PCI Guidance on Cloud Computing
The PCI Security Standards Council released a Cloud Guidance (PDF) paper yesterday. Network World calls this Security standards council cuts through PCI cloud confusion. In some ways that’s true, but in several important areas it does the opposite. Here are a couple examples:
SecaaS solutions not directly involved in storing, processing, or transmitting CHD may still be an integral part of the security of the CDE …the SecaaS functionality will need to be reviewed to verify that it is meeting the applicable requirements.
… and …
Segmentation on a cloud-computing infrastructure must provide an equivalent level of isolation as that achievable through physical network separation. Mechanisms to ensure appropriate isolation may be required at the network, operating system, and application layers;
Which are both problematic because public cloud and SecaaS vendors won’t provide that level of access, and because the construction of the infrastructure cannot be audited in the same way in-house virtualization and private clouds can be. More to the point, under Logging and Audit Trails:
CSPs should be able to segregate log data applicable for each client and provide it to each respective client for analysis without exposing log data from other clients. Additionally, the ability to maintain an accurate and complete audit trail may require logs from all levels of the infrastructure, requiring involvement from both the CSP and the client.
And from the Hypervisor Access and Introspection section:
introspection can provide the CSP with a level of real-time auditing of VM activity that may otherwise be unattainable. This can help the CSP to monitor for and detect suspicious activity within and between VMs. Additionally, introspection may facilitate cloud-efficient implementations of traditional security controls–for example, hypervisor-managed security functions such as malware protection, access controls, firewalling and intrusion detection between VMs.
Good theory, but unfortunately with little basis in reality. Cloud providers, especially SaaS providers, don’t provide any such thing. They often can’t – log files in multi-tenant clouds aren’t normally segregated between client environments. Providing the log files to a client would leak information on other tenants. In many cases the cloud providers don’t provide customers any details about the underlying hypervisor – much less access. And there is no freakin’ way they would ever let an external auditor monitor hypervisor traffic through introspection.
Have you ever tried negotiating with a vending machine? It’s like that. Put in your dollar, get a soda. You can talk to the vending machine all you want – ask for a ham sandwich if you like, but you will just be disappointed. It’s not going to talk back. It’s not going to negotiate. It’s self service to the mass market. In the vast majority of cases you simply cannot get this level of access from a public cloud provider. You can’t even negotiate for it.
My guess is that the document was drafted by a committee, and
some of the members of that committee don’t actually have any exposure to cloud computing it does not offer real-world advice. It appears to be guidance for private cloud or fully virtualized om-premise computing. Granted, this is not unique to the PCI Council – early versions of the Cloud Security Alliance recommendations had similar flaws as well. But this is a serious problem because the people who most need PCI guidance are least capable of distinguishing great ideas from total BS.
And lest you think I regard the document as all bad, it’s not. The section on Data Encryption and Cryptographic Key Management is dead on-target. The issue will be ensuring that you have full control over both the encryption keys and the key management facility. And the guidance does a good job of advising people on getting clear and specific documentation on how data is handled, SLAs, and Incident Response. This is a really good guide for private cloud and on-premise virtualization. But I’m skeptical that you could ever use this guidance for public cloud infrastructure. If you must, look for providers who have certified themselves as PCI compliant – they take some of the burden off you.