© Fraunhofer
APPLIED AND INTEGRATED SECURITY
New approach for Compliance, Security and
Data privacy assessment in the Cloud Age –
NGCert Next Generation Certification
AGENDA
Fraunhofer AISEC in a nutshell
New approach for Compliance, Security and
Data privacy assessment in the Cloud Age –
NGCert Next Generation Certification
© Fraunhofer | Mario Hoffmann | 07.10.2015
Fraunhofer AISEC – In a nutshell
Fraunhofer Institute for
Applied and Integrated Security
Parkring 4
85748 Garching (near Munich) Germany
Founded 2009
> 100 employees end of 2014 Directors: Prof. Dr. Claudia Eckert
Prof. Dr. Georg Sigl
Fraunhofer AISEC – In a nutshell
Fields of expertise
• Embedded Security • Security Evaluation • Hardware Security • Product Protection• Cloud & Service Computing • Network Security
• Automotive Security • Smart Grid Security
© Fraunhofer | Mario Hoffmann | 07.10.2015
New approach for Compliance, Security and
Data privacy assessment in the Cloud Age –
NGCert Next Generation Certification
Trust
“Trust can be used to measure our confidence that a secure system behaves as expected.”
Security guidelines & policies, SLAs, certificates (CSA, NIST, BSI, EuroCloud, …)
Certification
You don‘t have to measure by your own
Certificates can give evidence that a system behaves as specified and expected.
Cloud Services
IaaS, PaaS, SaaS A question of trust(?)
Dynamic, flexibel, on-demand
Dynamic Certification
Certification criteria are verified dynamically and on-demand
© Fraunhofer | Mario Hoffmann | 07.10.2015
56% of German companies worry about that Cloud
Computing compromises compliance requirements
83% of German companies do expect that the data
centre is operated in Germany
Source: “Cloud Monitor 2015“
Association for Information Technology, Telecommunications and New Media BITKOM
The Court of Justice declares that
the Commission’s US Safe
Harbour Decision is invalid
http://curia.europa.eu/jcms/upload/docs/application/pdf/2015-10/cp150117en.pdf
© Fraunhofer | Mario Hoffmann | 07.10.2015
Example: EuroCloud Star Audit
Developed under European Cloud Strategy for a worldwide use https://eurocloud-staraudit.eu/
SaaS Seal of Quality
Provider profile, contract and compliance, security, infrastructure realibility, processes, applications, implementations
Levels of quality from 1 to 5 stars (example criteria out of > 150)
3 Stars: Provider allows the choice of place of jurisdiction by the customer or offers a contract directly according to the customers legislation
4 Stars: Direct access by admins is restricted and before getting single access transaction data will be anonymised with respect to user profiles.
5 Stars: At least once a year pentests will be performed and documented in order to proof that security means have been implemented appropriately.
Link: DuD - Datenschutz und Datensicherheit 5 | 2011, „Zertifizierte Cloud durch das EuroCloud Star Audit SaaS“, Rüdiger Giebichenstein, Andreas Weiss
Problem Statement
Traditional approach to certification
Manual evaluation of a certificate‘s requirements
Static testing intervals and validity of one to three years
Years
0
1
2
Audit
Audit
Audit & Certification© Fraunhofer | Mario Hoffmann | 07.10.2015
Problem Statement
Problem of traditional approaches of certificates
Between audits the certified Cloud service has changed already
Violation of requirements of a certificate can occur without recognising
Years
0
1
2
Audit
Audit
?
?
Audit & CertificationProblem Statement
Automatic and continuous evaluation of the requirements
Automatic comparison of high-level requirements of a certificate with information about the Cloud service (e.g. behaviour during runtime based on monitoring data)
Years
0
1
2
Audit
Audit
?
?
Audit & Certification© Fraunhofer | Mario Hoffmann | 07.10.2015
Motivation
Certification
• Multi-year validity periods may put in doubt the reliability of certifications • Many widespread certificates already
existed before Cloud
More tailored certificates needed • Important: Transparency and
trustworthiness
Cloud Computing
• Cloud service certifications attempt to assure a high level of security and compliance.
• Cloud services are part of an ever-changing environment
• Challenge: Security, data privacy, service level objectives and legal compliance (e.g. commissioned data processing)
Research goal: Continuous auditing of selected certification criteria assure
continuously reliable and secure cloud services and thereby increase the trustworthiness of certifications.
The big picture
Le
gal
Imp
lica
tion
s
Certificates &
Catalogues of CriteriaCloud Ecosystems
Status information Complex EventProcessing Data and process model
Machine Learning
& Data Mining Monitoring & Testing Tools
Criteria, derived from technical information needs to be validated automatically and on-demand
Aggregation and interpretation of Cloud sensor data
© Fraunhofer | Mario Hoffmann | 07.10.2015
<Excursion>
Legal Implications
The Court of Justice declares that
the Commission’s US Safe
Harbour Decision is invalid
http://curia.europa.eu/jcms/upload/docs/application/pdf/2015-10/cp150117en.pdf
© Fraunhofer | Mario Hoffmann | 07.10.2015
Legal implications (1/3)
•
According to German data protection law the usage of Cloud Computing
services is about commissioned data processing
•
German Data Protection Act regulates the monitoring obligation of the Cloud
user concerning technical and organisational measures of the Cloud provider
Cloud-Provider
Contractor Cloud-User
Legal implications (2/3)
Challenge
• Personal on-site control
• Cloud users show a common lack of expert knowledge • Where data is stored is ambiguous
• Disproportional effort necessary
• “Validation Tourism“ is not practical for both sides
Approach
• Utilisation of external expertise possible but static
certification does not fully fulfil legal compliance
• Dynamic certification?
© Fraunhofer | Mario Hoffmann | 07.10.2015
Legal implications (3/3)
Research questions from a legal perspective:
• Who certifies?
• Private or public institution?
• Legitimation? Reputation? Acceptance?
• How are the testing criteria defined and specified? • Are they up-to-date?
• Who supervises the certification authority?
• What kind of legal impact has the grant/denial of such a certificate?
Fields of law concerned:
• Constitutional law, constitutional process law, European law, data protection law,
administrative law, administrative procedural law, civil law, civil process law, competition law, criminal law etc.
</Excursion>
© Fraunhofer | Mario Hoffmann | 07.10.2015
NGCert – Next Generation Certification
nationally funded project 10/2014-09/2017 http://www.ngcert.de/download/papers/
Hypotheses:
• It is possible to evaluate critical requirements of a certificate automatically. • A completely automaticcertification for dedicated test steps (only) is possible. • Automatic test steps can
help to prove fulfiling requirements regarding quality, data protection, and data security ensuring legal compliance.
Technical requirements but not automatically verifiable Certificate requirements (checklist) Σ Checklists (requirements of all certificates) Automatically verifiable technical requirements
Analyse & Validate (e.g. CEP) Results & Reports
(e.g. dashboard)
Metric 1 (with threshold)
... Metric N
NGCert – Summary
•
Design principles
for developing dynamic certifications
•
Appropriate metrics
and (new) methods for assuring requirements such
as security, privacy, and compliance to …
•
Match monitoring results
as appropriate evidence for common
compliance controls in the area of security, data privacy, service level
objectives and legal compliance
•
Certification framework and tool chain
for continuous (semi-)automated
© Fraunhofer | Mario Hoffmann | 07.10.2015
Contact
Fraunhofer AISEC Parkring 4
85748 Garching (near Munich) Germany
Service & Application Security – SAS Mario Hoffmann Head of department Tel: +49-(0)89 322 9986 -177 Fax: +49-(0)89 322 9986 -299 eMail: [email protected] Web: http://www.aisec.fraunhofer.de