Rational Survivability

* Update:  A few hours after writing this last night, AWS announced they had achieved Level 1 PCI DSS Compliance.* If you pay attention to how the announcement is worded, you’ll find a reasonable treatment of what PCI compliance means to an IaaS cloud provider – it’s actually the first time I’ve seen this honestly described:

Merchants and other service providers can now run their applications on AWS PCI-compliant technology infrastructure to store, process and transmit credit card information in the cloud. Customers can use AWS cloud infrastructure, which has been validated at the highest level (Level 1) of PCI compliance, to build their cardholder environment and achieve PCI certification for their applications.

Note how they phrased this, then read my original post below.

However, pay no attention to the fact that they chose to make this announcement on Pearl Harbor Day 😉

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Here’s the thing…

A cloud provider can achieve compliance (such as PCI — yes v2.0 even) such that the in-scope elements of that provider which are audited and assessed can ultimately contribute to the compliance of a customer operating atop that environment.  We’ve seen a number of providers assert compliance across many fronts, but they marketed their way into a yellow card by over-reaching…

It should be clear already, but for a service to be considered compliant, it clearly means that the customer’s in-scope elements running atop a cloud provider must also undergo and achieve compliance.

That means compliance is elementally additive the same way “security” is when someone else has direct operational control over elements in the stack you don’t.

In the case of an IaaS cloud provider who may achieve compliance from the “concrete to the hypervisor,” (let’s use PCI again,) the customer in turn must have the contents of the virtual machine (OS, Applications, operations, controls, etc.) independently assessed and meet PCI compliance in order that the entire stack of in-scope elements can be described as compliant.

Thus security — and more specifically compliance — in IaaS (and PaaS) is a shared responsibility.

I’ve spent many a blog battling marketing dragons from cloud providers that assert or imply that by only using said provider’s network which has undergone and passed one or more audits against a compliance framework, that any of its customers magically inherit certification by default. I trust this is recognized as completely false.

As compliance frameworks catch up to the unique use-cases that multi-tenancy and technologies such as virtualization bring, we’ll see more “compliant cloud” offerings spring up, easing customer pain related to the underlying moving parts.  This is, for example, what FedRAMP is aiming to provide with “pre-approved” cloud offerings.  We’ve got visibility and transparency issues to solve , as well as temporal issues such as the frequency and period of compliance audits, but there’s progress.

We’re going to see more and more of this as infrastructure- and platform-as-a-service vendors look to mutually accelerate compliance to achieve that which software-as-a-service can more organically deliver as a function of stack control.

/Hoff

* Note: It’s still a little unclear to me how some of the PCI requirements are met in an environment like an IaaS Cloud provider where “applications” that we typically think of that traffic in PCI in-scope data don’t exist (but the infrastructure does,) but I would assume that AWS leverages other certifications such as SAS and ISO as a cumulative to petition the QSA for consideration during certification.  I’ll ask this question of AWS and see what I get back.

Related articles

• Navigating PCI DSS (2.0) – Related to Virtualization/Cloud, May the Schwartz Be With You! (rationalsurvivability.com)
• Seeing Through The Clouds: Understanding the Options and Issues (thesecuritysamurai.com)
• I’ll Say It Again: Security Is NOT the Biggest Barrier To Cloud… (rationalsurvivability.com)
• PCI 2.0 Allows For Compliant Clouds, Make Sure Your Service Providers Are PCI Compliant (securecloudreview.com)
• What’s The Problem With Cloud Security? There’s Too Much Of It… (rationalsurvivability.com)
• FedRAMP. My First Impression? We’re Gonna Need A Bigger Boat… (rationalsurvivability.com)
• Mixed Mode and PCI DSS 2.0 (brandenwilliams.com)
• The Future Of Audit & Compliance Is…Facebook? (rationalsurvivability.com)
• Incomplete Thought: Compliance – The Autotune Of The Security Industry (rationalsurvivability.com)

You’ll forgive my impertinence, but the last time I saw a similar claim of a PCI compliant Cloud offering, it turned out rather anti-climatically for RackSpace/Mosso, so I just want to make sure I understand what is really being said.  I may be mixing things up in asking my questions, so hopefully someone can shed some light.

This press release announces that:

“…Verizon’s On-Demand Cloud Computing Solution First to Achieve PCI Compliance” and the company’s cloud computing solution called Computing as a Service (CaaS) which is “…delivered from Verizon cloud centers in the U.S. and Europe, is the first cloud-based solution to successfully complete the Payment Card Industry Data Security Standard (PCI DSS) audit for storing, processing and transmitting credit card information.”

It’s unclear to me (at least) what’s considered in scope and what level/type of PCI certification we’re talking about here since it doesn’t appear that the underlying offering itself is merchant or transactional in nature, but rather Verizon is operating as a service provider that stores, processes, and transmits cardholder data on behalf of another entity.

Here’s what the article says about what Verizon undertook for DSS validation:

To become PCI DSS-validated, Verizon CaaS underwent a comprehensive third-party examination of its policies, procedures and technical systems, as well as an on-site assessment and systemwide vulnerability scan.

I’m interested in the underlying mechanicals of the CaaS offering.  Specifically, it would appear that the platform – compute, network, and storage — are virtualized.  What is unclear is if the [physical] resources allocated to a customer are dedicated or shared (multi-tenant,) regardless of virtualization.

According to this article in The Register (dated 2009,) the infrastructure is composed like this:

The CaaS offering from Verizon takes x64 server from Hewlett-Packard and slaps VMware’s ESX Server hypervisor and Red Hat Enterprise Linux instances atop it, allowing customers to set up and manage virtualized RHEL partitions and their applications. Based on the customer portal screen shots, the CaaS service also supports Microsoft’s Windows Server 2003 operating system.

Some details emerge from the Verizon website that describes the environment more:

Every virtual farm comes securely bundled with a virtual load balancer, a virtual firewall, and defined network space. Once the farm is designed, built, and named – all in a matter of minutes through the CaaS Customer Management Portal – you can then choose whether you want to manage the servers in-house or have us manage them for you.

If the customer chooses to manage the “servers…in-house (sic)” is the customer’s network, staff and practices now in-scope as part of Verizon’s CaaS validation? Where does the line start/stop?

I’m very interested in the virtual load balancer (Zeus ZXTM perhaps?) and the virtual firewall (vShield? Altor? Reflex? VMsafe-API enabled Virtual Appliance?)  What about other controls (preventitive or detective such as IDS, IPS, AV, etc.)

The reason for my interest is how, if these resources are indeed shared, they are partitioned/configured and kept isolated especially in light of the fact that:

Customers have the flexibility to connect to their CaaS environment through our global IP backbone or by leveraging the Verizon Private IP network (our Layer 3 MPLS VPN) for secure communication with mission critical and back office systems.

It’s clear that Verizon has no dominion over what’s contained in the VM’s atop the hypervisor, but what about the network to which these virtualized compute resources are connected?

So for me, all this all comes down to scope. I’m trying to figure out what is actually included in this certification, what components in the stack were audited and how.  It’s not clear I’m going to get answers, but I thought I’d ask any way.

Oh, by the way, transparency and auditability would be swell for an environment such as this. How about CloudAudit? We even have a PCI DSS CompliancePack 😉

Question for my QSA peeps: Are service providers required to also adhere to sections like 6.6 (WAF/Binary analysis) of their offerings even if they are not acting as a merchant?

/Hoff

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