Database Security Issues in the Cloud, Part 2: Regulatory Compliance
As the number of databases moving to public, private and hybrid cloud computing infrastructure increases, security concerns are a significant and growing problem. Organizations will do well to scrutinize the security practices of cloud providers and other third parties that store their data. But wherever databases are running, responsibility for the security and integrity of data ultimately rests with the organization that owns the data – even when it resides with a service provider.
As I outlined in Part 1 of this post, cloud database security concerns fall into three basic categories: data access control (covered in Part 1), regulatory compliance, and physical/network controls. This post discusses regulatory compliance issues.
Regulatory compliance issues in the cloud
Much has been written about concerns with physical control of data in cloud environments. Cloud providers frequently need to reconfigure and/or move the virtual servers hosting your data, possibly across multiple data center locations.
How can you demonstrate to auditors that your data is secure if you don’t know exactly where it resides? The answer lies in having clear visibility into database activity relative to applicable regulations. You need to:
- Put the necessary policies in place to meet compliance requirements;
- Audit your databases against your policies and against all the regulations that apply to you, whether the data resides in a cloud environment or not; and
- Make sure you can generate all the reports on database activity that you need to demonstrate compliance to auditors.
At Buda Consulting we use automated tools including Application Security’s Appdetective Pro to assess the vulnerability of clients’ databases and audit them against a host of regulations. The following list from the Appdetective documentation describes some of the key audit policies that we check in regulated environments:
- Basel II – ideal for a Basel II compliance assessment
- Best Practices for Federal Government
- DISA-STIG Database Security Configuration – leverages the configuration parameters outlined by the DISA-STIG for SQL Server and Oracle
- Gramm-Leach-Bliley Act – structured according to GLBA standards and recommended for GLBA compliance assessment
- HIPAA – structured following NIST standards and best practices for databases security; highly recommended for use in a HIPAA compliance assessment
- PCI Data Security Standard – recommended for use in PCI compliance assessments
- Sarbanes-Oxley – follows CoBIT and ISO 17799 standards; recommended for use in a SOX compliance assessment
Using tools like App Detective Pro, auditors and advisors can perform a database security assessment against the organization’s policies and against applicable regulations, capture results for manual verification, and generate compliance reports.
Some of the scans will be difficult or impossible to run in a cloud environment without the assistance of the cloud provider. In particular, scans that require privileged operating system accounts will not be possible without cloud provider cooperation.
Therefore, it is important to obtain from the cloud provider documentation ensuring that they have the necessary controls in place to satisfy the applicable regulations.
This may be more difficult than it sounds. Some cloud providers refuse to give out any information about their security policies and procedures, indicating that doing so may compromise security. Others may withhold specifics, but instead point to the fact that they have undergone a SAS 70 type II audit. While passing a SAS 70 type II audit can be a valuable criterion to use when evaluating a provider, you must be sure to review which controls are included in that audit. These audits do not have to include every control that may be important to the pertinent regulations impacting your business.
Contact Buda Consulting to learn more about how to ensure the security of your data in the cloud.