This post will cover some issues and concerns customers cite when considering a move – or more carefully reassessing a move they have already made – to cloud services.
To provide some context to this discussion, one of the major mental adjustments security folks need to make when moving to cloud services is where their responsibilities begin and end. You are no longer responsible for physical security of cloud systems, and do not control the security of resource pools (e.g.: compute, storage, network), so your areas of concern move “up the stack”. With IaaS you control applications, data, user access, and network accessibility. With SaaS, you’re limited to data and user access. With either you are more limited in the tools at your disposal, either provided natively by your vendor or third-party tools which work with the specific cloud service. The good news is that the cloud shrinks your overall set of responsibilities. Whether or not these are appropriate to your use case is a different question.
Fielding customer calls on data security for the better part of the last decade, we learned inquiries regarding on-premise systems typically start with the data repository. For example, “I need to protect my database”, “My SAN vendor provides encryption, but what threats does that protect us from?” or “I need to protect sensitive data on my file servers.” In these conversations, once we understand the repository and the threats to address, we can construct a data security plan. They usually center on some implementation of encryption with supporting key management, access management, and possibly masking/tokenization technologies. In the cloud encryption is still the primary to tool for data security, but the starting points of conversations have been different. The issues are more about needs than by threats. The following are the main issues cited by customers:
- PII: Personally Identifiable Information – essentially sensitive data specific to a user or customer – is the top concern. PII includes things like social security numbers, credit card numbers, account numbers, passwords, and other sensitive data types, as defined by various regulations. And it’s highly very common for what companies move into – or derive inside – the cloud to contain sensitive customer information. Other types of sensitive data are present as well, but PII compliance requirements are driving our conversations. The regulation might be GLBA, Mass Privacy Regulation 201 CMR 17, NIST 800-53, FedRAMP, PCI-DSS, HIPAA, or another from the evolving list. The mapping of these requirements to on-premise security controls has always been fuzzy, and the differences have confused many IT staff and external auditors who are accustomed to on-premise systems. Leveraging existing encryption keys and tools helps ensure consistency with existing processes.
- Trust: More precisely, the problem is lack of trust: Some customers simply do not trust their vendor.s Many security pros, having seen security products and platforms fail repeatedly during their careers, view security with a jaundiced eye. They are especially hesitant with security systems they cannot fully audit. Or they do not have faith that cloud vendors’ IT staff cannot access their data. In some cases they do not trust software-based encryption services. Perhaps the customer cannot risk the cloud service provider being forced to turn over encryption keys by court order, or compromised by a nation-state. If the vendor is never provided they keys, they cannot be compelled to turn them over.
- Vendor Lock-in and Migration: A common reservation regards vendor lock-in, and not being able to move to another cloud service provider in case a service fails or the contractual relationship becomes untenable. Some native cloud encryption systems do not allow customer keys to move outside the system, and cloud encryption systems offer proprietary APIs. The goal is to maintain protection regardless of where data resides, moving between cloud vendors as needed.
- Jurisdiction: Cloud service providers, and especially IaaS vendors, offer services in multiple countries, often in more than one region, and with multiple (redundant) data centers. This redundancy is great for resilience, but the concern arises when moving data from one region to another with may have different laws and jurisdictions. For example the General Data Protection Regulation (GDPR) is an EU regulation governing the personal data of EU citizens, and applies to any foreign company regardless of where data is moved. While similar in intent and covered types of data to the US regulation mentioned above under ‘PII’, it further specifies that some citizen data must not be available in foreign countries, or in some data centers. Many SaaS and IaaS security models do not account for such data-centric concerns. Segregation of duties and access controls are augmented in this case by key management.
- Consistency: It’s common for firms to adopt a “best of breed” cloud approach. They leverage multiple IaaS providers, placing each application on the service which best fits the application’s particular requirements. Most firms are quite familiar with their on-premise encryption and key management systems, so they often prefer to leverage the same tool and skills across multiple clouds. This minimizes process changes around key management, and often application changes to support different APIs.
Obviously there nuances of each cloud implementation guide these conversations as well. Not all services are created equally, so what works in one may not be appropriate in another. But the major vendors offer very strong encryption implementations. Concerns such as data exfiltration protection, storage security, volume security, database security, and protecting data in transit can all be addressed with provided tools. That said, some firms cannot fully embrace a cloud native implementation, typically for regulatory or contract reasons. These firms have options to maintain control over encryption keys and leverage cloud native or third-party encryption.
Our next post will go into detail on several deployment options, and then illustrate how they work.