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.
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 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. The business function is part of the decision-making process within the end-to-end home loan business process shown in figure 5. 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.


In addition, businesses struggle with identifying and following a road map for cloud implementation. 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 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. 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. 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. 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 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.



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Comments

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