Cloud Computing and the Regulatory Compliance Labyrinth
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1 Cloud Computing and the Regulatory Compliance Labyrinth
2 About ERM
3 About The Speaker Nick Shuman Information Security Consultant Bachelor of Science in Computer Science and Psychology - University of Miami Core Experience: Regulatory Compliance and Standards Risk and Vulnerability Management Technical Security Assessment Ethical Hacking
4 The Cloud What is The Cloud? Foggy about the Cloud Public, Private, and Hybrid Clouds What is the difference? Cloud-based services Software as a service (Saas) Platform as a service (PaaS) Infrastructure as a service (IaaS) Anything as a service (Xaas)
5 Why the Cloud? Pros Cost Management Efficiency Time to Market Scalability Cons Information Security Data Ownership Responsibilities Legal/Contractual Issues Performance Standards Customer Demand Technical Resources
6 Regulatory Compliance Issues Distinction between data owners and data processors Lack of knowledge about geographical location of data centers Physical controls being replaced by virtual controls Non-standard Private and Public Clouds
7 Questions Regarding Compliance in the Cloud Can I remain compliant after moving to the cloud? How do I do that? How will I know where my data is? Will my cloud provider be forthcoming about potential compliance issues? Will my data be more secure in the cloud?
8 Payment Card Industry Data Security Standard (PCI DSS) What is PCI DSS? Set of regulations that are responsible for ensuring that companies are handling users credit card data in a secure and responsible manner Not all cloud providers are equal PCI compliant only in certain areas PCI DSS Cloud Computing Guidelines
9 Health Insurance Portability and Accountability Act (HIPAA) What is HIPAA? Strict rules set in place in the healthcare field in order to protect patient privacy Pertain to how medical information is collected, handled, protected, used, and disclosed Compliance is a two way street Burden falls on you and the cloud computing provider Where is data being physically stored?
10 Federal Risk and Authorization Management Program (FedRAMP) What is FedRAMP? Authorization, not certification NIST-based Standardized requirements Needed for any cloud service provider that intends to provide cloud computing services to Federal government agencies Contractors to hire third-party assessment organizations that will verify whether they meet the basic security requirements.
11 Gramm-Leach-Bliley Act (GLBA) What is GLBA? Requires that financial institutions establish appropriate standards for protecting the security and confidentiality of their customers' non-public personal information Financial Privacy Rule Safeguards Rule Security and confidentiality of customer records and information Protect against any anticipated threats or hazards to the security or integrity Protect against unauthorized access which could result in harm or inconvenience to any customer
12 Cloud Compliance Conclusions and Suggestions Not sufficient to rely solely on claims of cloud providers Due diligence Thorough discussions with cloud providers Make a checklist Enumerate all compliance requirements Who manages/is responsible for which? 100% compliant cloud providers is usually a warning sign Compliance DOES NOT EQUAL Security Do you fully understand all requirements?
13 Questions and Inquiries For further information please contact: Nick Shuman Information Security Consultant (o) (m)
14 Your go to advisors for all matters in information security. Upcoming Webinars June 2013: July 2013: Business Continuity Planning Information Security for Law Firms
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