The Impact of Cloud: Cloud Computing Security and Privacy

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Presentation to HKQAA: The Impact of Cloud: Cloud Computing Security and Privacy (2013.10.29)


  • 1. Technological advances, combined with the ubiquity of the Internet, have spawned a near-infinite range of potentially grave security threats to governments, commercial entities and individuals. Paul Rosenzweig

2. Can we still trust the cloud? What are the local laws that govern data being collected, transferred and stored? 3. BIGGEST INHIBITOR TO THE ADOPTION OF CLOUD COMPUTINGData Security 4. SENSITIVE DATA IN THE CLOUD More data, more storage Personally identifiable information examples Credit card information Medical records Tax records Customer account records Human resources information Banking and insurance records Browsing history, emails and other communication 5. CLOUD SECURITY - STAKEHOLDERS Data collector/ownerCloud service providersOutsourcing: How to select a cloud vendor? How to maintain direct control to safeguard data integrity?How to satisfy data residency and privacy requirements How to remain flexible and provide costeffective service?Regulator Formulation of relevant standards and practices How to ensure adoption and compliance? Would sensitive data end up overseas?Customers/endusers Are my data safe in the cloud? Would I know if there is security or privacy breach? 6. ISSUES ON CLOUD SECURITYSecurityResidencyPrivacyIs the data protected from theft, leakage, spying or attacks?Where is the data stored? geographically disbursed?Who can see personally identifiable information (PII)?What is the level of control and protection?What to do with data in transit & outside territory?Storing, transferring, locating and protecting PII 7. Info on 3rd party service and distributed infrastructure Deliver resiliency, availability and flexibility of cloud servicesMaintaining ownership and control of dataChallenges of cloud and security 8. COMPLIANCE REQUIREMENTS Some countries have laws restricting storage of data outside their physical country borders: India, Switzerland, Germany, Australia, South Africa and Canada EU: Data Protection Directive; Safe Harbor Principles no sending PII outside European Economic area unless protections guaranteed USA: US Patriot Act, 40+ states have breach notification laws (25 states have exemption for encrypted personal data) Canada: Freedom of Information and Protection of Privacy Act 9. HONG KONG Section 33(2)(f) of Personal Data (Privacy) Ordinance, Forming standards through HK/Guangdong Expert Committee on Cloud Computing Services and Standards Guidelines and information via 10. INTERCEPTION OF COMMUNICATIONS: REGULATIONS IN HK Article 30 of the Basic Law: freedom and privacy of communication of Hong Kong residents shall be protected by law Law enforcement agencies: Interception of Communications and Surveillance Ordinance (Cap 589) Non-public officers and non-governmental bodies: Telecommunications Ordinance (s24, s27, s29), Personal Data (Privacy) Ordinance, s161 of Crimes Ordinance 11. TWO ISSUES TO THINK ABOUT - Data residency: Transfer of personal information or moving data storage device outside of local jurisdiction - Data encryption: Data should be encrypted before being sent to the cloud, and that data owner retains the encryption keys 12. KEY QUESTIONS TO ASK What do we need? What is our goal? Where are the risks? What are the systems, processes, policies and practices we need to mitigate risks? How to protect our data assets and keep cloud platform secure? How to ensure transparency and compliance? How to evaluate potential cloud service providers? 13. CRITICAL AREAS GovernanceOperationGovernance and Enterprise Risk ManagementTraditional Security, Business Continuity and Disaster RecoveryLegal and Electronic DiscoveryData Center OperationsCompliance and AuditIncident Response, Notification and RemediationInformation Lifecycle ManagementApplication SecurityPortability and InteroperabilityEncryption and Key Management Identity and Access Management Virtualization 14. PLANNING AHEAD: STRATEGIC APPROACH Service models: SaaS, PaaS, IaaS? Multiple layers: Physical security (facilities) Network security (infrastructure) System security (IT systems) Application and data security 15. IDENTIFY, LOCATE AND DEFINE THE RISKS Identification and valuation of assets Identification and analysis of threats and vulnerabilities Risk and incident scenarios Analysis of the likelihoods of scenarios, risk acceptance levels and criteria risk treatment plans with multiple options (control, avoid, transfer, accept) 16. CONSISTENCY BETWEEN YOU AND YOUR PROVIDER Alignment of impact analysis criteria and definition of likelihood Specify assessment and risk management requirement e.g. vulnerability assessment, audit logs, activity monitoring Detailed in Service Level Agreements, contract requirements, and provider documentation 17. OPERATION: KEY AREAS Disaster Recovery and Business Continuity Breach notification and data residency Data management at rest Data protection in motion Encryption key management Identification and Access controls Long-term resiliency of the encryption system 18. Charles Mok Legislative Councillor (Information Technology) Facebook: Charles Mok B Twitter: @charlesmok