Compliance is one of the biggest considerations for organisations these days. And rightly so. Without the strictest standards of regulation in place, end-users and customers are left wide open to the potentially catastrophic impact of an organisation’s non-compliance. More than that, the organisation itself faces severe consequences if it fails to meet its compliance obligations, whether that is through incomplete in-house processes or the external threat of network breaches. Any failure to meet these obligations can see an organisation facing such repercussions as regulatory fines, lawsuits, cybersecurity incidents and substantial reputational damage.
There was a time when keeping data and details safe was a straightforward matter of taking stringent on-premise measures – implementing encryption software and ensuring secure storage of data and files. But with the advent and mass-adoption of cloud services, compliance has become an altogether more scattered undertaking. And it remains just as important to get it right. So whether your organisation has embraced the Cloud fully with Software- or Infrastructure as a Service, or is just beginning to dip its toe into the pool of collaboration tools, it’s vital to ensure all your compliance boxes are being ticked and that all the relevant standards are being met to ensure end-user safety.
To do this, you need to recognise the sheer scale and reach of the Cloud. It is everywhere. It’s behind so many of the things we do and so many of the applications we use on a daily basis without even thinking about it. The proliferation of collaboration and file-sharing applications like Microsoft Teams and Dropbox might seem like small fry, but they are cloud-based solutions that test and challenge your organisation’s data and security procedures, whether you’ve considered that or not.
The Cloud services underpinning your operations will help determine how far you, as an organisation, need to consider cloud compliance. As a starter, data transfer, storage, backup and access will all necessitate cloud compliance, whether you’re using them as standard or dipping in and out on an ad hoc basis.
While compliance was once the remit of IT teams alone, these days it needs to be a discussion that happens with other departments across your organisation. Cloud compliance concerns internal processes and procedures and decision-making needs to be done with consideration for monitoring and audits, governance, security, data protection, risk management and legal. Compliance is no longer a straightforward job of making sure data is stored on an encrypted hard drive or hidden behind layers of passwords – rather, it’s an organisational consideration.
Cloud compliance and security
Compliance and security are among the biggest reasons given for some organisations hesitating to adopt cloud solutions. And it’s almost impossible to not talk about security when addressing compliance requirements, because the systems necessary to achieve compliance are often implemented as ‘security’ measures. But are concerns about security and compliance in relation to cloud services justified? Arguably not.
As with everything ‘security’, it’s about understanding the risks and attempting to mitigate them, whether you’re talking about on-premise infrastructure or software hosted in the Cloud. In that respect, it’s your internal processes and reporting procedures, as well as how they work for and alongside your cloud services, that ensure your organisation is operating securely and compliantly. No matter what type of business you are in, whether you are manufacturing goods or providing a service, the more you standardise operations, the more efficient you become.
That holds true for cloud compliance too. As you move functions to the Cloud, get into the habit of spinning up the operational security and compliance functions that go along with them, each and every time. The more these compliance operations can be consistent, the easier it will be to enforce security and respond to audit requests.
Get your internal systems in place, and even the most closed-down business, operating in the most regulated of industries, can compete and remain compliant in an ever-changing regulatory environment.
Cloud service provider responsibilities
Cloud compliance ensures that cloud service providers meet the compliance requirements of their customers. To some extent. They will necessarily have in place the appropriate policies and procedures surrounding data transfer, storage, backup, retrieval and access, but customers shouldn’t assume that all cloud services providers will meet the same standards. And they certainly shouldn’t expect the service provider to meet very specific or unique requirements.
In fact many cloud providers, including AWS and Microsoft Azure, make a point of the fact that cloud compliance is a dual responsibility, shared by the provider and the customer. Because while the Cloud providers have certain contractual obligations to their customers, it is on the customers themselves to look after their own best interests. If something should go wrong, you’re not going to get very far by using ‘outsourcing’ as a defence. At the very least, this means doing due diligence when choosing your cloud services provider, and then ensuring the level of compliance offered by each service is aligned with your company’s own requirements.
Data compliance as shared responsibility
It used to be so straightforward: data lived in the data centre, and the IT team kept it safe. These days, with the proliferation of mobile devices and BYOD working practices, critical corporate information is sitting in more places than ever. Couple that with the increased use of cloud-based applications and services, and getting a single, holistic view of your data – never mind ensuring you are meeting regulatory requirements in all spheres – is more challenging than ever.
Many organisations make the mistake of assuming that once data is sent to the Cloud, all security and compliance responsibility for the data shifts to the cloud provider. This is not true.
As soon as an organisation begins sending data to the Cloud, responsibility for the security and compliance of that data becomes a shared responsibility.
As a general rule, think about responsibility for security and compliance falling as follows:
- Customers: Responsible for security and compliance in the cloud application
- SaaS providers: Responsible for security and compliance in the Cloud
- Cloud service providers: Responsible for security and compliance of the Cloud
And unless your organisation has bought into services in the upper echelons of the ‘cloud stack’, you will retain responsibility for implementing and using any and all security and compliance features and ensuring your on-premise policies and procedures extend to the cloud.
Compliance elements to consider
While looking to expand any part of your network to the Cloud, it will serve you well to get the answers to the following compliance-related questions:
- Access controls: Data security is central to compliance, so you’ll need to know exactly who has access to what, including those within your company and those (including third-party contractors) working for your cloud service provider.
- Asset management: The Cloud service provider will be responsible for managing its own infrastructure assets, and you will remain responsible for managing your company’s assets, including hosted operating systems and applications.
- You’ll want to understand which third parties are responsible for auditing cloud compliance, as well as finding out if your company will be entitled to audit cloud compliance.
- Compliance reports. What’s the scope of your cloud provider’s reports? Are you able to access them when you need to?
- Configuration management: Who bears the responsibility for any misconfigurations?
- Data encryption: Compliance generally relies on data being encrypted whether at rest or in motion and you’ll probably need to do it on-premise as well as in the Cloud.
- Data location: Will you know where your data is located? Auditors might ask for that information, but not all cloud service providers share it.
- Data protection. To what degree will your chosen cloud provider protect your information? Do you need to take further steps to ensure an adequate level of protection?
- Data storage: What will and what won’t be stored in the Cloud, and why?
- Disaster recovery. What laws and regulations are your company bound by in the event of an outage? Does your cloud service provider cover you?
- Due diligence. Do you understand how this will be handled?
- E-discovery capabilities. If your company finds itself facing a lawsuit, will you be able to gain fast access to all the required data?
- Insurers: Many insurance firms who offer business interruption or data loss insurance will want to understand the potential risks and the scale of them before proceeding , cloud and geolocation can often factor into the decision making process
- Security requirements. What types of security does your company require from a cloud services
- provider? For compliance purposes, you need to understand what level of security you are bound by.
- Shared or private resources. Depending on your company’s specific requirements, you may require a private data centre suite in your cloud service provider’s data centre.
- The laws and regulations governing your business may involve a service level agreement. Before you commit to anything, be sure this doesn’t limit the types of service you can use.
Partner with a specialist firm
There’s no denying there’s a lot to think about when it comes to ensuring you remain compliant while making the most of the many benefits of cloud computing. It might well be that, for your organisation, partnering with a specialist compliance firm makes sense. For example, our own partnership with global cyber security specialists MetaCompliance has ensured M247 is meeting the strictest international standards of information security, at every level of our business. Their specialist knowledge and software has enabled us to strengthen our culture of compliance through refined processes, policies and reporting procedures, as well as ensuring our teams are trained in and aware of relevant, ever-evolving cyber security issues.
But whether you opt for due diligence, or decide to enlist the support of a specialist partner, getting your compliance and regulatory boxes ticked is essential for ensuring the greatest level of protection for your organisation, as well as your customers.
To find out more about our services, contact one of our team today.