Can Nuclear Installations and Research Centres Adopt Cloud Computing Platform?

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1 Can Nuclear Installations and Research Centres Adopt Cloud Computing Platform? Ameer PICHAN, Dr. Sie Teng SOH, A/Prof Mihai LAZARESCU School of Electrical Engineering and Computing, Curtin University, Kent Street, Bentley, Perth, WA, Australia 6102 Abstract. Cloud Computing is arguably one of the recent and highly significant advances in information technology today. It produces transformative changes in the history of computing and presents many promising technological and economic opportunities. The pay per use model, the computing power, abundance of storage, skilled resources, fault tolerance and the economy of scale it offers, provides significant advantages to enterprises to adopt cloud platform for their business needs. However, customers especially those dealing with national security, high-end scientific research institutions, and critical national infrastructure service providers (like power, water) remain very much reluctant to move their business system to the cloud. One of the main concerns is the question of information security in the cloud and the threat of the unknown. Cloud Service Providers (CSP) indirectly encourages this perception by not letting their customers see what is behind their virtual curtain. Jurisdiction (information assets being stored elsewhere), data duplication, multi-tenancy, virtualisation and decentralised nature of data processing are the default characteristics of cloud computing. Therefore, traditional approach of enforcing and implementing security controls remains a big challenge and largely depends upon the service provider. The other biggest challenge and open issue is the ability to perform digital forensic investigations in the cloud in case of security breaches. Traditional approaches to evidence collection and recovery are no longer practical as they rely on unrestricted access to the relevant systems and user data, something that is not available in the cloud model. This continues to fuel high insecurity for the cloud customers. In this paper we analyse the cyber security and digital forensics challenges, issues and opportunities for nuclear facilities to adopt cloud computing. We also discuss the due diligence process and applicable industry best practices which shall be considered before deciding to adopt cloud computing for the organisational ICT needs. 1. Introduction In the recent years the advent of cloud computing has produced major technological advancement in the way the Information Technology (IT) services are being provisioned and deployed. Cloud computing offers speed, agility, flexibility, infinite elasticity, much lower cost and more importantly the mobility where services can be accessed anytime from anywhere. It helps to replace big capital investments with operational expenditure. This has fuelled a phenomenal growth in cloud services market and continues to grow. High growth in cloud services will cause IT spending to shift from traditional IT systems to cloud computing platform. [1] Though the cloud computing offers significant benefits, there has been growing concern about the security, privacy, legal, and jurisdictional aspects of cloud environment and the way the cloud computing stores and process customer s data. In this paper, we are analysing and presenting the security issues and challenges to adopt cloud computing platform for nuclear installations, sensitive research institutions or similar organisations dealing with sensitive data. We also discuss the options and the due diligence process that shall be conducted, while moving organization s IT systems to cloud. We conclude by providing an informed assessment of the security risks, the benefits, and recommendation for using cloud computing. 2. Cloud Computing: An Overview Cloud computing is a new concept of how we provision and run IT services. The cloud computing model promises that users do not need to worry about running their own IT, because it will be delivered as a service. It envisages a world where computing resources can be rapidly orchestrated, implemented, provisioned, scaled up or down and decommissioned to provide an on-demand utilitylike model of allocation and consumption [2]. The major benefit of cloud computing is the capability of providing business supporting technologies more efficiently than ever before, economies of scale 1

2 and considerable cost reduction. The National Institute of Standards and Technology (NIST) provides the following definition for cloud computing: a model for enabling ubiquitous, convenient, on demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction. [3] 2.1 Cloud Computing Characteristics In simple terms the cloud computing is a service delivery model, in which IT services are offered as a service to consumers and they are billed as per usage. The services can be accessed via Internet anytime and from anywhere, which have fuelled the rapid growth in the adoption of cloud computing by customers. The cloud computing architecture has the following core characteristics [4]: Elasticity: the ability to scale up or down computing and storage needs as per need. Connectivity: the ability to connect and access the services anytime from anywhere. Multi-tenancy: the ability to host multiple tenants on the same physical resources (i.e., resource pooling by sharing physical storage, memory and networks) Visibility: the ability for consumers to have full visibility and control of their cloud deployment parameters, usage and cost. On demand self-service: the ability for consumer to provision capabilities such as computing power, storage and security services, without the need to interact with the service provider. Measured service: the ability to meter the services and bill as per usage. Cloud computing comes in several deployment models and service delivery models. FIG. 1 describes the cloud deployment model, essential characteristics and parameters affecting security of information assets in the cloud. The most popular cloud computing deployment models are: Public cloud: Computing services are made available over internet, but owned and operated by an external provider selling cloud services. Private cloud: Computing environment exclusively owned by the organization and operated by the organization or third party. By virtue, private cloud provides greater control of all computational resources. Community cloud: Similar to private cloud, but the computational resources are shared by many organizations with similar privacy, security and regulatory rules, e.g., banks, hospitals. Hybrid cloud: A composition of two or more clouds bound together by standardized or proprietary technology and enables interoperability. Essential Characteristics Service models Deployment Model FIG. 1. Cloud deployment model and security 2

3 The most popular cloud computing service delivery models are: Software-as-a-Service (SaaS): is a model where the consumers have the facility of using the service providers software and computational resource to run them on demand as a turnkey service, accessed using a thin client, usually via Internet. Some of the SaaS examples are: Google Drive, Google Calendar. Platform-as-a-Service (PaaS): is a model where the computing platform is provided as an ondemand service upon which applications can be developed and deployed. PaaS examples are: Google App Engine and Windows Azure. Infrastructure-as-a-Service (IaaS): is a model where the computing infrastructure consisting of servers, storage and network equipment, are provided as an on-demand service upon which a platform to develop FIG. 2. Cloud Service Layers and execute applications can be established. It alleviates the costly process of maintaining own data center. An example of IaaS is Amazon Elastic Cloud Computing (Amazon EC2). FIG. 2 describes the various cloud service layers [5]. Though the cloud model provides the customers the ability to choose and use the service they want, the degree of control that customers have on their information assets also varies according to the service model. In IaaS users have more control of their information assets, where as in PaaS model, they can have access only to their application data and logs and in SaaS model customers have either little or no access, other than to their own data. As the customers increasingly rely on the CSPs to provide the functionality and services, they correspondingly give the CSPs more control, i.e., the lower down the stack the cloud provider stops, the more security the consumer is tactically responsible for implementing and managing. 2.2 Cloud Security Challenges In the context of moving a nuclear facility or organisations dealing with sensitive data assets to cloud, the prime concern that users will have is the security of information assets and the threats specifically related to the unique characteristics that cloud computing exhibits, as well as the issues related to loss of governance and control. Among the most significant security risk associated is the tendency to bypass the organisational IT process, governance and information officers. Although shifting to cloud computing is relatively easy, but doing so without conducting proper due diligence process can easily undermine the gains and could produce serious business impact. Therefore, it is essential that a detailed risk assessment shall be carried out, and service level agreements (SLAs) done accordingly, to ensure that the risk is well managed and controlled before adopting the cloud. Otherwise, there is a tremendous potential for misguided risk management decisions causing detrimental outcomes. Professional organisations like Cloud Security Alliance (CSA), NIST and academia have published research papers on security issues in cloud environment [3, 6, 7]. There is also many security advantages by using cloud [8]. Below we are analysing the use of cloud computing in the context of 3

4 sensitive data storage and processing, which is of national importance, like nuclear research, defence or critical infrastructure Data Locality In traditional on premise deployment model, the sensitive data continues to reside within the enterprise boundary and it is subject to enterprise governance regime, such as physical, logical and personnel security and access controls. However, in a cloud environment data is stored outside the enterprise boundary, which could be even outside country in a different jurisdictional area, especially in a public cloud model. In addition, cloud providers often duplicate the data to secondary locations, which in reality can be anywhere [9]. This could pose a significant risk. Extra territorial deployment of data or when the information crosses borders, raises serious concerns regarding governance, privacy, regulatory regimes, accountability and policy compliance. Extra territorial data location also raises serious legal and jurisdictional challenges and associated risk. For example in case of a security incident it is very difficult, if not impossible, to identify, locate and acquire the information assets and digital artefacts required for forensic investigation. Different cloud providers provide different models of service. For example, Google provides a global service delivery, where the data location is not clearly transparent. Amazon provides a regional service delivery option, where the customers have the option to choose the regional location where one can host their Virtual Machine (VM) instances or use it as data repositories. As of this writing Amazon provides public cloud services in the following regions: three regions in US, one in EU (Ireland), three in Asia (Singapore, Tokyo, Beijing), one in Australia (Sydney), and one in South America (Sao Paulo). In addition Amazon supports a Govt. cloud model, namely AWS GovCloud (US). The GovCloud is designed to satisfy specific US Govt. laws and regulations, so that US government agencies can use cloud infrastructure [10]. This feature is available only in US now. Amazon does not move or doesn t replicate customers data between two separate regions, i.e., the data stays within the regional location (unless the customers does by themselves), thereby alleviating the risks associated with the data locality for Amazon customers. But this is a service provider specific function, which needs to be assessed as a part of cloud adoption strategy. Though the physical location of data can be of prime concern for organisations dealing with nuclear information or sensitive data, there are options available, or can be addressed using other compensating controls. Such as encryption, stream lined and well managed access control, auditability and having proper governance structure in place Data Loss In cloud computing environment there are multiple avenues for data loss or data leakage to occur. Examples are; malicious attackers targeting cloud facilities (e.g., attack on Gmail in June 2011, compromise of icloud in Aug 2014), accidental deletion of data assets by the service provider, or physical catastrophe on their data centre. Though the data loss and data leakage are serious threats and causes significant risk to users dealing with nuclear facility or sensitive data, the inherent feature of cloud provides great level of data protection mechanisms as well, such as; In a cloud environment every user s application and their data is contained in a virtual box, and runs within in its boundary. No application running in a user partition knows the existence of its neighbor. This feature of isolation and containment provides great level of protection by itself. Users can encrypt their data. Many CSPs provides in built functions compatible with Advanced Encryption Standard (AES) to enable encryption in both storage and transmission. Alternately, users can encrypt it prior, without depending upon the CSPs provided functions. If so the users should have a robust encryption key management systems following proper governance regime; otherwise the data would become irretrievable. 4

5 The cloud providers have high level of redundancy and duplicate data to multiple locations to counter the threat of regional data center failure thereby ensuring high availability, continuity of service, acceptable performance and to avoid single point of failure. Data duplication is one of the default characteristics of cloud computing. Looking at from an angle of sensitive data this raises some serious concerns as well. If the secondary storage falls outside the regional area, then that could give rise to jurisdictional and legal challenges as mentioned earlier. But if the secondary storage falls within the region, then there is risk associated with regional data centre failure. However, cloud providers are cautious about this, and have the capacity and resources to scale and to manage such incidents without affecting the services. Regardless, the cloud customers dealing with sensitive data should always encrypt the data, before uploading to the cloud, in any cloud model, to reduce the risk of data leakage Multi-tenancy Cloud service providers deliver their services in a scalable way by sharing infrastructure, platform and applications among multiple tenants. Researchers have demonstrated security risks associated with multi-tenancy. They demonstrated a leakage attack against Amazon EC2 virtual machine by colocating a physical instance to the target VM instance and launching a side channel attack. But, a further follow up study concluded that side channel attacks aren t just a potential risk, but only a probability [4, 11]. Much larger risk is due to potential misconfiguration of shared component, such as hypervisor, or exploiting vulnerability in a shared platform component, which can expose the entire environment to potential compromise affecting many tenants. But the CSA study also reported that the perceived risk due to shared technology misconfiguration is rather low [6]. Providers often have multiple levels of controls and resiliency built into the cloud infrastructure. Alternately, some CSPs (e.g., Amazon) provide single tenancy option for an additional cost Malicious insider The risk due to malicious insiders has been a topic of debate in the security industry for some time now. Malicious insider is someone who is either a current or former employee who has or had authorised access to an organisations network or system and intentionally exceeded or misused that access rights in a manner which can negatively impact the organisation s confidentiality, integrity or availability of information assets. In cloud computing, the data is stored and processed outside the confines of an organisation and the customers do not have any control over provider s personnel, fuelling the insecurity feeling. The lack of visibility into the hiring practices of CSPs adds to the extent of insider threat concern. By adopting cloud computing, in fact the customers are bound to confer an unprecedented level of trust on cloud providers. Despite, a recent research report on cloud computing vulnerability incidents by CSA ranked the threat due to the malicious insider causing cloud outage below 5% [12]. This is a major win factor for the providers. Major providers take insider threat very seriously; conduct formal background checks and vetting process on personnel who has access to critical resources such as the data centre. CSPs deploy multiple levels of access controls, auditability, and provision access to resources based only on individual employee s functional role [10, 13]. In general, CSP staff, including system administrators, do not have any visibility to customers instance inside a virtual machine; for example, an Amazon employee does not have any access to a user s EC2 instance [10]. It is impossible to know the location of a customer data among huge array of servers, thereby making it very difficult for anyone with malicious intent to physically access a given customer s data. The exact location of physical data centre remains very much confidential too. These multiple levels of access controls and restrictions make the threat due to insiders less concern Insecure Interfaces Cloud computing exposes a set of software interfaces, known as Application Programming Interfaces (API), which customers use to manage and interact with cloud services. Dynamic service 5

6 provisioning, management, orchestration, monitoring and more importantly the user authentication and access control are all performed using these interfaces. In addition, third party organisations use these services to provide value added services. These interfaces must be protected against any attempt to circumvent the policy. CSA reported that the threat due to insecure interface vulnerability is 29% of all threats [12]. However CSPs follows, rigid and rigorous security practices that are well integrated to its application development life cycle, and they respond quickly to any flaws or vulnerabilities found. If the client organisations, especially those dealing with sensitive data, want to consume third party add on tools, they should check the process, policies and security certification status of the providers as a part of the cloud migration strategy Account Hijacking Unauthorised person, using illegal means, getting access to an authorised users account and using the credentials to access account or service is referred as account hijacking. In the cloud environment this problem is of higher magnitude, because the systems can be accessed from anywhere over Internet, using hijacked credentials. Major cloud vendors provide Identity and Access Management (IAM) services, which enables multi factor authentication and fine-grained access control provisioning mechanisms. This is a highly recommended and secure way to access the cloud services by authorised users, primarily those dealing with sensitive data, to mitigate threat against account hijacking. There are also possibilities of security risks due to Denial of Service attack against cloud infrastructure being it is a high value target, hardware failure, closure of cloud services, cloud specific malware or vendors having inadequate facilities. These are all parameters to be assessed in view of the specific organisational requirements and risk appetite. 2.3 Cloud Security Advantages Though there is a big concern regarding data security in the cloud, the cloud computing provides some major security benefits too. Cloud vendors have been becoming security mature and provide many security features and suite of products, which can be configured and deployed easily. Most of them also have compliance accreditation to various international standards [10, 13, 14]. Few of the major security benefits to mention are: (a) greater investment in security infrastructure, (b) fault tolerance, reliability and resiliency, (c) Identity and Access Management services, (d) business continuity, (e) low cost disaster recovery and storage solutions, (f) real time detection of system tampering (h) rapid re-constitution of services (i) encryption (j) and on demand security controls. More importantly, major cloud providers have highly skilled dedicated security team, the capacity to scale and the ability to quickly react and recover in case of security incidents. These features are hard to have and expensive to maintain for an IT department of a normal organisation. 3. Nuclear Facility Information Security Requirements The respective regulatory authority or the host Govt. often stipulates the information security requirements and classification of information assets in a nuclear facility, research centres or similar institution of national importance. In the hindsight, security requirements conform to satisfy the confidentiality, integrity and availability of information assets. Access to such data often requires the satisfactory compliance with need-to-know principle and security clearance. Countries may also regulate the trans-border flow of the information as well as the storage location. For example, European data protection laws regulates the handling, processing and data transfer across its borders [3]. The organisation must identify and document its security, privacy, legal and compliance requirements for cloud services to meet, as criteria for risk assessment and selection of cloud provider. 6

7 3.1 Due Diligence Process It is essential to understand the responsibility of cloud service consumers and providers. Moving the organisations IT to cloud often creates a shared responsibility model between the provider and consumer, and it depends upon the service delivery model. Cloud providers are responsible for securing everything that they provide and consumers for everything that they deploy. For example, in case IaaS, providers have the responsibility to secure everything up to and including the virtualisation layer and the customers have the responsibility of securing everything above it, as described in FIG. 2. Table I lists, the essential cloud evaluation criteria. [3, 15] Table I. Essential cloud evaluation criteria Task Description Provider Evaluate the security controls and certification that the provider has; e.g., ISO evaluation standards or industry compliances in line with your requirements. Consider parameters like track record, competency, longevity, industry presence, visibility of audit logs and ensure confidence. Data locations Ensure the data locations and cross border data flow meet compliance with regulatory or other industry specific requirements. Third party usage Evaluate the provider s use of third parties and the services they are outsourcing Governance and Compliance Trust Access Management Instance isolation and tenancy Availability Data Protection Incident Response Human Resources Service Level Agreements Back out plan and control mechanism in place and verify that they satisfy your needs. Review and assess the provider s policies, process and service offerings are satisfactory and in accordance with your organisational requirements, especially to the related industry laws, regulations, security and privacy. Put in place an audit mechanism to ensure that governance and compliance regime is followed. Incorporate mechanisms into the contract to allow visibility into the security and privacy controls, their policy and process and performance over time. Institute a risk management program that s flexible and adaptable to the shifting landscape. Ensure that the provider has proper safeguards in place for secure authentication, authorization and other identity and access management functions. Understand the underlying architecture that the provider is using to provision services. Understand the virtualisation and instance isolation and storage isolation services the provider offers, its viability, usability and risks involved. Ensure that the provider has the capability and means to provide continuous services, and in the event of a disaster or disruption to the service, the services and information assets are restored within an acceptable timeframe, as per your need. Evaluate that the provider s data management solutions meet your organisational requirements. Verify that their data protection controls and data centre meet industry standards. Assess the incident response procedures that the provider follows to handle security incidents, and ensure that they are satisfactory or negotiate contract terms as required. Assess the recruitment and vetting process the employer has in place, especially for those with system administration roles and data centre access and functions. Verify that the provider is open for a negotiable SLA and ensure that all contractual requirements are explicitly stated in the SLA. Have a mechanism in place to verify SLA compliance. Be cautious to non-negotiable SLAs, as they are typically drafted in favour of the provider, and may be subjected unilateral change by them. This may prove impracticable, especially for organisations dealing with nuclear data. Having a strong SLA, is a crucial element of cloud adoption. Negotiate a back out plan, should the organisation decide that it no longer needs the services and avoid a vendor lock situation. In short, the organisation should undertake the following tasks as a part of outsourcing strategy. Identify security, privacy, compliance and regulatory and other requirements for cloud services to meet and make this as a part of cloud selection criteria. 7

8 Perform risk assessment on the service provider, and ensure that it is in conformance with the organizational objectives and risk appetite. Evaluate the providers ability and commitment to deliver services over the period of time that the organization wants to engage with them. Ensure that all contractual requirements are clearly stipulated in SLA and agreed by the provider. Implement a process for periodic verification of SLA. Upon termination ensure that all resources made available to the provider or entrusted with the provider are returned in a usable form, and confirm the evidence that data assets in the provider s storage locations has been properly expunged with no residual data left. 4. Conclusion Cloud computing has changed the way the IT services are being delivered and consumed and there has been a tremendous growth in cloud adoption and that continues to grow. Moreover, there is a growing push by many Governments to move govt. agencies or departmental IT services to cloud, for cost and performance benefits. Nevertheless, there also has been a growing concern about the information security and privacy of data assets stored on the cloud. Many of the features that make cloud computing attractive can also be at odds with traditional security models and controls, and this is a major factor especially for those organisations dealing with sensitive data of national importance, like national security, nuclear related data or institutions dealing with classified research. On the other side, public cloud model offers very many security advantages and benefits too. Cloud computing is here to stay and it is the future. It offers great deal of computing and storage power at a low cost, purely based on a consumption model. We strongly recommend that nuclear installations, research centres or similar institutions should approach cloud adoption seriously, after going thru proper due diligence process. If public cloud model raises concern due to security, jurisdiction, data location, or regulatory compliance issues, consider private cloud, community cloud or GovCloud (if available) as a viable alternative. However, there is no evidence that the public cloud is less secure than private cloud or on-premises data centres. The large cloud providers have lot of vested interest in keeping the customers data assets safe and secure and they often provide better security than customers can do on their own. Public cloud providers are always under scrutiny and for them there is so much at stake if something goes wrong [15]. Often public cloud offers better security protection solutions and controls. Moreover, private cloud lacks the capacity to scale, the agility and economies that public cloud offers. While outsourcing relieves IT operational commitment on the part of the organization, the act of engaging a cloud provider s service offerings, especially in a public cloud model poses risks, against which an organization needs to safeguard itself. The decision to transition to outsourced cloud computing environment is therefore, a risk management exercise in itself. Outsourcing of services does not transfer the accountability. Accountability for security of information assets remains with the organisation and not with the provider. [3] Major public cloud providers have taken security very seriously, and they made very significant progress in protecting customer s data assets through continuous innovation, technology advancements and implementing best practices. Many of them have various security standards (e.g., ISO 27001, FedRAMP, FIPS etc.) or industry compliant (e.g., PCI DSS, HIPPA) certifications also, which are hard to have and to keep for a normal organisation s IT department. The accreditations and periodic audit by the relevant authorities provide much needed assurances to customers. In addition, cloud service providers also have a pool of highly skilled and talented resources, technological and financial means to leverage. Security is also a factor of benefits of scale. In simple terms, all kinds of security measures are cheaper when implemented on a larger scale. Therefore, the same amount of investment in security buys better protection in cloud environment, and hence can offer significantly improved security solutions to consumers. [16] 8

9 Another open issue is the ability to perform digital forensic investigations, in case of security incidents and the support that CSPs can provide. Recent advancement in cloud service offerings includes support for incident investigations by some service providers. For example, Amazon s CloudTrail is a comprehensive logging mechanism which logs all user activities to a predefined location. Log files are encrypted and events are recorded in UTC time format, and logs satisfy international and compliance standards like ISO 27001:2005, PCI DSS etc. [10]. In short, the logs provide valuable forensic info like who did what activity, when and from where. Importantly, the users can retrieve the logs, without any support from the provider. However, the extend of provider s support for incident investigations should be a parameter for consideration during vendor selection. In summary, nuclear organisations or similar institutions should not be in the process of running IT, rather they should be consuming IT on need basis. Using cloud computing, organisations can turn big multi-year capital expenditure to operational expenditure, resulting considerable cost savings while focussing on their core business. REFERENCES: [1] Gartner. (2014, July 2014). Forecast: Public Cloud Services, Worldwide, , 1Q14 Update. Available: [2] CSA, "Security Guidance for Critical Areas of Focus in Cloud Computing V3.0," Cloud Security Alliance [3] W. Jansen and T. Grance, "Guidelines on security and privacy in public cloud computing," in NIST special publication vol , ed, 2011, pp [4] IEEE. (2014, May 2014) IEEE Cloud Computing Premiere Issue. IEEE Cloud Computing Premiere Issue. 4-7, Available: [5] J. Dykstra and A. T. Sherman, "Understanding issues in cloud forensics: two hypothetical case studies," Journal of Network Forensics 2011b, vol. 3, pp , [6] CSA, "The Notorius Nine Cloud Computing Top Threats in 2013," Cloud Security Alliance [7] S. Subashini and V. Kavitha, "A survey on security issues in service delivery models of cloud computing," Journal of Network and Computer Applications, vol. 34, pp. 1-11, [8] P. Mell and T. Grance, "NIST: Effectively and securely using the cloud computing paradigm," [9] B. Hay, K. Nance, and M. Bishop, "Storm Clouds Rising: Security Challenges for IaaS Cloud Computing," in 2011 System Sciences (HICSS), 44th Hawaii International Conference on, 2011, pp [10] A. S. Centre, "Amazon Web Services: Overview of Security Process," [11] T. Ristenpart, E. Tromer, H. Shacham, and S. Savage, "Hey, you, get off of my cloud: exploring information leakage in third-party compute clouds," in Proceedings of the 16th ACM conference on Computer and communications security, 2009, pp [12] CSA, "Cloud Computing Vulnerability Incidents: A Statistical Overview," Cloud Security Alliance [13] Google. (2014, June). Google's Approach to IT Security, A Google White Paper. Available: [14] Microsoft, "Addressing Cloud Computing Security Considerations with a Partner Private Cloud," Microsoft2011. [15] D. Hester. (2014) 7 Ways to Evaluate Cloud Services. InfoSecurity Professional March-April [16] D. Catteddu; G. Hogben, "Cloud Computing Risk Assessment," European Network and Information Security Agency (ENISA) Nov

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