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When it comes to auditors and your organization’s use of cloud services, there is no “if,” only “when.” If you have not explored what cloud services your people are using, or where your business data are kept in the cloud, you will lose points on your next audit. Or you may fail.
Two years ago when we launched Netskope, CIOs told us “We’re not in the cloud,” and auditors told us “The cloud is not part of our audit.” Today, one-third of our business pipeline is made up of inbound requests and there is a steady stream of cloud access security broker (CASB)-specific RFPs. Many of those are driven by failed (or near-failed) security audits.
What are auditors asking about your cloud security regimen? In other words, what answers do you need to have in your back pocket? Here are five.
- Do you maintain an inventory of cloud services? Where is it and how often is it updated? The average number is 755 per enterprise at last count, and only about one-tenth are known to IT. Getting (and maintaining) this list is critical and foundational to anything else you do.
- Do you have a cloud service vendor assurance process that includes criteria like data center and software certifications as well as inherent audit capabilities, authentication support, and cloud data security? Does the entire organization adhere to it? Clearly articulating what you will and won’t accept in your organization, and further specifying what compensating controls need to be in place when a cloud service falls short, will go a long way. Besides articulating your process and criteria, think about how you will demonstrate enterprise-wide adherence, what your process is for violators, and how you will show that process to your auditor. Comprehensive monitoring, process enforcement, and automated user coaching can all be useful tacks here.
- Do your periodic technology risk assessments include cloud services? You should modify it to the idiosyncrasies of the cloud and perform it for cloud services just as regularly. You will be ahead of the game if you do this.
- Do you have defined access controls for services that contain sensitive or regulated data? Some of your cloud services contain data that can only be accessed by a handful of authorized individuals. Proving that, and reporting on incidents and your response will be as critical for the cloud as it is for on-premises systems. Think about what this means for cloud-based financial apps beholden to Sarbanes-Oxley, HR apps containing personally-identifiable information, and file-sharing apps containing M&A priorities.
- Do you monitor user activity in cloud services that contain sensitive or regulated data? Just as important as monitoring and reporting on unauthorized access is keeping an audit trail of user activities like “share,” “edit,” “download,” and “delete” in cloud services. This way you can deterministically say whether an individual has stolen or exposed data, and report on the incident and your response in a thorough manner.
We’ve now seen this movie enough times that we can say audits that involve cloud are no longer a question of “if” than “when.” Want to have the right answers in your back pocket when the time comes? Consider these five questions your cheat sheet.
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