The benefits of cloud computing (specifically Software as a Service [SaaS]) over in-house development are clearly articulated and well known, and they include rapid deployment, ease of customisation, reduced build and testing effort, and reduced project risk.
Recent high-profile outages and security breaches serve to further confuse businesses as they attempt to correlate their current internal control environment and proposed controls for the cloud with the external incidents chronicled in the press.
Over the last few years, a plethora of documents have been written containing risk exposure, ad hoc guidance and control checklists to be consulted when considering cloud computing.
In 2009, the European Network and Information Security Agency (ENISA) produced a document titled ‘Cloud Computing: Benefits, Risks and Recommendations for Information Security’.
In July 2011, ISACA released IT Control Objectives for Cloud Computing: Controls and Assurance in the Cloud, which provides a comprehensive guide to cloud controls taken from COBIT, Val IT and Risk IT. The security-related risk can be assessed in a similar structured approach by assessing against selected ISO 2700x, COBIT and NIST 800-53 controls that are applicable to the exposures within cloud computing. The ten principles of cloud computing risk8 help to give context to the frameworks for assessment previously discussed, and they can be used as an overall road map for migration to cloud computing. The ISACA Business Model for Information SecurityTM (BMISTM)9 (figure 4) was used as an overarching framework for risk and security. Based on BMIS, these 10 principles of cloud computing risk provide a framework for cloud computing migration which is presented here in a case study. The business benefit of placing this function in the cloud is that it will allow branches, call centres, brokers and other channels to use the same code base and avoid replicating the calculations in multiple places. The first step in the framework is to formulate and communicate a vision for the cloud at an enterprise and business-unit level. Once the vision is articulated and the risk management organisation is in place, the next step in the road map is to ensure visibility of what needs to be done and the risk of doing it. A more complete CIA analysis might also consider detailed business requirements, data retention requirements, and privacy and regulatory requirements. Once this assessment is completed, the asset can be mapped to potential cloud deployment models. As the next step, the risk associated with a cloud implementation must be assessed against the risk associated with the incumbent in-house system, and also against the option of acquiring a new internally operated system. The current risk assessment may have identified a value-at-risk (VaR) of US $20 million per year and a need to spend approximately US $1 million–$2 million, stabilising and securing the existing system. The risk profile for the business process after moving it to a private cloud (using the combined ISO 9126 and COBIT assessment framework) is shown in figure 8. Movement of the business function to a private cloud reduced the VaR to around US $2 million per annum by removing the exposure to aging, poor-performing technology, and removing the user and data security risk of having multiple copies of the system and data in circulation. This article has reviewed some of the existing guidance to keep in mind when considering cloud computing, suggested ISO 9126 as a valuable standard for a more structured and coherent assessment of cloud offerings, and proposed ten principles of cloud computing risk loosely based on BMIS and cloud assessment road map consisting of four guiding principles: vision, visibility, accountability and sustainability. David Vohradsky, CGEIT, CRISC, is a principal consultant with Tata Consultancy Services and has more than 25 years of experience in the areas of applications development, program management, information management and risk management.
Similarly well known are Infrastructure as a Service (IaaS) benefits, which include reduction in cost, movement from capital expenditure to operational expenditure and agility.1 A consensus on the risk of cloud computing is, however, more difficult to achieve because the industry is lacking a structured framework for risk identification and assessment.


Most of these are deep on security concerns but narrow across the breadth of IT risk where a comprehensive framework for assessment is needed. The business function is part of the decision-making process within the end-to-end home loan business process shown in figure 5. The CIA rating of the business data is an average of high, based on the assessment provided in figure 6. The framework for assessment could be used for each of these options, to assess risk areas such as deficient vendor or internal support, application complexity, and application reliability.
Figure 1 gives a comparison of the top types of risk identified by the CSA, OWASP and ENISA, showing the variation in both content and ranking. In the case study, an assessment of the existing loan mortgage insurance application identified an aging application with overreliance on a single vendor and limited disaster recovery. In the case study, the business decides to assign ownership of the complete (business and IT) risk of the initiative to the retail bank operational risk manager, who works with the departmental IT risk manager to plan actions covering both the business and technical risk involved.
In the case study, the retail bank operational risk manager ensures that relevant policies are in place and communicated, and that a mapping of policy clauses to the assessment framework is included. In the case study, the departmental IT risk manager is involved in all aspects of the initiative, including vendor evaluation and management, technology review, security assessment and design, and the final investment decision. This will require working with the IT manager and the possible engagement of external assessment organisations. A gap analysis is then performed against IT development and support processes and included in the risk and control profile. The risk profile for cloud migration itself is also in a state of flux, as existing offerings are maturing and new offerings are emerging. The ISACA publication7 critiques a number of standards, certifications or frameworks, including COBIT, ENISA, CSA, NIST, ISO 27001, the American Institute of Certified Public Accountants (AICPA) Service Organisation Control (SOC) 1 Report, AICPA Trust Services (SysTrust), CSA’s Cloud Security Matrix, FedRAMP, Health Information Trust Alliance (HITRUST), BITS Shared Assessment Program and Jericho Forum® Self-assessment Scheme (SAS).
In addition, the standard can be used to derive a superset of risk that is currently not coherently articulated in the industry. As an example, figure 3 shows a cross-reference of the security-related risk (identified in the literature reviewed) to COBIT 4.1 DS5 Ensure systems security. Executives must have oversight over the cloud—The business as a whole needs to recognise the value of the cloud-based technology and data. Management must own the risks in the cloud—The management of the relevant business unit must own the risk associated with its use of cloud services, and must establish, direct, monitor and evaluate commensurate risk management on an on-going basis. All necessary staff must have knowledge of the cloud—All users of the cloud should have knowledge of the cloud and its risk (commensurate with their role in the organisation), understand their responsibilities and be accountable for their use of the cloud.
Management must authorise what is put in the cloud—All cloud-based technology and data must be formally classified for confidentiality, integrity and availability (CIA) and must be assessed for risk in business terms, and best practice business and technical controls must be incorporated and tested to mitigate the risk throughout the asset life cycle. The as-is risk profile for the current in-house system (using the risk associated with deficient characteristics from the ISO 9216 framework) is shown in figure 7.
A similar risk assessment (as well as an assessment of relative business value) should be conducted on the other option—an internally operated and hosted system.


In the case study, the business owner works with the operational risk manager to develop a matrix of roles and responsibilities, shown in figure 9.
Mature IT processes must be followed in the cloud— All cloud-based systems development and technical infrastructure processes must align with policy, meet agreed business requirements, be well documented and communicated to all stakeholders, and be appropriately resourced. Management must buy or build management and security in the cloud—Information risk and security, as well as its monitoring and management, must be a consideration in all cloud investment decisions. Management must monitor risk in the cloud—All cloud-based technology developed or acquired must enable transparent and timely reporting of information risk and be supported by well-documented and communicated monitoring and escalation processes.
Best practices must be followed in the cloud—All cloud-based systems development and technical infrastructure related processes must consider contemporary technology and controls to address emerging information risk identified through internal and external monitoring.
In doing so, the publication highlights both the need for a consistent and broadly accepted risk assessment framework and the fact that its existence still remains elusive. A cloud-consuming business needs to be aware of risk variations within each cloud model and remain accountable for risk and security regardless of the cloud model or the contractual obligations of the cloud service provider. In the case study, the home lending line-of-business owner and the IT manager work together to ensure that the involved business and technology staff have the appropriate skills to embark on the cloud initiative or that the needed expertise is obtained externally.
In the case study, the retail banking operational risk manager and departmental IT risk manager work together to develop an ongoing cloud risk and security monitoring, reporting and escalation process. The operational risk manager works with the IT risk manager and vendor manager to ensure that processes are in place to similarly assess compliance within the cloud service provider. In addition, businesses struggle with identifying and following a road map for cloud implementation. There is also a potential business driver for allowing customers access to their own data if placed on the public cloud. There must be constant vigilance and continuous monitoring of risk to these information assets, including ensuring compliance with appropriate laws, regulations, policies and frameworks. This is related to the technology dimension of BMIS, and it is where the ISO 9126-based framework for assessment is used in this road map.
Vohradsky specialises in governance, risk and compliance within TCS’s Global Consulting Practice, is a member of the ISACA CGEIT Test Enhancement Subcommittee, and an external thesis examiner for the Doctor of Business Administration at Charles Sturt University (Australia). In the case study, the home lending line of business owner must ensure that the necessary background checks, segregation of duties, least privilege and user access review controls are in place in the business, IT and cloud service provider. In the case study, the departmental IT risk manager and IT resources involved in the cloud initiative undertake continuing education on cloud technology and related risk through formal education, industry contacts and associations such as ISACA. Paradoxically, from a small to medium-sized enterprise perspective, migrating to the cloud may in fact mitigate risk.2 For example, the likelihood of server misconfiguration or poor patch management leading to a successful attack is greatly reduced, as is the risk of data loss due to less use of portable media.



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