From the Tool Belt
Overcoming the Security and Privacy Challenges of the Cloud
Note from the Editor:
Chris will delve further into cloud computing issues while speaking at the breakout session, Viva la Cloud, at this year's IAPP Privacy Academy, September 30 - October 2, in Seattle, WA.
There is no doubt that the use of the cloud will continue to grow at an impressive rate. IDC estimates the cloud market will be worth over $50 billion by 2014 and over $120 billion by 2020. Even the U.S. government, who is not viewed as a leader in the use of technology, has a “cloud first” mandate. With compelling evidence that migration to the cloud will improve an organization’s bottom line and business efficiencies, it would seem to be an easy decision.
However, the ubiquitous articles and blog posts about the seemingly insurmountable security and privacy risks of moving mainstream applications to the cloud have created ample fear, uncertainty and doubt in some organizations.
An InformationWeek survey from 2012 revealed that the #1 cloud concern is unauthorized access to or leaks of sensitive information (if you like cloud surveys, find a similar one here just released this year, with slightly different questions). While there are real security and privacy concerns surrounding the cloud, they are by no means insurmountable. There are many organizations, including those in highly regulated industries such as financial services and health care, already in the cloud.
So how do some organizations find a way to identify and manage the risks associated with using the cloud and others cannot?
The answer varies by organization and depends on the organizational culture and politics, approach to risk management and the views and capabilities of the stakeholders involved in the analysis. There are some common characteristics for those companies that have moved to the cloud. These characteristics include:
- Strong IT leadership – they seek and embrace opportunities to enable the business and reduce costs.
- Strong Security & Privacy leadership – they focus not only on risk identification but practical risk management solutions.
- Realistic expectations – they understand and accept that no cloud service provider can guarantee the security of their information or provide indemnification provisions that would cover all potential losses from a data breach.
- Reduced reliance on the cloud service provider – they implement controls that minimize or eliminate reliance on the cloud service provider to secure their data.
I have always been a believer that strong encryption with appropriate key management is the most effective control to secure data. Various statutes (e.g., Massachusetts 201, certain State data breach laws, HIPAA) require and/or recognize the value of encryption for protecting data.
What would be the security and privacy risk if only encrypted data is ever stored in the cloud and only you as the cloud customer have the encryption keys? There would be no risk.
In this scenario, regardless of whether the threat was an external hacker, disgruntled cloud employee, malicious tenant in the same cloud or government agency, the only data they could potentially access is encrypted data and encrypted data that cannot be decrypted is really not data. Obviously this approach is only effective if a strong encryption protocol is used and the encryption keys are appropriately managed and secured.
In addition, from a business perspective, effectively using this technique requires that the functionality of the application is maintained and not broken by the use of encryption. This technique is already used by some companies to take control of their own data, address security and privacy concerns and realize the benefits of the cloud. There are products already in market that provide this functionality.
At the upcoming IAPP Academy in Seattle there will be a breakout session called “Viva la Cloud” for a deeper discussion of how to securely use the cloud. Hope to see you at the session and that you will provide your perspective in this blog.
About the Author
Chris Zoladz, CIPP/US, CIPP/E, CIPP/IT, CIPP/G, CISSP, CISA, CPA, is the founder of Navigate LLC, a consulting company focused on providing comprehensive strategic and tactical information protection and privacy consulting services. Prior to founding Navigate, Zoladz was the vice president of information protection and privacy at Marriott International, Inc., a function he created in 1999. He also served as chair of the Information Security & Privacy Governance Committee and was a member of the eBusiness Council. Zoladz joined Marriott from Ernst & Young, where he last served as the mid-Atlantic area office director of IT audit and security services. He also served on the Ernst & Young IT Assurance & Advisory Services Practice Management Committee.
A past-chairman, treasurer and founding board member of the IAPP, Zoladz was the recipient of the 2006 IAPP Vanguard Award as the chief privacy officer of the year. He was also named one of the top privacy advisors by Computerworld in 2010, the last year the list was published. Zoladz is also a past member of the U.S. Chamber of Commerce Telecommunications and eCommerce Committee and speaks frequently on privacy matters.