Unit 3 Notes Part 2
Unit 3 Notes Part 2
Cloud Services are not immune to outages (failure/interruption) and the severity and the scope
of impact on the customer can vary based on the situation. As it will depend on the criticality
of the cloud application and its relationship to internal business processes.
1. Impact on business: In the case of business-critical applications where businesses rely
on the continuous availability of service, even a few minutes of service failure can have
a serious impact on the organization’s productivity, revenue, customer satisfaction, and
service-level compliance.
2. Impact on customers: During a cloud service disruption, affected customers will not
be able to access the cloud service and in some cases may suffer degraded performance
or user experience. For Example:- when a storage service is disrupted, it will affect the
availability and performance of a computing service that depends on the storage service.
For example, on December 20, 2005, Salesforce.com (the on-demand customer relationship
management service) said it suffered from a system outage that prevented users from accessing
the system during business hours. Users “experienced intermittent access” because of a
database cluster error in one of the company’s four global network nodes, company officials
said in a statement the day following the outage.
Factors Affecting Availability:
The cloud service’s ability to recover from an outage situation and availability depends on a
few factors, including the cloud service provider’s data center architecture, application
architecture, hosting location redundancy, diversity of Internet service providers (ISPs), and
data storage architecture.
Following is a list of the major factors:
• The redundant design of System as a Service and Platform as a Service application.
• The architecture of the Cloud service data center should be fault-tolerant.
• Having better Network connectivity and geography can resist disaster in most cases.
• Customers of the cloud service should quickly respond to outages with the support team
of the Cloud Service Provider.
• Sometimes the outage affects only a specific region or area of cloud services, so it is
difficult in those cases to troubleshoot the situation.
• There should be reliability in the software and hardware used in delivering cloud
services.
• The infrastructure of the network should be efficient and should be able to cope-up with
DDoS(distributed denial of service ) attacks on the cloud service.
• Not having proper security against internal and external threats, e.g., privileged users
abusing privileges.
• Regular testing and maintenance of the cloud infrastructure and applications can help
identify and fix issues before they cause downtime.
• Proper capacity planning is essential to ensure that the cloud service can handle peak
traffic and usage without becoming overloaded.
• Adequate backups and disaster recovery plans can help minimize the impact of outages
or data loss incidents.
• Monitoring tools and alerts can help detect and respond to issues quickly, reducing
downtime and improving overall availability.
• Ensuring compliance with industry standards and regulations can help minimize the
risk of security breaches and downtime due to compliance issues.
• Continuous updates and patches to the cloud infrastructure and applications can help
address vulnerabilities and improve overall security and availability.
• Transparency and communication with customers during outages can help manage
expectations and maintain trust in the cloud service provider.
System as a Service Customer’s Responsibility:
• Customers should understand the Service Level Agreement(SLA) and communication
methods so that they will be informed on service outages or maintenance.
• Customers should be aware of options to support availability management that is they
should understand the factors affecting availability management.
• The customer of System as a service should be aware that the cloud service is
multitenant which means Cloud Service Providers typically offer a Standard Service
Level Agreement(SLA) for all customers. Thus, Cloud Service Providers may not be
able to provide their services to the customers if the standard Service level-
Agreement(SLA) does not meet the service requirements. However, if you are a
medium or large enterprise with a big budget, a custom SLA can be made available.
• The customers should be aware of how resource democratization occurs within the
Cloud Service Providers to best predict the likelihood of system availability and
performance during business fluctuations.
• Customers should ensure that their applications are designed and deployed in a way
that maximizes availability and resilience. This may include using load balancing,
redundancy, and failover mechanisms.
• It’s important for customers to monitor their own applications and infrastructure to
detect and respond to issues quickly, rather than relying solely on the cloud service
provider to do so.
• Customers should understand the security and compliance implications of using a cloud
service and take appropriate measures to protect their data and systems.
• It’s important for customers to have a disaster recovery plan in place, including backups
and a procedure for restoring service in the event of an outage.
• Customers should understand the cost implications of using a cloud service, including
any charges for exceeding usage limits or for premium support options.
• It’s important for customers to provide feedback to the cloud service provider on their
experience using the service, including any issues or suggestions for improvement.
• Customers should understand the limitations and restrictions of their cloud service
subscription, such as the maximum number of users or the amount of data that can be
stored, and plan accordingly.
System as a Service Health Monitoring:
The following options are available to customers to stay informed on the health of their service:
• Service dashboards should be published by the Cloud Service Providers So that they
can publish the current state of services and can also inform the outage or any kind of
maintenance of the cloud.
• Customer should check their mailing list as the service provider might have notified
them about recently occurring outrages.
• Use third-party tools to check the health of the application.
Platform as a Services Customer’s Responsibilities:
The following considerations are for Platform as a Services Customers:
• PaaS platform service levels: Customers should read and understand the terms and
conditions of the Cloud Service Provider’s Service Level Agreements.
• Third-party web services provider service levels: When your Platform as a Services
application depends on a third-party service it is critical to understand the Service Level
Agreements of that service. Network connectivity parameters with third-party service
providers. Example: Bandwidth and latency factors.
• Platform as a Service Health Monitoring: The following options are available to
customers to monitor the health of their service:
o Service health dashboard published by the Cloud Service Provider.
o Cloud Service Providers customer mailing list that notifies customers of
occurring and recently occurred outages
o Use third-party tools to check the health of the application
• Infrastructure as a Service Health Monitoring: The following options are available
to Infrastructure as a Service customer for managing the health of their service:
o Service health dashboard published by the Cloud Service Providers.
o Cloud Service Providers customer mailing list that notifies customers of
occurring and recently occurred outages.
o Third-party-based service monitoring tools that periodically check the health of
your Infrastructure as a Service virtual server.
Confidentiality of the user’s data is an important issue to be considered when externalizing and
outsourcing extremely delicate and sensitive data to the cloud service provider. Personal data
should be made unreachable to users who do not have proper authorization to access it and one
way of making sure that confidentiality is by the usage of severe access control policies and
regulations. The lack of trust between the users and cloud service providers or the cloud
database service provider regarding the data is a major security concern and holds back a lot of
people from using cloud services.
Data loss or data theft is one of the major security challenges that the cloud providers face. If
a cloud vendor has reported data loss or data theft of critical or sensitive material data in the
past, more than sixty percent of the users would decline to use the cloud services provided by
the vendor. Outages of the cloud services are very frequently visible even from firms such as
Dropbox, Microsoft, Amazon, etc., which in turn results in an absence of trust in these services
during a critical time. Also, it is quite easy for an attacker to gain access to multiple storage
units even if a single one is compromised.
Since the cloud infrastructure is distributed across different geographical locations spread
throughout the world, it is often possible that the user’s data is stored in a location that is out
of the legal jurisdiction which leads to the user’s concerns about the legal accessibility of local
law enforcement and regulations on data that is stored out of their region. Moreover, the user
fears that local laws can be violated due to the dynamic nature of the cloud makes it very
difficult to delegate a specific server that is to be used for trans-border data transmission.
Multi-tenancy is a paradigm that follows the concept of sharing computational resources, data
storage, applications, and services among different tenants. This is then hosted by the same
logical or physical platform at the cloud service provider’s premises. While following this
approach, the provider can maximize profits but puts the customer at a risk. Attackers can take
undue advantage of the multi-residence opportunities and can launch various attacks against
their co-tenants which can result in several privacy challenges.
5. Transparency Issues
In cloud computing security, transparency means the willingness of a cloud service provider to
reveal different details and characteristics on its security preparedness. Some of these details
compromise policies and regulations on security, privacy, and service level. In addition to the
willingness and disposition, when calculating transparency, it is important to notice how
reachable the security readiness data and information actually are. It will not matter the extent
to which the security facts about an organization are at hand if they are not presented in an
organized and easily understandable way for cloud service users and auditors, the transparency
of the organization can then also be rated relatively small.
Virtualization means the logical abstraction of computing resources from physical restrictions
and constraints. But this poses new challenges for factors like user authentication, accounting,
and authorization. The hypervisor manages multiple Virtual Machines and therefore becomes
the target of adversaries. Different from the physical devices that are independent of one
another, Virtual Machines in the cloud usually reside in a single physical device that is managed
by the same hypervisor. The compromise of the hypervisor will hence put various virtual
machines at risk. Moreover, the newness of the hypervisor technology, which includes
isolation, security hardening, access control, etc. provides adversaries with new ways to exploit
the system.
7. Managerial Issues
There are not only technical aspects of cloud privacy challenges but also non-technical and
managerial ones. Even on implementing a technical solution to a problem or a product and not
managing it properly is eventually bound to introduce vulnerabilities. Some examples are lack
of control, security and privacy management for virtualization, developing comprehensive
service level agreements, going through cloud service vendors and user negotiations, etc.
Protecting Privacy in Cloud Computing is a critical concern for organizations and individuals
who rely on cloud services to store, process, and manage sensitive data. Cloud environments
are inherently more vulnerable to privacy risks due to the shared nature of resources, multi-
tenancy, and the possibility of cross-border data transfers. However, through the
implementation of effective privacy protection strategies and adherence to best practices,
organizations can significantly reduce the risks associated with cloud computing and maintain
compliance with privacy regulations.
1. Data Encryption
• Encryption at Rest and in Transit: Encrypting data both at rest (when it is stored on
disk) and in transit (when it is being transmitted over networks) is a fundamental
privacy protection mechanism.
o At Rest: Encrypting data stored in databases, file storage systems, and backup
environments ensures that unauthorized access to storage media does not expose
sensitive information.
o In Transit: Encryption protocols such as TLS (Transport Layer Security) ensure
that data transmitted between users, applications, and cloud services remains
secure.
o Best Practice: Use strong encryption standards such as AES-256 (Advanced
Encryption Standard) and manage encryption keys securely using cloud-native
Key Management Services (KMS) like AWS KMS or Azure Key Vault.
• Data Masking: Data masking replaces sensitive data with fictional, yet realistic-looking
data for testing and development purposes, without exposing actual sensitive
information.
• Tokenization: Tokenization involves replacing sensitive data, such as credit card
numbers or personal identifiers, with non-sensitive equivalents (tokens), which can
only be mapped back to the original data through a secure tokenization process.
o Best Practice: Implement tokenization and data masking for sensitive data that
is used in non-production environments to mitigate privacy risks.
• Role-Based Access Control (RBAC): Implement RBAC to ensure that users only have
access to data and resources they need to perform their jobs. This limits the exposure
of sensitive data to unauthorized or unnecessary parties.
o Best Practice: Enforce the Principle of Least Privilege (PoLP) by ensuring that
each user and service has only the minimum permissions required.
• Identity and Access Management (IAM): Strong IAM practices, including the use of
multi-factor authentication (MFA), can prevent unauthorized access to cloud resources,
especially those that contain sensitive data.
o Best Practice: Ensure that MFA is enforced for all users accessing cloud services
that handle sensitive data.
4. Data Residency and Sovereignty
• Data Residency refers to the physical location where data is stored. Cloud providers
typically operate data centers in multiple regions, which can create concerns about
where data is located and which jurisdiction’s laws apply.
• Data Sovereignty involves compliance with local laws regarding data storage,
processing, and access. Organizations need to ensure that they comply with privacy
laws and regulations such as GDPR, HIPAA, and CCPA, which may impose restrictions
on where data can be stored and processed.
o Best Practice: Choose cloud providers that offer data residency controls,
allowing you to select the region in which your data will be stored, ensuring
compliance with relevant privacy regulations.
o Best Practice: Review and understand the data transfer agreements and model
clauses offered by cloud providers to ensure compliance with data sovereignty
regulations.
• Privacy by Design is a principle that advocates for integrating privacy features into the
design of systems, processes, and infrastructure from the outset, rather than as an
afterthought. This means considering data privacy as a core requirement in the
development of cloud-based services and applications.
• Privacy by Default ensures that only the minimum necessary amount of personal data
is processed, and that it is retained only for as long as necessary to fulfill the intended
purpose.
o Best Practice: Implement data minimization and data retention policies to limit
the collection and storage of personal data, and to ensure that sensitive data is
securely deleted once it is no longer needed.
• Continuous monitoring and auditing of cloud environments are essential for detecting
potential privacy violations, unauthorized access, or data leaks.
• Audit Logs: Cloud providers often offer logging capabilities to record who accessed
what data and when. This enables organizations to track and audit access to sensitive
data in real time.
o Best Practice: Enable audit logging on cloud services to capture detailed records
of who accessed data, what actions they performed, and what resources they
interacted with. Use tools like AWS CloudTrail, Google Cloud Audit Logs, or
Azure Monitor.
• Security Information and Event Management (SIEM): Use SIEM tools to aggregate and
analyze security events and alerts across cloud resources to detect suspicious activities
that may indicate a privacy breach.
• Data Loss Prevention (DLP) technologies are designed to prevent the unauthorized
movement, sharing, or leakage of sensitive data, both within and outside the cloud
environment.
o Best Practice: Implement DLP policies to monitor for the unauthorized
transmission of personal data, such as credit card information, personally
identifiable information (PII), or protected health information (PHI).
• An incident response plan is essential for managing and mitigating the impact of data
breaches or privacy incidents in cloud environments.
• Incident Response Plan: Develop and implement a formal incident response plan to
quickly detect, investigate, and resolve any privacy incidents that may occur, such as
unauthorized access or data breaches.
o Best Practice: Cloud providers offer tools to assist with incident response, such
as AWS Config, Google Cloud Security Command Center, and Azure Security
Center, which provide real-time alerts and tools to respond to security incidents.
• Breach Notification: In compliance with privacy laws like GDPR, cloud providers and
customers are often required to notify affected individuals and regulators about data
breaches within a specified time frame.
o Best Practice: Ensure that breach notification procedures are in place, including
identifying affected individuals, assessing the impact of the breach, and
notifying relevant authorities in a timely manner.
• Data Deletion: Secure data deletion is critical to ensure that sensitive information is not
recoverable after it is no longer needed. When data is deleted, it should be completely
destroyed to prevent unauthorized access.
• Data Destruction Standards: Use certified data destruction methods to ensure that data
stored in cloud environments is securely erased, including the secure destruction of
physical media and logical data erasure.
Best Practice: Ensure that your cloud provider offers secure data destruction practices as part
of their service level agreements (SLAs).
o Key Changes in Privacy Risk Management and Compliance Due to Cloud Computing
o 1. Shift in Data Ownership and Control
o Traditional Model: In on-premises systems, organizations had direct control over their
data, infrastructure, and security, allowing them to easily implement and monitor privacy
measures.
o Cloud Model: In the cloud, data is stored and processed on third-party servers managed
by cloud service providers (CSPs). While organizations maintain ownership of their data,
CSPs control the infrastructure and often have access to the systems hosting that data.
o Challenge: This shared control increases the complexity of ensuring that data privacy is
maintained across multiple jurisdictions and parties.
o Change: Organizations must adjust their privacy risk management strategies to account
for the cloud provider’s responsibilities (e.g., physical security, network security) and
their own (e.g., data encryption, access controls).
o 2. The Shared Responsibility Model
o Traditional Model: In traditional IT environments, organizations had full responsibility
for the protection of their data, security, and compliance efforts.
o Cloud Model: Cloud providers typically operate under a shared responsibility model,
where security responsibilities are divided between the provider and the customer.
o Provider’s Responsibility: The CSP is generally responsible for securing the physical
infrastructure, networking, and basic cloud services.
o Customer’s Responsibility: The customer is responsible for securing their data,
applications, user access, and configurations in the cloud (including compliance with
privacy regulations).
o Change: Privacy risk management now requires a clearer understanding of who is
responsible for what in the cloud. Customers must ensure that the appropriate controls
and protections are in place for data they store and process in the cloud.
o Best Practice: Ensure that the shared responsibility model is clearly defined in contractual
agreements (e.g., Service Level Agreements (SLAs)) between the cloud provider and the
customer.
o 3. Data Residency and Sovereignty Challenges
o Traditional Model: On-premises environments allowed organizations to control the
physical location of their data, ensuring that it remained within a specific jurisdiction.
o Cloud Model: Cloud providers operate data centers globally, meaning that data may be
stored in regions or countries outside of the customer’s primary jurisdiction. This can
lead to concerns over data sovereignty, as different countries have varying privacy laws
and regulations.
o Change: Privacy risk management must now include considerations of where data is
physically stored and processed, as data could be subject to different legal frameworks
depending on the jurisdiction.
o Best Practice: Select a cloud provider that offers data residency controls, which allow
customers to specify where their data will be stored (e.g., choosing regions or countries
where data should reside). Customers should also ensure that cloud providers comply
with applicable regulations like GDPR, CCPA, or HIPAA when operating in specific
regions.
o 4. Cross-Border Data Transfers and Compliance
o Traditional Model: Cross-border data transfers were generally easier to control in on-
premises environments, where organizations could manage the movement of data
between locations within specific borders.
o Cloud Model: In cloud environments, data may be transferred between different countries
and continents as part of cloud services, creating complexities in complying with data
protection laws like GDPR, which imposes strict rules on transferring personal data
outside of the European Union (EU).
o Change: Privacy risk management must now account for cross-border data transfers,
ensuring that appropriate mechanisms (such as Standard Contractual Clauses (SCCs) or
Privacy Shield Frameworks) are in place to ensure compliance with data protection laws
when transferring data across borders.
o Best Practice: Review and negotiate contracts with cloud providers to include appropriate
data protection mechanisms for cross-border data transfers.
o 5. Automated Privacy Risk Assessments and Continuous Monitoring
o Traditional Model: Privacy risk management in traditional IT systems often involved
periodic audits and assessments of security and privacy controls, typically done manually
or on a scheduled basis.
o Cloud Model: Cloud environments are dynamic, with resources being provisioned and
decommissioned in real-time. This requires continuous monitoring and automated
privacy risk assessments to ensure compliance at all times.
o Change: Privacy risk management must adapt to an agile and continuous monitoring
approach, utilizing tools that provide real-time visibility into data usage, access, and
security risks across cloud resources.
o Best Practice: Use Cloud Security Posture Management (CSPM) tools like AWS Config,
Azure Security Center, or Google Cloud Security Command Center to continuously
monitor cloud environments for compliance and privacy risks. Automated Data Loss
Prevention (DLP) tools can help detect potential privacy violations in real time.
o 6. Regulatory and Compliance Landscape Complexity
o Traditional Model: Organizations typically had to comply with a limited number of
regulations or standards depending on the industry, such as PCI DSS for payment card
information or HIPAA for healthcare data.
o Cloud Model: The global nature of cloud services means that organizations may need to
comply with multiple, often conflicting, regulatory frameworks across different
jurisdictions, such as GDPR, CCPA, HIPAA, FISMA, and more.
o Change: Privacy risk management in cloud computing requires navigating a complex and
evolving landscape of privacy regulations and frameworks. Organizations must ensure
that their cloud providers meet the compliance requirements that are applicable to their
data and operations.
o Best Practice: Regularly assess cloud providers' certifications and ensure that their
compliance frameworks align with your organization’s regulatory needs. Cloud providers
typically offer compliance documentation (e.g., SOC 2, ISO 27001, GDPR Compliance),
but customers should also assess their own compliance needs.
o 7. Privacy-Enhancing Technologies (PETs) and Cloud Security
o Traditional Model: Privacy risk management in traditional IT systems relied on measures
such as firewalls, encryption, and access controls, but the focus on privacy-enhancing
technologies (PETs) was relatively limited.
o Cloud Model: Cloud computing offers new opportunities and tools to implement PETs
like homomorphic encryption, differential privacy, and secure multiparty computation,
which allow organizations to process and analyze data without exposing sensitive
information.
o Change: As cloud providers offer advanced privacy technologies, privacy risk
management strategies can now include more sophisticated techniques for protecting
data even in untrusted environments.
o Best Practice: Stay informed about emerging privacy technologies offered by cloud
providers and integrate them into privacy risk management plans, especially for sensitive
data processing.
o 8. Third-Party Risk Management
o Traditional Model: Third-party vendors and service providers were often subject to
oversight, and organizations had more control over the selection and management of
those vendors.
o Cloud Model: In the cloud, organizations rely on cloud providers as third-party vendors,
and those providers often subcontract services to other third parties (e.g., subcontracted
data centers, analytics platforms).
o Change: Privacy risk management in the cloud now requires not only ensuring that the
cloud provider adheres to privacy standards, but also assessing the privacy practices of
any third-party vendors that the cloud provider uses.
o Best Practice: Include robust data protection and privacy clauses in contracts with cloud
providers, ensuring that third-party subprocessors meet your organization’s privacy
requirements.
o 9. Incident Response and Data Breach Management
o Traditional Model: Incident response and data breach management in traditional systems
were typically centralized and within an organization's control, with clear boundaries for
data protection.
o Cloud Model: Cloud environments can involve multiple entities (the cloud provider, the
customer, third-party vendors), making it more difficult to coordinate a response to data
breaches and privacy incidents.
o Change: Privacy risk management requires coordinated incident response and breach
management plans that account for the shared responsibility model and the involvement
of third-party vendors.
o Best Practice: Establish an incident response plan that includes cloud-specific
considerations, such as cloud provider notifications, roles and responsibilities, and breach
notification requirements under privacy laws (e.g., GDPR’s 72-hour notification
requirement).
o 10. Data Retention and Deletion
o Traditional Model: On-premises environments allowed organizations to control the
retention and deletion of their data based on their own internal policies and retention
schedules.
o Cloud Model: Cloud providers may have different data retention and deletion policies,
and data can be replicated across multiple locations and environments, complicating the
process of ensuring data is properly deleted when no longer needed.
o Change: Privacy risk management now requires clear agreements with cloud providers
about data retention, archiving, and secure deletion processes.
o Best Practice: Implement strict data retention policies, automate data lifecycle
management, and ensure that the cloud provider offers secure data deletion mechanisms
when data is no longer needed.
Legal and Regulatory Implications of Cloud Computing have become a major area of
concern for businesses and organizations that store, process, or manage data in cloud
environments. As cloud computing becomes more integral to business operations, it introduces
a complex landscape of legal challenges and regulatory requirements, both in the U.S. and
internationally. These challenges are exacerbated by the multi-jurisdictional nature of cloud
services, where data can be stored and processed across different countries and regions.
To navigate these challenges, organizations must understand how various legal and regulatory
frameworks apply to cloud computing, particularly with regard to data privacy, security, and
compliance. The landscape includes U.S. federal and state laws, international regulations such
as the General Data Protection Regulation (GDPR), and sector-specific requirements like
HIPAA for healthcare data.
o The use of cloud services involves sharing sensitive data with third-party cloud providers,
which may introduce several legal and regulatory risks, including:
o Data Ownership: Determining who owns the data in the cloud is a critical legal issue.
While customers typically retain ownership of their data, cloud providers may have
control over the infrastructure and systems used to store and process the data. This raises
questions around access rights, data sovereignty, and the level of control that customers
have over their own data.
o Data Privacy: As cloud environments often span multiple jurisdictions, organizations
must comply with various data privacy laws, which can differ significantly between
countries. Ensuring that data is properly protected and managed according to the
applicable regulations is essential.
o Data Breach and Incident Response: Data stored in the cloud may be subject to data
breaches or unauthorized access. Organizations must ensure that they have clear
protocols and agreements with cloud providers regarding incident response, breach
notification, and remedial measures.
o Third-Party Liability: Cloud service providers (CSPs) may outsource certain services
(e.g., data center management, processing), creating a complex web of third-party
relationships that could affect an organization’s legal responsibilities in case of non-
compliance, data loss, or a breach.
o Contractual Obligations: Organizations must carefully review and negotiate contracts
with cloud service providers to ensure that they meet the necessary compliance
requirements, including data protection clauses, service level agreements (SLAs), and
audit rights.
o UK GDPR:
o After Brexit, the UK adopted a version of the GDPR, which is essentially the same as the
EU’s GDPR but with certain modifications specific to the UK. UK-based organizations
and those with UK customers must comply with UK GDPR standards, including those
governing cloud services.
o Implication: Organizations using cloud providers based outside the UK must ensure that
the provider complies with UK data protection laws and that data transfers are legally
protected.
o c. Other Regions
o Asia-Pacific (APAC):
o Many countries in the APAC region have introduced their own data protection laws, such
as China's Personal Information Protection Law (PIPL), Singapore's Personal Data
Protection Act (PDPA), and Japan's Act on the Protection of Personal Information
(APPI).
o Implication: Cloud service providers must ensure that their services comply with local
data protection laws in these regions, which may require adjustments in data storage,
access, and transfer practices.
o Brazil:
o Lei Geral de Proteção de Dados (LGPD) is Brazil's version of data protection law, heavily
modeled on the GDPR. It imposes rules on data controllers and processors, including
those offering cloud services.
o Implication: Cloud providers and businesses operating in Brazil must comply with LGPD
regarding the handling of personal data.
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