The Elephant in the Room:
What’s the Buzz Around
Cloud Computing?
Warren W. Stippich, Jr.
Partner and National Governance, Risk and Compliance Solution Leader Business Advisory Services
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Learning objectives –
Presentation focus
Today’s presentation
will focus
on the following:
•
Understanding primary
outsourced/hosted
cloud computing
options
•
Understanding unique
risks
associated with various cloud
computing models
•
Practical controls
for securing the Company’s assets when
using cloud computing
•
Methods for deciding if cloud computing fulfills the
organization’s business
needs
and
risk appetite
Agenda
•
Introductions
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Introductions
Warren W. Stippich, Jr. – Chicago
• Partner and National Governance, Risk and
Compliance Solution Leader, including Cyber Security Solution, in Grant Thornton's Business Advisory
Services Practice
• Certified Internal Auditor (CIA)
• Certified Public Accountant (CPA IL)
• 20 years practicing internal audit, including 5 years as a CAE for a multi-national public company
Introductions
Matt Thompson – Raleigh, NC
• Senior Manager in Grant Thornton’s Business Advisory Services Practice
• Certified Information Systems Auditor (CISA)
• A member of the Triad (NC) IIA Board of Governors • 15+ years experience working in the Cyber Security
and IT Internal Audit arenas
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Agenda
• Introductions
•
Cloud computing overview
Cloud computing overview
Why the buzz?
Cloud computing is the future of IT
•
A
new
and
flexible
model for deploying
technology
•
Extremely
reliable
and infinitely
scalable
•
Cost
benefits
and
ease
of ownership
•
Allows you to
expand
or
contract
as business needs
dictate
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
• What are you hoping to learn from today’s presentation?
• What is your experience with cloud computing? • How does your company utilize cloud computing? • What level of involvement did your Internal Audit
group have with your Company’s cloud computing implementation?
• Has your company’s cloud environment been audited?
•
More than 300 CAEs surveyed responded that
– 77% are at least somewhat familiar with cloud computing
– 69% use cloud computing; many expect cloud computing
use to increase (45%) or stay the same (55%) in the next 12
months
•
When asked to describe their view as to the security,
governance, risk and controls implications in moving to a cloud
environment, 43% responded "I haven’t really given it much
thought."
Cloud computing overview
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
“ Looking past the current industry hype surrounding all
things Cloud, Forrester believes that
Cloud
computing is a sustainable, long-term IT paradigm
,
and the
successor to previous mainframe,
client/server, and network computing eras
.”
- Forrester Research, Inc.
“The Evolution of Cloud Computing Markets”
Cloud computing overview
“The cloud is about immediacy,
elasticity, and utility economics”
Mark Shuttleworth, Ubuntu & Canonical
“The cloud is water
vapor
”
Larry Ellison,Cloud computing overview
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
“
Cloud computing is the next stage in the Internet's
evolution, providing the means through which everything
— from computing power to computing infrastructure,
applications, business processes to personal
collaboration — can be delivered to you as a service
wherever and whenever you need.
”
Dummies.com
Cloud computing overview
The term “Cloud” originated as a metaphor to depict the
public switched telephone system on network diagrams.
Cloud computing overview
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
• Network enabled
• Abstraction of infrastructure
• Resource democratization
• Services oriented architecture
• Elasticity/Dynamism of resources
• Utility model of consumption and allocation
Cloud computing overview
Cloud computing overview
Economic value
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
#1 Infrastructure
• Data Center •Processor • Memory • Storage
• Virtualized & Dynamic • Redundant/Hardened
Cloud computing overview
Infrastructure #2 Platform • Operating System • Web Servers • Database Servers • Operational Services • Virtualized
Cloud computing overview
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Utility #3 Application • Google Apps • Salesforce • Mobile Me Platform
Cloud computing overview
Cloud computing overview
Types and models
Types of Clouds• Public
- Shared computer
resources provided by an off-site third-party provider
• Private
- Dedicated computer
resources provided by an off-site third party or use of cloud technologies on a private internal network
• Hybrid
Models of Cloud:
•
Software as a Service
(SaaS) - Software applications deliveredover the Internet
•
Platform as a Service
(PaaS) - Full or partial operatingsystem/development environment delivered over the Internet
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Cloud computing overview
Grant Thornton technology model
Grant Thornton Technology Model
•
A
tool
for IT Internal Auditing
•
SaaS
relates to the application and
data management layers.
•
PaaS
relates to the operating
system layer for servers.
Cloud computing overview
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Cloud computing overview
• Software as a Service (SaaS)
– The consumer does not manage or control the underlying cloud infrastructure, network, servers, operating systems, storage, or even individual application capabilities, with the possible exception of limited user-specific application configuration settings.
• Platform as a Service (PaaS)
– Consumer has control over the deployed applications and possibly application hosting environment configurations.
• Infrastructure as a Service (IaaS)
– Consumer has control over operating systems, storage, deployed applications, and possibly select networking components (e.g.,
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Cloud computing overview
•
Interoperability Across Platform Owners
– User to Application or Hardware Resource – Application to Application– Hardware Resource to Hardware Resource
•
Cost Effective and Higher Utilization of Resources
– Dynamic Allocation As Needed– Dynamically De-Provision when Not Needed
•
Speed to Market
– Enable Faster Delivery of Applications & Upgrades
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Cloud computing overview
Agenda
• Introductions
• Cloud computing overview
•
Risks and audit strategies
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
"A
widespread failure
in Amazon.com’s Web services
business affected many Internet sites, highlighting the risks
involved when companies rely on so-called cloud computing.
The problems affected sites including Quora.com,
Reddit.com, GroupMe.com and Scvngr.com, which all posted
messages to their visitors about the issue.
Most of the sites
have been inaccessible for hours
, and others were only
partly operational…"
- NYTimes.com
April 21, 2011
Risks and audit strategies
"A
data breach
at one of the
world's largest providers
of
marketing email services may have enabled unauthorized
people to access the
names and email addresses for
customers
of major financial-services, retailing and other
companies."
- WSJ.com
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
• What are the physical components of the “Clouds”?
– Data Centers – self-hosted, third-party, both, etc.?
– Network circuits and firewalls – who’s managing, who’s watching, etc.? – Disaster preparedness and recoverability – is there a plan, is it tested, etc.? – Who is aware of and managing vendor SLAs and are they adequate?
• Where’s the data and how is it protected?
– In-flight, standing still/at-rest, etc.? – Archives and back-up?
– Unintended uses?
– Data privacy and compliance?
• What is the tone at the top?
– Stakeholder knowledge of attributes and risks – Have internal controls evolved effectively?
– Who is monitoring internal use of public cloud services?
•
When outsourcing parts of their business (including cloud
computing), companies are still responsible for the data, processing
and/or services provided by the outsourcing company (service
organization).
•
As a result, many companies (and their auditors) desire or require
their service organizations to obtain an independent assessment of
their security, availability, processing integrity, confidentiality and
privacy practices
.
Risks and audit strategies
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
• SSAE No. 16, Reporting on Controls at a Service Organization, superseded SAS 70 on June 15, 2011.
• There are several reporting options for service auditors examining controls at service organizations. Financial Reporting Risks Nonfinancial Reporting Risks SOC 1 SOC 2 SOC 3 With testing details "Pass" with a seal display SSAE 16
Risks and audit strategies
Risks and audit strategies
Six additional risk areas
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
1. Security - risks
• The cloud provider’s security policies are not as strong as the Company’s data security
requirements
• Cloud systems which store Company data are not updated or patched when necessary
• Security vulnerability assessments or
penetration tests are not performed to ensure logical and physical security controls are in place
Risks and audit strategies
1. Security – audit strategy
• Determine if the cloud provider meets or exceeds the Company’s security
requirements
• Determine if the cloud provider’s security
posture is based on a security standard (i.e., ISO27001, Cloud Security Alliance, PCI DSS, etc.)
• Determine if the cloud provider has a security assessment performed
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
2. Multi-tenancy – risks
• Company data is not appropriately
segregated on shared hardware resulting in Company data being inappropriately accessed by third parties
• The cloud service provider has not deployed appropriate levels of encryption to ensure data is appropriately segregated both in rest and transit
• The cloud service provider cannot determine the specific location of the Company’s data on its systems
• Company data resides on shared server space which might conflict with regulatory
Risks and audit strategies
2. Multi-tenancy – audit strategy
• Inquire of the cloud service provider’s method used to secure the Company’s data from being accessed by other customers/third parties
• Review the cloud service provider’s SLA to
determine if the SLA addresses security of the Company’s data
• Review independent audit report(s) related to the Cloud provider’s security posture (i.e.,
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
3. Data location – risks
• The Company is not aware of all of the cloud service provider’s physical location(s)
• The Company does not know where their data is physically or virtually stored
• The Cloud service provider moves company data to another location without informing the Company
• Company data is stored in international
Risks and audit strategies
3. Data location – audit strategy
• Inquire of the cloud provider the specific physical and virtual location of the Company’s data
• Work with the Company’s legal group to fully understand the impact and potential risks of the Company’s data residing in a foreign country
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
4. Reliability – risks
• The cloud service provider has quality of
service standards which conflict with business requirements
• During peak system activity times, the cloud service provider experiences system
performance issues that result in the following:
- Company employees cannot access the Company’s data when needed
- Customers are unable to use the
Risks and audit strategies
4. Reliability – audit strategy
• Inquire of the cloud service provider to determine the controls in place to ensure the reliability of the cloud solution
• Obtain an SLA/contract from the cloud service provider which details the specific reliability agreement for the Company. Compare this information to actual performance
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
5. Sustainability – risks
• In the event the cloud service provider goes out of business, the Company might not be able to
retrieve the Company’s data. In addition,
another third party might gain access/control of the Company’s data
• The cloud service provider does not have appropriate system recovery procedures in place in the event of a disaster
• The Company’s business continuity plan does not address the cloud’s service offering being unavailable
Risks and audit strategies
5. Sustainability – audit strategy
• Inquire of the cloud service provider to determine if they have adequate controls in place to recover and protect the Company’s data even in the event of a disaster
• Review the Company’s business continuity plan and determine if the plan addresses
interruptions with the cloud solution
• Inquire of the cloud service provider to
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
6. Scalability – risks
• The cloud service provider’s systems cannot scale to meet the Company’s anticipated growth, both for a short-term spike and/or to meet a long-term strategy
• If the Company decides to migrate all or part of the Company’s system and/or data back in-house (or to another provider), the cloud
Risks and audit strategies
6. Scalability – audit strategy
• Determine if the cloud provider’s system can scale to meet the Company’s expected short-term
spikes and/or growth over the next five years • Determine if the Company has a contingency
plan in the event the cloud provider’s systems cannot scale to meet the Company’s needs
• Determine who is the “owner” of the Company’s data
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Risks and audit strategies
Case study
• An energy solutions company is a leading provider of energy solutions with annual revenues in excess of $850 million for a payroll size of 400 employees
• Decision made by Senior Management to
outsource their payroll system to a SaaS vendor cloud solution to allow for increased efficiency and cost savings
• Internal Audit identified payroll as a high-risk area since this was the Company’s first use of a cloud computing solution
Risks and audit strategies
Case study (cont'd)
• Company's Internal Audit department reviewed the cloud provider's Service
Organization Report and did not note any exceptions
• Internal Audit also used existing user-ids to perform limited audit procedures and
discovered they had access to view and edit another company's payroll information
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA
Agenda
• Introductions
2011 All Star Conference
October 17 – 19, 2011 / Las Vegas, NV, USA