Rational Survivability

In the Information Security community, many of us have long come to the conclusion that we are caught in what I call my “Security Hamster Sine Wave Of Pain.”  Those of us who have been doing this awhile recognize that InfoSec is a zero-sum game; it’s about staving off the inevitable and trying to ensure we can deal with the residual impact in the face of being “survivable” versus being “secure.”

While we can (and do) make incremental progress in certain areas, the collision of disruptive innovation, massive consumerization of technology along with the slow churn of security vendor roadmaps, dissolving budgets, natural marketspace commoditzation and the unfortunate velocity of attacker innovation yields the constant realization that we’re not motivated or incentivized to do the right thing or manage risk.

Instead, we’re poked in the side and haunted by the four letter word of our industry: compliance.

Compliance is often dismissed as irrelevant in the consumer space and associated instead with government or large enterprise, but as privacy continues to erode and breaches make the news, the fact that we’re putting more and more of our information — of all sorts — in the hands of others to manage is again beginning to stoke an upsurge in efforts to somehow measure and manage visibility against a standardized baseline of general, common sense and minimal efforts to guard against badness.

Ultimately, it doesn’t matter how “secure” Cloud providers suggest they are.  It doesn’t matter what breakthroughs in technology sprout up in the face of this new model of compute. The only measure that counts in the long run is how compliant you are.  That’s what will determine the success of Cloud.  Don’t believe me? Look at how the leading vendors in Cloud are responding today to their biggest (potential) customers — taking the “one size fits all” model of mass-market Cloud and beginning to chop it up and create one-off’s in order to satisfy…compliance.

Why?  Because it’s easier to deal with the vagaries of trust and isolation and multi-tenant environments by eliminating the latter to increase the former. If an auditor/examiner doesn’t understand or cannot measure your compliance to those things he/she is tasked to evaluate you against, you’re sunk.

The only thing that will budge the needle on this issue is how agile those who craft the regulatory guidelines are or how you can clearly demonstrate why your compensating controls mitigate the risk of the provider of service if they cannot. Given the nature and behavior of those involved in this space and where we are with putting our eggs in a vaporous basket, I wouldn’t hold my breath.  Movement in this area is glacial at best and in many cases out of touch with the realities of just how disruptive Cloud Computing is.  All it will take is one monumental cock-up due to a true Cloudtastrophe and the Cloud will hit the fan.

As I have oft suggested, the core issue we need to tackle in Cloud is trust, since the graceful surrender of such is at the heart of what Cloud requires.  Trust is comprised of Security, Control, Service Levels and Compliance.  It’s relatively easy to establish where we are today with the first three, but the last one is MIA.  We’re just *now* seeing movement in the form of SIGs to deal with virtualization.  Cloud?

When the best you have is a SAS-70, it’s time to weep.  Conversely, wishing for more regulation will simply extend the cycle.

What can you do?  Simple. Help educate your auditors and examiners. Read the Cloud Security Alliance’s guidelines. Participate in making the Automated Audit, Assertion, Assessment, and Assurance API (A6) a success so we can at least gain back some visibility and transparency which helps demonstrate compliance, since that’s how we’re measured.  Ultimately, if you’re able, focus on risk assessment in helping to advise your constituent business customers on how to migrate to Cloud Computing safely.

There are TONS of things one can do in order to make up for the shortcomings of Cloud security today.  The problem is, most of them erode the benefits of Cloud: agility, flexibility, cost savings, and dynamism.  We need to make the business aware of these tradeoffs as well as our auditors because we’re stuck.  We need the regulators and examiners to keep pace with technology — as painful as that might be in the short term — to guarantee our success in the long term.

Manage compliance, don’t let it manage you because a Cloud is a terrible thing to waste.

/Hoff

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