Date post: | 16-May-2015 |
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Technology |
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THE IM
PACT
OF CLO
UD :
CLOUD C
OMPUTI
NG
SECURITY
& PRIV
ACY
12
/ 9/ 2
01
3
“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
Can we still trust the ‘cloud’?
What are the local laws that govern data being collected, transferred and stored?
BIGGEST INHIBITOR TO THE ADOPTION OF CLOUD
COMPUTING
Data Security
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
CLOUD SECURITY - STAKEHOLDERS
Data collector/own
er• Outsourcing:
How to select a cloud vendor?
• How to maintain direct control to safeguard data integrity?
Cloud service providers
• How to satisfy data residency and privacy requirements
• How to remain flexible and provide cost-effective service?
Regulator
• Formulation of relevant standards and practices
• How to ensure adoption and compliance?
• Would sensitive data end up overseas?
Customers/end-users
• Are my data safe in the cloud?
• Would I know if there is security or privacy breach?
ISSUES ON CLOUD SECURITY
Security
Is the data protected from theft, leakage, spying or attacks?
What is the level of control
and protection?
Residency
Where is the data stored?
geographically disbursed?
What to do with data in
transit & outside
territory?
Privacy
Who can see personally identifiable information
(PII)?
Storing, transferring, locating and protecting PII
Challenges of cloud and
security
Maintaining ownership and control
of data
Info on 3rd party service
and distributed
infrastructure Deliver
resiliency, availability
and flexibility of cloud services
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
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 infocloud.gov.hk
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
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
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?
CRITICAL AREAS
Governance Operation
Governance and Enterprise Risk Management
Traditional Security, Business Continuity and Disaster Recovery
Legal and Electronic Discovery Data Center Operations
Compliance and Audit Incident Response, Notification and Remediation
Information Lifecycle Management
Application Security
Portability and Interoperability Encryption and Key Management
Identity and Access Management
Virtualization
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
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)
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
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
THANK YO
U!
Charles MokLegislative Councillor (Information Technology)
[email protected]: Charles Mok BTwitter: @charlesmok