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There are a number of different ways we can evaluate cloud providers.

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We can perform various types of audits,

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either as an external group or as the consumer.

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Many cloud service providers have audits done by external groups

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that they can use to show the fact that they followed good

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practice, for example. In many cases,

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the purpose of an audit is to provide an independent

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assessment of the cloud provider.

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We don't necessarily trust if an organization has just done a self‑assessment.

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Instead,

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we have a reputable firm using a template or some type of standard

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to measure against in order to ensure that the cloud provider is

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adhering to good practice. We have, for example,

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from the Cloud Security Alliance STAR, we have things like the SSAE 18 or

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today, usually, the SSAE 20. We have the ISAE 3402,

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which is the international equivalent of the SSAE series put out

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by the AICPA. In the US Federal Government,

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we have a criteria that is then listed under FISMA.

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The STAR process put forward by the Cloud Security Alliance

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stands for security, trust, assurance, and risk.

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It allows us to take a look at what are good practice for a cloud

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provider as listed in the Cloud Controls Matrix,

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the CCM, and the General Data Protection Regulations would look at privacy.

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So the CSA STAR process allows us to compare and to ensure

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that a cloud provider is adhering to all of the practices

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listed in these documents.

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One way to ensure that something didn't get missed is to use

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something like the Cloud Controls Matrix.

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There are three different levels of STAR certification. Level one is

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where the cloud service provider performs their own self‑assessment, and

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we all know how valid that may or may not be.

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When we take a look at level two,

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we see third‑party audits conducted by a reputable independent and

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hopefully objective organization that reviews the cloud service provider to

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see whether or not they are following the good, trusted security principles

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they should be following. A level three is where we're doing this type of

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review on a continuous basis.

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There is continuous auditing being done.

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The idea of continuous audit is to ensure that an organization

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is not just compliant at the day of a review,

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but if we looked at them at any time, we would find

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that they are following good practice.

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This can be done through things like a Consensus

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Assessment Initiative Questionnaire, CAIQ.

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In the case of a self‑assessment,

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this is done every 30 days for level one. The American Institute of Certified

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Professional Accountants, the AICPA, put out a number of documents over the

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years with standards and audit engagements, and these started with a SAS 70,

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which then evolved in the SSAE 16,

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18, and now the current one is SSAE 20. It gets updated every couple of

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years, and so this was implemented in the end of 2021.

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The idea is that with each implementation we improve from

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what we learned from the earlier documents.

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The SSAE stands for the Statement on Standards for Attestation Engagements.

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So if I have an engagement to do an attestation or review of an organization,

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what are the standards that we should measure against?

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An audit should never be measured against a person's opinion.

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Instead, it should be measured against a reputable and recognized standard.

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It is put out, as we said, by the AICPA and updated on a regular basis.

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The main part of this is SOC, the System and Organization Controls report that

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is generated once the SSAE evaluation has been completed.

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If we took a look at an SSAE 20 SOC 1, that is a review of the

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financial reporting of the organization, very similar to what we

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used to see with the SAS 70, for example.

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So we know with some level of assurance whether or not the financial

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records of that cloud service provider are accurate.

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Are they in any way fictitious? Have they tried to hide something?

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We want to make sure that before we go to a cloud provider that they're not

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going to fall into bankruptcy a couple of days later. When we do a SOC 2,

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we're doing an evaluation of that cloud service provider based on several

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different principles, WebTrust and SysTrust. Here is where we look at the

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areas of security and does the cloud service provider have a good security

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program and are they implementing what are commonly recognized as acceptable

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security practices?

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We review their implementation of privacy and how they are then

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compliant with things like privacy regulations.

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We look at the integrity of their processes.

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We look at how they protect confidentiality.

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And of course,

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because a cloud provider is a critical part of our supply

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chain, we need to ensure that they have processes in place

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to ensure availability as well.

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We don't want to have all of our business reliant on a cloud

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provider and have a cut network cable or equipment failure that

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means none of my systems will actually work.

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The problem with a SOC 2 is the SOC 2 is a very detailed

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report primarily meant for internal use because it says

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what all of the problems are.

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So most organizations will instead give you a summary

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report, which is known as a SOC 3. Really,

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it's just the summary of the SOC 2, but without all of the embarrassing

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details of the things that the organization has to work on.

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Now there are a number of organizations out there that will

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actually provide their SOC 2 for you.

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They want to be transparent.

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They want to earn your trust.

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So therefore, they'll say,

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look, here you go. You can see what we're working on and

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has been brought to our attention.

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The idea of the SOC 3 is that it allows us to do marketing and show

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that we've paid attention to good security principles.

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We've had a review of our financial and, of course,

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WebTrust and SysTrust security.

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We've ensured that we're following the good practices of the Cloud

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Controls Matrix, and therefore, you can trust us with your data

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and data processing. When we conduct an SSAE 20 assessment, there

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are two ways we can do it.

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We can do what's called a Type 1 assessment where we

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conducted the assessment as of a date, as of a point in time.

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But many organizations today will instead want to see a Type 2.

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A Type 2 is a review that's done over a period of time, usually six months.

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But many organizations today are actually then using this

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in a type of continuous audit process.

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The idea being that if I've reviewed an

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organization over a six‑month time period,

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then the things they are doing are probably being done out of habit,

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not just in order to pass the day of the assessment.

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So a Type 2 costs more, but also would provide a higher level of assurance.

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Another way we can review whether or not the cloud service provider is

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following good practice is to see whether or not they are compliant with

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the international standard such as 27001.

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We review whether or not they have managed to ensure they've addressed all

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of the main security concerns that were listed in 27001.

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27001 is really the flagship standard of the 27000 series.

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27000 itself is a glossary of terms and a free document we can use to

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make sure we're all speaking the same language.

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But 27001 is a standard we can be measured against.

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It defines the standards for an information security management system.

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Another type of evaluation that's often done is according

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to the Uptime Institute. The Uptime Institute looks at

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things such as data center design, construction, and ongoing operations.

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It is there to try to ensure high availability of my cloud

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service provider if that's what I want.

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So, it evaluates the data center's infrastructure,

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things like backup power, for example,

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so that I can ensure that I am getting the level of availability I

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need, but, of course, I don't want either to be paying for services

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that we maybe didn't require either.

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A tier 4 data center, as evaluated by the Uptime Institute, is one

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in which we can have a very high level of trust.

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There are a number of other certification standards we can use as

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well. In the US Federal Government, we have FISMA,

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the Federal Information Security Management Act.

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We have PCI‑DSS from the Payment Card Industry,

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the Data Security Standard. And we have others such as the ISO

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standard 15408, better known as the common criteria,

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which is the basis for evaluation of the security properties of IT products.

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So we have things like ISO 15408 that look at the security of a product.

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We'll look at 27001, which will look at the security of an organization.

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So the idea being that if I build my security with good

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products, then of course, I can hopefully also have assurance

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in the security of the organization.

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Another product evaluation criteria that's often used is

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the Federal Information Processing Standard 140‑2, the

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evaluation of crypto devices.

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If I'm going to use a device that handles, for example, chip and PIN with

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a credit card transaction or I'm going to handle any type of encryption

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service that's built into, say, hardware, we want to evaluate it to make

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sure that that cryptography and the cryptographic functions were

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implemented in a secure way.

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So the FIPS140‑2 was the improvement on 140‑1, and it is used

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by organizations all over the world today.

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We also do see, of course, that many organizations are already moving

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towards the implementation of an even higher standard, 140‑3.

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In summary, this course provided an overview of cloud‑based services.

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It highlighted some of the security concerns that we have to look at as

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we move through the rest of this course and look at the adoption of the

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cloud. As a cloud security professional, we must ensure that security

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and business requirements are addressed in cloud migrations and

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implementations.
