By Philip Pearson, Field Chief Information Security Officer, Aqua Security
As financial institutions move to operate in the cloud, they must ensure that security, governance, and compliance are carefully managed and aligned with a systematic approach. By adhering to compliance standards, financial organisations can identify and mitigate potential security risks, protect against data breaches, and ensure business continuity. But beyond these risks, it is about building trust with customers, protecting brand reputation, and retaining a competitive edge.
There are several key compliance standards and regulations that financial organisations operating in the cloud need to be aware of with the sector facing increased regulatory scrutiny over the past several years. Some of the most important standards include Payment Card Industry Data Security Standard (PCI-DSS), ISO 27001, and NIST. If we take the example of ISO 27001, those cloud services providers who are ISO 27001 certified have proven that they have secure systems in place to protect data integrity, confidentiality, and availability. And organisations utilising cloud services must warrant their chosen providers to meet these standards to help maintain overall data security.
Regulatory landscapes are evolving fast, marked by stringent requirements from the FCA, PRA, and the EU’s MiFID II and DORA, among others. The Digital Operational Resilience Act (DORA) and the NIS2 Directive are two major pieces of European cybersecurity legislation. Active since January last year the NIS2 Directive aims to improve the level of cybersecurity protection across the EU, with an emphasis on harmonising security requirements and reporting obligations. It is encouraging member states to integrate new areas, such as supply chain security, vulnerability management, and cyber hygiene, into their national cybersecurity strategies.
To get the most out of cloud compliance financial organisations must follow a systematic approach. Here are the eight key steps to achieve cloud compliance.
- Develop a shared responsibility model
The first step towards achieving cloud compliance is to implement a shared responsibility model, Both the cloud service provider and the customer hold some level of responsibility concerning security and compliance. However, the degree of responsibility varies depending on the cloud service model—Infrastructure as a Service (IaaS), Platform as a Service (PaaS), or Software as a Service (SaaS).
As a general rule, the cloud service provider (CSP) is responsible for the security and compliance of the underlying cloud infrastructure, including physical servers, networks, and databases. However, the customer is responsible for everything they put in the cloud. This encompasses the security and compliance of their data, the configuration of cloud-based applications, and the management of user access and permissions. By implementing a shared responsibility model, both the CSP and the customer can clearly delineate their respective roles in maintaining a secure and compliant cloud environment, minimising the risk of oversights or gaps in security.
2. Implement a well-defined governance framework
Governance in the context of cloud compliance refers to the mechanisms, processes, and policies that control and monitor the cloud environment. A well-defined governance framework provides a structured approach to managing cloud operations in line with regulatory requirements, industry standards, and organisational policies. This is particularly important given the challenges of managing compliance requirements across multiple regions, with different requirements for different areas.
The key components of a cloud governance framework include risk management, policy management, and change management.
- Risk Management: Identify, assess, and mitigate risks associated with cloud operations. For example, conducting regular risk assessments using frameworks like ISO 31000 can help pinpoint vulnerabilities.
- Policy Management: Create, implement, and enforce policies that regulate cloud activities. Utilise tools such as AWS Organisations or Azure Policy to manage and enforce policies across your cloud environment.
- Change Management: Manage changes to the cloud environment to prevent disruptions and maintain compliance. Implementing a structured change management process, as outlined in ITIL, can help ensure all changes are reviewed and approved before implementation.
By incorporating these components, organisations can build a governance framework that not only ensures compliance but also enhances overall cloud security and operational efficiency.
3. Create a measurable cloud compliance strategy
A cloud compliance strategy outlines the measures and actions required to ensure and maintain compliance in the cloud environment.
A well-designed compliance strategy should clearly define the compliance objectives, identify relevant compliance regulations and standards, assign compliance roles and responsibilities, and delineate the compliance processes and procedures. It should also include a plan to monitor and measure compliance performance and address non-compliance issues.
4. Choose tech to automate and control compliance
Achieving cloud compliance requires the deployment of various tools and controls. These technologies help automate compliance tasks, detect compliance violations, and facilitate compliance reporting.
Compliance tools typically include security information and event management (SIEM) systems, compliance management software, and data protection tools. These tools help track and manage compliance tasks, generate compliance reports, and flag potential compliance issues.
Compliance controls are mechanisms put in place to control and regulate activities in the cloud environment. These controls may be technical, such as firewalls and encryption, or administrative, such as user access controls and audit trails.
5. Prioritise auditing and reporting
Regular auditing and reporting is a critical step toward achieving cloud compliance. Audits help verify that the cloud environment adheres to the defined compliance standards and regulations. They also help identify potential compliance issues and areas for improvement.
Reporting, on the other hand, involves documenting and communicating the audit findings to relevant stakeholders. Compliance reports provide insights into the compliance status and performance, thereby aiding decision-making and strategic planning.
6.Create comprehensive evidence mechanisms
It is essential to maintain comprehensive evidence of compliance efforts and activities. Policy documents, procedure manuals, audit reports, incident reports, and compliance certificates.
Documentation not only helps demonstrate compliance to auditors and regulators but also aids in knowledge sharing and continuity. It ensures that all stakeholders, including employees, management, and auditors, have a clear understanding of the compliance requirements and practices.
7. Implement advanced threat detection
Financial institutions face sophisticated threats, so if they’re to keep the data they manage safe, it’s vital that they implement advanced, real-time threat detection solutions with incident response capabilities.
This will not only enable them to meet complicated legal frameworks like GDPR, it will also reduce the risk of reputational damage and financial loss that can come from a cyber attack.
8. Implement continuous monitoring
Finally, achieving cloud compliance is not a one-time task. It requires continuous monitoring and updating of compliance measures. This ongoing process ensures that the cloud environment remains compliant amidst the ever-evolving regulatory landscape and technological advancements.
Monitoring involves regularly checking the compliance status and performance, while updating involves revising and improving the compliance measures based on monitoring results and changes in regulations, standards, and business needs.