Rational Survivability

You’ll forgive my impertinence, but the last time I saw a similar claim of a PCI compliant Cloud offering, it turned out rather anti-climatically for RackSpace/Mosso, so I just want to make sure I understand what is really being said.  I may be mixing things up in asking my questions, so hopefully someone can shed some light.

This press release announces that:

“…Verizon’s On-Demand Cloud Computing Solution First to Achieve PCI Compliance” and the company’s cloud computing solution called Computing as a Service (CaaS) which is “…delivered from Verizon cloud centers in the U.S. and Europe, is the first cloud-based solution to successfully complete the Payment Card Industry Data Security Standard (PCI DSS) audit for storing, processing and transmitting credit card information.”

It’s unclear to me (at least) what’s considered in scope and what level/type of PCI certification we’re talking about here since it doesn’t appear that the underlying offering itself is merchant or transactional in nature, but rather Verizon is operating as a service provider that stores, processes, and transmits cardholder data on behalf of another entity.

Here’s what the article says about what Verizon undertook for DSS validation:

To become PCI DSS-validated, Verizon CaaS underwent a comprehensive third-party examination of its policies, procedures and technical systems, as well as an on-site assessment and systemwide vulnerability scan.

I’m interested in the underlying mechanicals of the CaaS offering.  Specifically, it would appear that the platform – compute, network, and storage — are virtualized.  What is unclear is if the [physical] resources allocated to a customer are dedicated or shared (multi-tenant,) regardless of virtualization.

According to this article in The Register (dated 2009,) the infrastructure is composed like this:

The CaaS offering from Verizon takes x64 server from Hewlett-Packard and slaps VMware’s ESX Server hypervisor and Red Hat Enterprise Linux instances atop it, allowing customers to set up and manage virtualized RHEL partitions and their applications. Based on the customer portal screen shots, the CaaS service also supports Microsoft’s Windows Server 2003 operating system.

Some details emerge from the Verizon website that describes the environment more:

Every virtual farm comes securely bundled with a virtual load balancer, a virtual firewall, and defined network space. Once the farm is designed, built, and named – all in a matter of minutes through the CaaS Customer Management Portal – you can then choose whether you want to manage the servers in-house or have us manage them for you.

If the customer chooses to manage the “servers…in-house (sic)” is the customer’s network, staff and practices now in-scope as part of Verizon’s CaaS validation? Where does the line start/stop?

I’m very interested in the virtual load balancer (Zeus ZXTM perhaps?) and the virtual firewall (vShield? Altor? Reflex? VMsafe-API enabled Virtual Appliance?)  What about other controls (preventitive or detective such as IDS, IPS, AV, etc.)

The reason for my interest is how, if these resources are indeed shared, they are partitioned/configured and kept isolated especially in light of the fact that:

Customers have the flexibility to connect to their CaaS environment through our global IP backbone or by leveraging the Verizon Private IP network (our Layer 3 MPLS VPN) for secure communication with mission critical and back office systems.

It’s clear that Verizon has no dominion over what’s contained in the VM’s atop the hypervisor, but what about the network to which these virtualized compute resources are connected?

So for me, all this all comes down to scope. I’m trying to figure out what is actually included in this certification, what components in the stack were audited and how.  It’s not clear I’m going to get answers, but I thought I’d ask any way.

Oh, by the way, transparency and auditability would be swell for an environment such as this. How about CloudAudit? We even have a PCI DSS CompliancePack 😉

Question for my QSA peeps: Are service providers required to also adhere to sections like 6.6 (WAF/Binary analysis) of their offerings even if they are not acting as a merchant?

/Hoff

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Mike Dahn pinged me via Twitter with an interesting and challenging question:

I took this as a challenge in 5 minutes or less to articulate this in succinct, bulleted form.  I timed it. 4 minutes & 48 seconds. Loaded with snark and Hoffacino-fueled dogma.

Here goes:

1. Get an Amazon Web Services [or Rackspace or Terremark vCloud Express, etc.] account, instantiate a couple of instances as though you were deploying a web-based application with sensitive information that requires resilience, security, survivability and monitoring. If you have never done this and you’re in security spouting off about the insecurities of Cloud, STFU and don’t proceed to step 2 until you do.  These offerings put much of the burden on you to understand what needs to be done to secure Cloud-based services (OS, Apps, Data) which is why I focus on it. It’s also accessible and available to everyone.
   –
2. Take some time to be able to intelligently understand that as abstracted as much of Cloud is in terms of  the lack of exposed operational moving parts, you still need to grok architecture holistically in order to be able to secure it — and the things that matter most within it.  Building survivable systems, deploying securable (and as secure as you can make it) code, focusing on protecting information and ensuring you understand system design and The Three R’s (Resistance, Recognition, Recovery) is pretty darned important.  That means you have to understand how the Cloud provider actually works so when they don’t you’ll already have planned around that…
   –
3. Employ a well-developed risk assessment/management framework and perform threat modeling. See OCTAVE, STRIDE/DREAD, FAIR.  Understanding whether an application or datum is OK to move to “the Cloud” isn’t nuanced. It’s a simple application of basic, straightforward and prudent risk management. If you’re not doing that now, Cloud is the least of your problems. As I’ve said in the past “if your security sucks now, you’ll be pleasantly surprised by the lack of change when you move to Cloud.”
   –
4. Proceed to the Cloud Security Alliance website and download the guidance. Read it. Join one or more of the working groups and participate to make Cloud Security better in any way you believe you have the capacity to do so.  If you just crow about how “more secure” the Cloud is or how “horribly insecure by definition” it is, it’s clear you’ve not done steps 1-3. Skip 1-3, go to #5 and then return to #1.
   –
5. Use common sense.  There ain’t no patch for stupid.  Most of us inherently understand that this is a marathon and not a sprint. If you take steps 1-4 seriously you’re going to be able to logically have discussions and make decisions about what deployment models and providers suit your needs. Not everything will move to the Cloud (public, private or otherwise) but a lot of it can and should. Being able to layout a reasonable timeline is what moves the needle. Being an idealog on either side of the tarpit does nobody any good.  Arguing is for Twitter, doing is for people who matter.

Cloud is only rocket science if you’re NASA and using the Cloud for rocket science.  Else, for the rest of us, it’s an awesome platform upon which we leverage various opportunities to improve the way in which we think about and implement the practices and technology needed to secure the things that matter most to us.

/Hoff

(Yeah, I know. Not particularly novel or complex, right? Nope. That’s the point. Just like  “How to Kick Ass in Information Security — Hoff’s Spritually-Enlightened Top Ten Guide to Health, Wealth and Happiness“)

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In advance of publishing a more consolidated compilation of various recordings of my presentations, I thought I’d post this one.

This is from Microsoft’s BlueHat v9 and is from my “Cloudifornication: Indiscriminate Information Intercourse Involving Internet Infrastructure” presentation.

The direct link is here in case you have scripting disabled.

The follow-on to this is my latest presentation – “Cloudinomicon: Idempotent Infrastructure, Building Survivable Systems, and Bringing Sexy Back To Information Centricity.”

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I got an interesting tweet sent to me today that asked a great question:

I thought about this and it occurred to me that while I would have liked to have answered that the Cloud Security Alliance Guidance was my first choice, I think the most appropriate answer is actually the following:

“Cloud Security and Privacy: An Enterprise Perspective on Risks and Compliance”  by Tim Mather, Subra Kumaraswamy, and Shahed Latif is an excellent overview of the issues (and approaches to solutions) for Cloud Security and privacy. Pair it with the CSA and ENISA guidance and you’ve got a fantastic set of resources.  I’d also suggest George Reese’s excellent book “Cloud Application Architectures: Building Applications and Infrastructure in the Cloud”

I suppose it’s only fair to disclose that I played a small part in reviewing/commenting on both of these books prior to being published 😉

/Hoff

My good friend Amrit Williams (@amrittsering) from BigFix (congrats on the IBM acquisition!) has an awesome Podcast titled “Beyond the Perimeter.”

He was nice enough to invite me to record episode 93 titled “Is Trust the Real Barrier To Cloud Computing?” (ultimately points you to an iTunes subscription.)

We spoke for almost an hour on all sorts of great discussion points related to Cloud Computing, specifically focusing on Trust (which I define in context as Security, Compliance, Control, Reliability and Privacy.)

We also spoke about the Cloud Security Alliance, CloudAudit and the HacKid conference — three things I am very passionate about.

Thanks Amrit, great conversation as usual.

/Hoff

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Every day I get asked to discuss how Cloud Computing impacts security architecture and what enterprise security teams should do when considering “Cloud.”

These discussions generally lend themselves to a bifurcated set of perspectives depending upon whether we’re discussing Public or Private Cloud Computing.

This is unfortunate.

From a security perspective, focusing the discussion primarily on the deployment model instead of thinking holistically about the “how, why, where, and who” of Cloud, often means that we’re tethered to outdated methodologies because it’s where our comfort zones are.

When we’re discussing Public Cloud, the security teams are starting to understand that the choice of compensating controls and how they deploy and manage them require operational, economic and architectural changes.  They are also coming to terms with the changes to application architectures as it relates to distributed computing and SOA-like implementation.  It’s uncomfortable and it’s a slow-slog forward (for lots of good reasons,) but good questions are asked when considering the security, privacy and compliance impacts of Public Cloud and what can/should be done about them and how things need to change.

When discussing Private Cloud, however, even when a “clean slate design” is proposed, the same teams tend to try to fall back to what they know and preserve the classical n-tier application architecture separated by physical or virtual compensating controls — the classical split-subnet DMZ or perimeterized model of “inside” vs “outside.” They can do this given the direct operational control exposed by highly-virtualized infrastructure.  Sometimes they’re also forced into this given compliance and audit requirements. The issue here is that this discussion centers around molding cloud into the shape of the existing enterprise models and design patterns.

This is an issue; trying to simultaneously secure these diametrically-opposed architectural implementations yields cost inefficiencies, security disparity, policy violations, introduces operational risk and generally means that  the ball doesn’t get moved forward in protecting the things that matter most.

Public Cloud Computing is a good thing for the security machine; it forces us to (again) come face-to-face with the ugliness of the problems of securing the things that matter most — our information. Private Cloud Computing — when improperly viewed from the perspective of simply preserving the status quo — can often cause stagnation and introduce roadblocks.  We’ve got to move beyond this.

Public Cloud speaks to the needs (and delivers on) agility, flexibility, mobility and efficiency. These are things that traditional enterprise security are often not well aligned with.  Trying to fit “Cloud” into neat and tidy DMZ “boxes” doesn’t work.  Cloud requires revisiting our choices for security. We should take advantage of it, not try and squash it.

/Hoff

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That’s right. You can’t secure “The Cloud” and the real shocker is that you don’t need to.

You can and should, however, secure your assets and the elements within your control that are delivered by cloud services and cloud service providers, assuming of course there are interfaces to do so made available by the delivery/deployment model and you’ve appropriately assessed them against your requirements and appetite for risk.

That doesn’t mean it’s easy, cheap or agile, and lest we forget, just because you can “secure” your assets does not mean you’ll achieve “compliance” with those mandates against which you might be measured.

Even if you’re talking about making investments primarily in solutions via software thanks to the abstraction of cloud (and/or virtualization) as well adjusting processes and procedures due to operational impact, you can generally effect compensating controls (preventative and/or detective) that give you security on-par with what you might deploy today in a non-Cloud based offering.

Yes, it’s true. It’s absolutely possible to engineer solutions across most cloud services today that meet or exceed the security provided within the walled gardens of your enterprise today.

The realities of that statement come crashing down, however, when people confuse possibility with the capability to execute whilst not disrupting the business and not requiring wholesale re-architecture of applications, security, privacy, operations, compliance, economics, organization, culture and governance.

Not all of that is bad.  In fact, most of it is long overdue.

I think what is surprising is how many people (or at least vendors) simply suggest or expect that the “platform” or service providers to do all of this for them across the entire portfolio of services in an enterprise.  In my estimation that will never happen, at least not if one expects anything more than commodity-based capabilities at a cheap price while simultaneously being “secure.”

Vendors conflate the various value propositions of cloud (agility, low cost, scalability, security) and suggest you can achieve all four simultaneously and in equal proportions.  This is the fallacy of Cloud Computing.  There are trade-offs to be found with every model and Cloud is no different.

If we’ve learned anything from enterprise modernization over the last twenty years, it’s that nothing comes for free — and that even when it appears to, there’s always a tax to pay on the back-end of the delivery cycle.  Cloud computing is a series of compromises; it’s all about gracefully losing control over certain elements of the operational constructs of the computing experience. That’s not a bad thing, but it’s a painful process for many.

I really enjoy the forcing function of Cloud Computing; it makes us re-evaluate and sharpen our focus on providing service — at least it’s supposed to.  I look forward to using Cloud Computing as a lever to continue to help motivate industry, providers and consumers to begin to fix the material defects that plague IT and move the ball forward.

This means not worrying about securing the cloud, but rather understanding what you should do to secure your assets regardless of where they call home.

/Hoff

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The guys from SearchCloudComputing gave me a ring and we chatted about CloudAudit. The interview that follows is a distillation of that discussion and goes a long way toward answering many of the common questions surrounding CloudAudit/A6.  You can find the original here.

What are the biggest challenges when auditing cloud-based services, particularly for the solution providers?

Christofer Hoff:: One of the biggest issues is their lack of understanding of how the cloud differs from traditional enterprise IT. They’re learning as quickly as their customers are. Once they figure out what to ask and potentially how to ask it, there is the issue surrounding, in many cases, the lack of transparency on the part of the provider to be able to actually provide consistent answers across different cloud providers, given the various delivery and deployment models in the cloud.

How does the cloud change the way a traditional audit would be carried out?

Hoff: For the most part, a good amount of the questions that one would ask specifically surrounding the infrastructure is abstracted and obfuscated. In many cases, a lot of the moving parts, especially as they relate to the potential to being competitive differentiators for that particular provider, are simply a black box into which operationally you’re not really given a lot of visibility or transparency.
If you were to host in a colocation provider, where you would typically take a box, the operating system and the apps on top of it, you’d expect, given who controls what and who administers what, to potentially see a lot more, as well as there to be a lot more standardization of those deployed solutions, given the maturity of that space.

How did CloudAudit come about?

Hoff: I organized CloudAudit. We originally called it A6, which stands for Automated Audit Assertion Assessment and Assurance API. And as it stands now, it’s less in its first iteration about an API, and more specifically just about a common namespace and interface by which you can use simple protocols with good authentication to provide access to a lot of information that essentially can be automated in ways that you can do all sorts of interesting things with.

How does it work exactly?

Hoff: What we wanted to do is essentially keep it very simple, very lightweight and easy to implement without cloud providers having to make a lot of programmatic changes. Although we’re not prescriptive about how they do it (because each operation is different), we expect them to figure out how they’re going to get the information into this namespace, which essentially looks like a directory structure.

This kind of directory/namespace is really just an organized repository. We don’t care what is contained within those directories: .pdf, text documents, links to other websites. It could be a .pdf of a SAS 70 report with a signature that refers back to the issuing governing body. It could be logs, it could be assertions such as firewall=true. The whole point here is to allow these providers to agree upon the common set of minimum requirements.
We have aligned the first set of compliance-driven namespaces to that of theCloud Security Alliance‘s compliance control-mapping tool. So the first five namespaces pretty much run the gamut of what you expect to see most folks concentrating on in terms of compliance: PCI DSS, HIPAA, COBIT, ISO 27002 and NIST 800-53…Essentially, we’re looking at both starting with those five compliance frameworks, and allowing cloud providers to set up generic infrastructure-focused type or operational type namespaces also. So things that aren’t specific to a compliance framework, but that you may find of interest if you’re a consumer, auditor, or provider.

Who are the participants in CloudAudit?

Hoff: We have both pretty much the largest cloud providers as well as virtualization platform and cloud platform providers on the planet. We’ve got end users, auditors, system integrators. You can get the list off of the CloudAudit website. There are folks from CSC, Stratus, Akamai, Microsoft, VMware, Google, Amazon Web Services, Savvis, Terrimark, Rackspace, etc.

What are your short-term and long-term goals?

Hoff: Short-term goals are those that we are already trucking toward: to get this utilized as a common standard by which cloud providers, regardless of location — that could be internal private cloud or could be public cloud — essentially agree on the same set of standards by which consumers or interested parties can pull for information.

In the long-term, we wish to be able to improve visibility and transparency, which will ultimately drive additional market opportunities because, for example, if you have various levels of authentication, anywhere from anonymous to system administrator to auditor to fully trusted third party, you can imagine there’ll be a subset of anonymized information available that would actually allow a cloud broker or consumer to poll multiple cloud providers and actually make decisions based upon those assertions as to whether or not they want to do business with that cloud provider.

…It gives you an opportunity to shop wisely and ultimately compares services or allow that to be done in an automated fashion. And while CloudAudit does not seek to make an actual statement regarding compliance, you will ultimately be provided with enough information to allow either automated tools or at least auditors to get back to the business of auditing rather than data collection. Because this data gathering can be automated, it means that instead of having a PCI audit once every year, or every 6 months, you can have it on a schedule that is much more temporal and on-demand.

What will solution providers and resellers be able to take from it? How is it to their benefit to get involved?

Hoff: The cloud service providers themselves, for the most part, are seeing this as a tremendous opportunity to not only reduce cost, but also make this information more visible and available…The reality is, in many cases, to be frank, folks that make a living auditing actually spend the majority of their time in data collection rather than actually looking at and providing good, actual risk management, risk assessment and/or true interpretation of the actual data. Now the automation of that, whether it’s done on a standard or on an ad-hoc basis, could clearly put a crimp in their ability to collect revenues. So the whole point here is their “value-add” needs to be about helping customers to actually manage risk appropriately vs. just kind of becoming harvesters of information. It behooves them to make sure that the type of information being collected is in line with the services they hope to produce.

What needs to be done for this to become an industry standard?

Hoff: We’ve already written a normative spec that we hope to submit to the IETF. We have cross-section representation across industry, we’re building namespaces, specifications, and those are not done in the dark. They’re done with a direct contribution of the cloud providers themselves, because they understand how important it is to get this information standardized. Otherwise, you’re going to be having ad-hoc comparisons done of services which may not portray your actual security services capabilities or security posture accurately. We have a huge amount of interest, a good amount of participation, and a lot of alliances that are already bubbling with other cloud standards.

Cloud computing changes the game for many security services, including vulnerability management, penetration testing and data protection/encryption, not just audits. Is the CloudAudit initiative a piece of a larger cloud security puzzle?

Hoff: If anything, it’s a light bulb in the darkness. For us, it’s allowing these folks to adjust their tools to be able to consume the data that’s provided as part of the namespace within CloudAudit, and then essentially in the same way, we suggest human auditors focus more on interpreting that data rather than gathering it.
If gathering that data was unavailable to most of the vendors who would otherwise play in that space, due to either just that data not being presented or it being a violation of terms of service or acceptable use policy, the reality is that this is another way for these tool vendors to get back into the game, which is essentially then understanding the namespaces that we have, being able to modify their tools (which shouldn’t take much, since it’s already a standard-based protocol), and be able to interpret the namespaces to actually provide value with the data that we provide.
I think it’s an overall piece here, but again we’re really the conduit or the interface by which some of these technologies need to adapt. Rather than doing a one-off by one-off basis for every single cloud provider, you get a standardized interface. You only have to do it once.

Where should people go to get involved?

Hoff: If people want to get involved, it’s an open project. You can go to cloudaudit.org. There you’ll find links about us. There’ll be a link to the farm. The farm itself is currently a Google group, which you can sign up for and participate. We have calls every Monday, which are posted on the farm and tell you how to connect. You can also replay the last of the many calls that we’ve had already as we record them each time so that people have both the audio and visual versions of what we produce and how we’re going about this, and it’s very transparent and very open and we enjoy people getting involved. If you have something to add, please do.

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David Sparks (c/o Tripwire) interviewed me on the state of Information Security in virtualized/cloud environments.  It’s another reminder about Information Centricity.

Direct Link here.

Emedded below:

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Here are the slides from my Cloud Security Alliance (CSA) keynote from the Cloud Security Summit at the 2010 RSA Security Conference.

The punchline is as follows:

All this iteration and debate on the future of the “back-end” of Cloud Computing — the provider side of the equation — is ultimately less interesting than how the applications and content served up will be consumed.

Cloud Computing provides for the mass re-centralization of applications and data in mega-datacenters while simultaneously incredibly powerful mobile computing platforms provide for the mass re-distribution of (in many cases the same) applications and data.  We’re fixated on the security of the former but ignoring that of the latter — at our peril.

People worry about how Cloud Computing puts their applications and data in other people’s hands. The reality is that mobile computing — and the clouds that are here already and will form because of them — already put, quite literally, those applications and data in other people’s hands.

If we want to “secure” the things that matter most, we must focus BACK on information centricity and building survivable systems if we are to be successful in our approach.  I’ve written about the topics above many times, but this post from 2009 is quite apropos: The Quandary Of the Cloud: Centralized Compute But Distributed Data You can find other posts on Information Centricity here.

Slideshare direct link here (embedded below.)

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