Cloud Security is the Customer's Responsibility
Insurance Experts' Forum, October 15, 2012
When it comes to cloud computing, and data center management in general, F5's Lori MacVittie is the probably one of the most knowledgeable people around. So a post with the title “If Security in the Cloud Were Handled Like Car Accidents” really ought to resonate with insurance executives seeking to understand the do's and don'ts of security in their cloud projects.
MacVittie posted this advisory last year, but now more than ever, it hits home. MacVittie urges executives to look at the scenarios for ultimate responsibility in car accidents—a couple of definitions that P&C insurance executives probably know by heart.
• “Contributory negligence is a system of fault in which the injured party can only obtain compensation for injuries and damages if he or she did not contribute to the accident in any way.”
• “In comparative negligence, the injured party can recover damages even if she was partially at fault in causing the accident. In a pure comparative system, the plaintiff’s award is reduced by the amount of her fault in the accident. Some states have what is called modified comparative fault. This is where there is a cap on how much responsibility the injured party can have in the accident.”
The same definitions and onus of responsibility can be applied to security incidents in the cloud. “For example, a customer has no control over the network and management framework of an IaaS provider,” MacVittie illustrates. “The customer has no authority to modify, change or configure network infrastructure to ensure an agreeable level of network-security suitable for public-facing applications. Only the provider has the means by which such assurances can be made through policy enforcement and critical evaluation of traffic. If data security in a cloud computing environment is breached through the exploitation or manipulation of infrastructure and management components wholly under the control of the provider, then the fault for the breach falls solely on the shoulders of the provider.”
However, MacVittie continues, if a breach “is enabled by poor coding practices or configuration of application infrastructure which is wholly under the control of the customer, then the customer bears the burden of fault and not the provider.”
Often, she points out, cloud customers—who usually can neither change, modify nor otherwise impact the security of a network switch—should not be responsible for its security. Conversely, the cloud provider cannot be held responsible for bearing the burden of responsibility for securing an application that the provider had no input or control over.
Ultimately, both cloud consumers and providers need to share responsibility for security, MacVittie points out. But if you are a customer, and you turn over responsibility to a cloud provider, you still bear ultimate responsibility to understand how the provider handles security: “Ultimately, the data is yours; it is your responsibility to see it secured and the risk of a breach is wholly yours. If you choose to delegate—implicitly or explicitly—portions of the security responsibility to an external party, like the driver of a car service, then you are accepting that the third party has taken acceptable reasonable precautions.”
If the third party has not taken reasonable precautions, then it is the customer’s responsibility to find a provider that does.
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