SOC 2 Reports – A Third Party Risk Management Tool for Cloud Providers August 2014

Agenda Overview of Cloud Computing Importance of Third Party Risk Management SOC Reports – A Method of Third Party Risk Management Alignment of Cloud Security Alliance (CSA) Cloud Control Matrix (CCM) and SOC 2 Trust Services Principles (TSP) Summary and Conclusion Q&A

What is Cloud Computing Cloud computing is a model for enabling convenient, on-demand network access to a shared pool of configurable computing resources. Networks, servers, storage, applications, and services that can be rapidly provisioned and released with minimal management effort or service provider interaction. This cloud model promotes availability and is composed of five essential characteristics, three service models, and four deployment models.

What is Cloud Computing

Opportunities Cost savings – Customers pay for only the computing resources used. There are no physical space requirements or utility costs. All dollars are expensed (that is, receive a U.S. tax benefit). Speed of deployment – The time to fulfill requests for computing power and applications can change from months to weeks, weeks to days, and days to hours. Scalability and better alignment of technology resources – Companies can scale up or down their capacity without capital expenditures. Decreased effort in managing technology – Cloud computing provides the organization more time to focus on core purpose and goals; more consistent technology upgrades; and expedited fulfillment of IT resource requests. Environmental benefits – Significant adoption of cloud computing should yield less overall power consumption, carbon emissions, and physical land use.

Risks Some of the typical risks associated with cloud computing are: Disruptive force Residing in the same risk ecosystem as the cloud service provider (CSP) and other tenants of the cloud Lack of transparency Reliability and performance issues Vendor lock-in and lack of application portability and interoperability Security and compliance concerns Creation of high-value cyber-attack targets Risk of data leakage IT organizational changes Viability of the CSP

Changes in the Operating Environment With Cloud Computing Risks and other cloud computing effects should be incorporated in ERM programs. Organizations can engage cloud computing solutions while bypassing normal management oversight controls. Cloud computing solutions are: a) easily adopted within a short period of time, b) require a small monetary investment, and c) involve very few personnel.

Shared Control Environment

Risk Levels – Shared Control Environment

Shared Control Environment Risk Profile Impact of CSPs and fellow cloud tenants Using cloud computing converts an organization’s internal environment into a combination of its own internal environment and the internal environment of the contracted CSP. Why Both? Data and processes are hosted in a shared environment with other cloud tenants. Behavior and events of the CSP and fellow tenants could have a direct impact on the organization.

Cloud Governance Cloud governance” refers to the controls and processes in place for cloud planning and strategy, vendor selection, contract negotiation, implementation, operation, monitoring and possible termination and transition of cloud services.

Investing in Third Party Risk Management – Disruption of Service

Investing in Third Party Risk Management – Data Breach “On average, third party errors increased the cost of data breach by as much as $43 per record in the US” Source: “2013 Cost of Data Breach Study: Global Analysis”, Sponsored by Symantec, May 2013, Ponemon Institute

Third-Party Risk Management Concerns Source: "Closing the Gaps in Third-Party Risk Management, Defining a Larger Role for Internal Audit,” December 2013, Sponsored by Crowe Horwath LLP

Third Party Risk Management Activities Vendor management activities performed should be based on risk associated with the vendor In order to ensure the risks with outsourcing cloud services are properly addressed organizations should consider performing the following activities: Review cloud provider’s policies and procedures Request cloud provider respond to internal control questionnaires Perform an onsite review of cloud provider operations Review a Service Organization Control (SOC) Report Organizations can use SOC reports to obtain a level of comfort over a cloud provider’s controls related to security, availability, processing integrity, confidentiality and privacy controls. The CSA issued a position paper in February 2013 stating that a SOC 2 Type 2 report should meet the vendor management needs of cloud users. (https://cloudsecurityalliance.org/download/csa-position-paper-on-aicpa-service-organization-control-reports/)

Service Organization Controls (SOC) Reports – Overview AICPA created separate reports on internal controls over financial reporting and reports on other types of controls. The AICPA has added additional reporting options. The three reporting options now are: SOC 1 SOC 2 SOC 3

Internal controls related to financial reporting Types of SOC Reports SOC 1 Internal controls related to financial reporting SOC 2 Trust Services Principles Restricted Use Report SOC 3 Trust Services Principles General use report SSAE 16/ AT 801 AT 101

Who May Need to Issue a SOC 2 Report? Organizations that need to demonstrate how they process transactions and/or data on behalf of their customers Organizations that need to demonstrate how their security controls operate Organizations that need to demonstrate how their controls related to system availability function Organizations that need to demonstrate how their controls related to data privacy or confidentiality operate A Cloud Service Provider Fits These Characteristics!

Trust Services Principles Security – The system is protected against unauthorized access (both physical and logical). Availability – The system is available for operation and use as committed or agreed to. Processing Integrity – System processing is complete, accurate, timely, and authorized. Confidentiality – Information designated as confidential is protected as committed or agreed to. Privacy – Personal information is collected, used, retained, disclosed, and destroyed in conformity with the commitments in the entity’s privacy notice and with criteria set forth in generally accepted privacy principles (GAPP) issued by the AICPA and the Canadian Institute of Chartered Accountants (CICA).

Relationship Between Principles, Criteria and Controls

Example Criteria and Illustrative Controls Security Principle - Criteria 3.3 Procedures exist to restrict physical access to the defined system including, but not limited to, facilities, backup media, and other system components such as firewalls, routers, and servers. Illustrative Controls: Physical access to the computer rooms, which house the entity's IT resources, servers, and related hardware such as firewalls and routers, is restricted to authorized individuals by card key systems and monitored by video surveillance. Physical access cards are managed by building security staff. Access card usage is logged. Logs are maintained and reviewed by building security staff. Requests for physical access privileges to the entity's computer facilities require the approval of the manager of computer operations. Documented procedures exist for the identification and escalation of potential physical security breaches. Offsite media are stored in locked containers in secured facilities. Physical access to these containers is restricted to facilities personnel and employees authorized by the manager of computer operations.

Example Criteria and Illustrative Controls Security Principle - Criteria 3.4 Procedures exist to protect against unauthorized access to system resources. Illustrative Controls: Login sessions are terminated after three unsuccessful login attempts. Virtual private networking (VPN) software is used to permit remote access by authorized users. Users are authenticated by the VPN server through specific "client" software and user ID and passwords. Firewalls are used and configured to prevent unauthorized access. Firewall events are logged and reviewed daily by the security administrator. Unneeded network services (for example, telnet, ftp, and http) are deactivated on the entity's servers. A listing of the required and authorized services is maintained by the IT department. This list is reviewed by entity management on a routine basis for its appropriateness for the current operating conditions. Intrusion detection systems are used to provide continuous monitoring of the entity's network and early identification of potential security breaches. The entity contracts with third parties to conduct periodic security reviews and vulnerability assessments. Results and recommendations for improvement are reported to management.

Service Auditor’s Opinion SOC Report Sections SOC 2 Report Sections Service Auditor’s Opinion Management’s Assertion Description of Systems Test Results Complementary Controls Other Information

Cloud Control Matrix (CCM) Developed by the Cloud Security Alliance (CSA) Establishes a controls framework for cloud providers to follow Based on industry accepted control frameworks such as ISO 27001/27002, ISACA COBIT and NIST Provides guidance in the following domains: Application and Interface Security Audit Assurance and Compliance Business Continuity Management & Operational Resilience Change Control & Configuration Management Data Security & Information Lifecycle Management Datacenter Security Encryption and Key Management Governance and Risk Management Human Resources Identify and Access Management Infrastructure & Virtualization Security Interoperability & Portability Mobile Security Security Incident Management, E-Discovery & Cloud Forensics Supply Chain Management, Transparency and Accountability Threat and Vulnerability Management

CCM Controls Map to SOC 2 Criteria CCM - Change Control and Configuration Management Control Specification: Policies and procedures shall be established, and supporting business processes and technical measures implemented, to ensure the development and/or acquisition of new data, physical or virtual applications, infrastructure network and systems components, or any corporate, operations and/or datacenter facilities have been pre-authorized by the organization's business leadership or other accountable business role or function. SOC 2 TSP Criteria: (S3.10.0) Design, acquisition, implementation, configuration, modification, and management of infrastructure and software are consistent with defined system security policies. (S3.12.0) Procedures exist to maintain system components, including configurations consistent with the defined system security policies. (S3.13.0) Procedures exist to provide that only authorized, tested, and documented changes are made to the system.

CCM Controls Map to SOC 2 Criteria CCM – Datacenter Security Control Specification: Physical access to information assets and functions by users and support personnel shall be restricted. SOC 2 TSP Criteria: (S3.4.0) Procedures exist to restrict physical access to the defined system including, but not limited to, facilities, backup media, and other system components such as firewalls, routers, and servers.

SOC Report Review Organizations should obtain and formally review SOC reports. The review should focus on the following: Report Type Type 1 or Type 2 Areas of Coverage/Scope Opinion Unqualified or Qualified Subservice Organizations Description of Systems Content Test Results/Impact of Exceptions Noted Evaluation of User Control Considerations More emphasize on this component

Summary and Conclusion Cloud computing services affect TPRM activities SOC reports one component of TPRM activities

Questions

For more information, contact: Jeff Palgon Direct 404.442.1623 Jeff.Palgon@crowehorwath.com