding the associated risks:
In order to understand the risks associated with vendors, it helps to know they are meeting some sort of standard or
guideline, such as:
An international set of guidelines and specifications (ISO/IEC 15408) developed for evaluation information security
products to ensure they do what they say they do
CSA STAR
Created to establish transparency and assurance for cloud-based environments. Allows for customers to assess the
security of CSPs by asking the CSPs for information who openly provide that information in a transparent manner. CSA
STAR is broken into three layers:
• Self-Assessment: Requires release of publication of due diligence assessments against the CSA's questionnaire
• CSA STAR Attestation: Requires the release and publication of results of a third-party audit of the cloud vendor
against CSA CCM and ISO 27001:2013 requirements or an AICPA SOC 2
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• Continuous Auditing: Requires the release and publication of results related to the security properties of
monitoring based on the CloudTrust Protocol
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Failing to address key contract components can result in additional costs to the customer in the event that additions or
amendments to the contract are necessary.
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Each supplier added, including CSPs and their subcontractors, increases risk to the organization.
• Obtain regular updates from vendors listing dependencies and reliance on third parties.
• Where single points of failure are identified, vendors should be challenged.
• Continuously monitor suppliers and their changes.
• NIST SP800-161: "Supply Chain Risk Management Practices for Federal Information Systems and Organizations"
• ISO 28000: Supply Chain Standard
• ISO 27036: Information Security for Supplier Relationships
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