A Starter Guide to Cloud Compliance

Bhavna B. Sehgal - July 10, 2024

A Starter Guide to <strong>Cloud Compliance</strong>
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What is cloud compliance?

Cloud compliance refers to the process of adhering to regulatory standards, international laws and mandates, and industry best practices (frameworks, benchmarks) in the context of cloud computing. It ensures that cloud services and the data they handle meet specific security, privacy, and operational criteria. Organizations must navigate various compliance requirements — such as MITRE ATT&CK®, CIS, NIST, and ISO — and regulations like the GDPR, FedRAMP, and HIPAA to build and maintain customer trust. Achieving cloud compliance involves implementing robust security measures, regular audits, and continuous monitoring to safeguard against breaches and ensure regulatory alignment.

The compliance landscape is rapidly changing, with new regulations, frameworks, and benchmarks being adopted to address various issues associated with the exponential growth of data collected by organizations. These regulations encompass not only data protection and privacy but areas such as cybersecurity, financial reporting, and environmental standards. Information technology is also evolving as organizations migrate from on-premises data centers to cloud-based infrastructure, presenting new challenges and opportunities in maintaining compliance across diverse operational domains. Consequently, many organizations face uncertainty regarding their compliance obligations and how to define cloud compliance. In most cases, however, the requirements remain consistent whether data is hosted on-premises or in the public cloud. In this post, we will discuss the importance of maintaining compliance, the challenges of cloud compliance, and mechanisms for ensuring best practices.

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Importance of cloud compliance

In today’s digital world, businesses and organizations have access to massive repositories of data, encompassing not only customer information but proprietary business data, financial records, and intellectual property. This data often includes sensitive information, such as payment card details, addresses, and Social Security numbers. Customers and stakeholders trust these companies to safeguard their data, knowing that breaches can have catastrophic consequences.

To protect sensitive information from adversaries and mitigate security risks, organizations must comply with industry, national, and international regulations and frameworks. These regulations are designed to not only prevent data breaches and misuse but to ensure robust security measures are in place. Noncompliance can lead to severe repercussions, including substantial fines, loss of competitive advantage, and significant reputational damage.

A breach can erode consumer trust and confidence, resulting in decreased customer loyalty and profit losses that negatively impact all stakeholders. Organizations must prioritize cloud compliance to address security concerns, manage reputational risks, and maintain operational integrity in an increasingly digital landscape.

Challenges of cloud compliance

Adopting cloud computing introduces unique compliance challenges due to the nature of cloud environments. Below are key challenges organizations may face when ensuring cloud compliance:

  • Certifications and attestations: To meet the requirements of applicable standards and regulations, both your organization and your cloud service provider must demonstrate compliance. This means ensuring that your cloud platform holds the necessary certifications and attestations. Beyond obtaining these certifications, continuous monitoring is essential — data protection laws evolve, new regulations come into force, and cloud providers’ compliance statuses can change.
  • Data residency: Most data protection laws mandate hosting personal data within permitted territories. This necessitates careful selection of cloud regions to comply with these laws. The challenge intensifies for organizations subject to multiple regulations, potentially requiring a multi-cloud strategy to adequately cover all regulated data.
  • Cloud complexity: Visibility and control over data are crucial for protection, but the dynamic and complex nature of cloud environments presents significant challenges. With numerous moving parts, it becomes difficult to track all data assets and assess their associated risks. Organizations must implement robust data management practices and tools specifically designed for the cloud to maintain visibility and control.
  • Different approach to security: Traditional security tools are often inadequate for the cloud, where IP addresses frequently change and resources are continuously launched and terminated. Compliance requirements generally mandate appropriate technical and organizational measures for data protection, necessitating security solutions tailored for cloud infrastructure. These solutions should emphasize configuration management and individual workload protection to adapt to the cloud environment.
  • Shared responsibility model: In the cloud, security and compliance responsibilities are shared between the cloud provider and the customer. Each leading cloud service provider publishes a shared responsibility model that clarifies these roles. For example, cloud providers are responsible for the security of their physical data centers, hardware, and hypervisors. In contrast, customers are responsible for their guest operating systems, applications, and network configurations. Similarly, compliance responsibilities are divided. The cloud vendor ensures the compliance of the infrastructure and services it offers, and customers must ensure their deployments on the vendor’s platform comply with relevant regulations.
  • Continuous compliance monitoring: Given the dynamic nature of cloud environments, compliance is not a one-time task — it requires ongoing monitoring and adaptation. Organizations must implement continuous compliance monitoring to detect and address compliance issues promptly. This involves regular audits, real-time monitoring tools, and updating policies and procedures as necessary to remain compliant with evolving regulations.
  • Vendor management: Ensuring that cloud service providers maintain their compliance standards is critical. This requires robust vendor management practices, including regular reviews and audits of the provider’s compliance status, understanding their compliance processes, and ensuring that any changes in the provider’s status are promptly addressed. By understanding and addressing these challenges, organizations can effectively manage their compliance obligations in the cloud, ensuring robust protection of sensitive data and maintaining trust with customers and stakeholders.

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Common cloud regulations and standards

Some of the most common compliance requirements (regulations, frameworks, benchmarks, etc.) for the cloud include:

General Data Protection Regulation (GDPR)

The GDPR is an EU legislation designed to unify and strengthen data protection laws across EU member states. It includes comprehensive requirements to safeguard the privacy rights of European Economic Area (EEA) citizens. Key provisions include:

  • Data residency: Personal data must be processed and stored within the EEA or in other permitted countries unless the individual consents otherwise.
  • Data minimization: Organizations should collect and store only the personal data that is necessary for their operations.
  • Storage limitation: Personal data must not be retained longer than necessary.
  • Right of access: Individuals have the right to access the personal data an organization keeps.
  • Right of erasure: Individuals can request the deletion of their personal data.

The GDPR also mandates robust data security measures, though these requirements are somewhat broadly defined. Despite being European legislation, the GDPR has a global reach, applying to any organization that processes or stores personal data about EEA residents, regardless of the organization’s location. Penalties for noncompliance are significant, with fines up to €20 million or 4% of annual global turnover, whichever is higher.

Following its departure from the EU, the U.K. has implemented its own version of the GDPR, known as the U.K. GDPR. The U.K. GDPR is nearly identical to the EU GDPR but includes adjustments to accommodate domestic legal frameworks. For instance, the U.K. GDPR works in conjunction with the Data Protection Act 2018, which provides additional provisions specific to the U.K., such as those related to law enforcement and national security. Organizations operating within or processing data from the U.K. must comply with the U.K. GDPR and the Data Protection Act 2018, ensuring that data protection standards are maintained at the highest level.

Federal Risk and Authorization Management Program (FedRAMP) and NIST SP 800-53

FedRAMP is a notable example of governmental regulation specifically addressing data processed and stored in the cloud. It is a streamlined adaptation of the Federal Information Security Modernization Act (FISMA), the U.S. law governing the processing and storage of data by federal agencies and their contractors, tailored for cloud-based deployments.

FedRAMP is part of a broader framework of regulations designed to ensure the security and resilience of IT systems. These regulations are outlined in NIST SP 800-53, a comprehensive library of requirements categorized according to the risk to data. NIST SP 800-53 provides a standardized set of controls that organizations must implement to maintain security and resilience.

Although FedRAMP and NIST guidelines are voluntary for private sector companies, their adoption helps organizations align with a more standardized approach to privacy and security, especially given the fragmented nature of federal regulations across the U.S. This standardized approach not only aids in achieving compliance with various regulatory requirements but enhances overall data security and operational integrity.

FedRAMP’s rigorous framework ensures that cloud service providers meet stringent security standards, which is crucial for federal agencies and beneficial for private sector companies seeking to maintain high security and compliance standards. This program includes continuous monitoring and regular assessments to ensure ongoing compliance and security.

For organizations looking to adopt cloud services, adhering to FedRAMP guidelines can provide a competitive advantage by demonstrating a commitment to robust security practices and compliance with federal standards. This can be particularly important for companies seeking to do business with federal agencies or those looking to reassure customers and stakeholders about the security of their cloud-based operations.

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ISO 27000 family of standards

The ISO 27000 family of international standards provides comprehensive best practice recommendations for protecting information systems from a variety of threats. This family of standards includes:

  • ISO 27001: This is the core standard in the series, offering a general set of controls for managing information security. It defines the requirements for establishing, implementing, maintaining, and continually improving an information security management system (ISMS).
  • ISO 27017: This standard provides additional security controls specifically for cloud computing, addressing unique security challenges associated with cloud environments.
  • ISO 27018: Focused on the protection of personal data in cloud-based environments, this standard outlines privacy controls to ensure compliance with data protection regulations.

Though compliance with ISO standards is voluntary, obtaining certification can offer numerous benefits. Certification demonstrates a commitment to robust information security practices, instilling trust in customers and suppliers. It also reduces the risk to information assets and facilitates compliance with mandatory data protection regulations. Adhering to these standards helps organizations establish a systematic approach to managing sensitive information, ensuring it remains secure and confidential.

In addition to these core standards, the ISO 27000 family includes other guidelines and frameworks tailored to specific aspects of information security, such as risk management (ISO 27005) and cybersecurity (ISO 27032). Together, these standards provide a comprehensive toolkit for organizations seeking to enhance their information security posture and protect against a wide range of cyber threats.

By adopting and certifying to ISO 27000 standards, organizations can not only improve their security measures but gain a competitive edge, as certification is widely recognized and respected in both domestic and international markets. This commitment to best practices in information security can lead to increased customer confidence and business opportunities.

Payment Card Industry Data Security Standard (PCI DSS)

PCI DSS, administered by the Payment Card Industry Security Standards Council (PCI SSC), is a security-oriented standard applicable to any organization that accepts or processes card payments. This standard is designed to protect payment card transactions and cardholder details by specifying 12 essential requirements.

These requirements are more specific than those outlined in general data protection regulations such as the GDPR, offering concrete measures to enhance payment security. However, implementing these requirements can differ significantly in cloud environments. Traditional perimeter-based firewalls are not designed for the dynamic, distributed, and highly scalable nature of the cloud. To address this challenge, organizations need to use cloud firewalls, which are software-based solutions specifically designed to protect cloud infrastructure. Cloud firewalls can dynamically adjust to the changing landscape of cloud environments, offering more robust and flexible security measures.

Compliance with PCI DSS not only helps protect sensitive payment information but demonstrates a commitment to stringent security practices, boosting customer trust and potentially reducing the risk of data breaches. As cyber threats continue to evolve, maintaining PCI DSS compliance is essential for organizations that handle payment card transactions, ensuring they stay ahead of potential security vulnerabilities and protect their customers’ data effectively.

The Health Insurance Portability and Accountability Act (HIPAA)

HIPAA is a U.S. legislation enacted to ensure the protection of sensitive patient data. HIPAA applies to any organization that handles protected health information (PHI), including healthcare providers, insurers, and their business associates. Compliance with HIPAA is crucial to safeguard patient privacy and secure healthcare information from unauthorized access and breaches — especially in cloud environments, where data storage and processing dynamics differ significantly from traditional on-premises setups.

To comply with HIPAA in the cloud, organizations must:

  • Conduct regular risk assessments: Identify potential vulnerabilities in the handling of PHI within cloud environments and assess the security measures of CSPs.
  • Develop and implement policies and procedures: Ensure these policies address the unique challenges of cloud storage and processing, such as data residency, encryption, and access controls.
  • Employee training: Train employees on HIPAA requirements and best practices for protecting PHI, with a focus on cloud-specific considerations.
  • Robust security measures: Implement encryption, secure access controls, and regular monitoring of systems handling ePHI in the cloud. Ensure that CSPs offer HIPAA-compliant security features and maintain a Business Associate Agreement (BAA) with them.
  • Incident response plan: Establish a clear incident response plan that includes steps for addressing potential breaches in the cloud and ensuring timely notification.

Compliance with HIPAA not only protects sensitive patient data but helps organizations avoid significant penalties for noncompliance, which can include fines of up to $50,000 per violation, with a maximum annual penalty of $1.5 million for identical provisions. Additionally, maintaining HIPAA compliance demonstrates a commitment to patient privacy and trust, which is essential for building and maintaining a reputable healthcare organization.

By adhering to HIPAA regulations and addressing cloud-specific considerations, healthcare organizations can effectively manage and secure PHI, ensuring the privacy and security of patient information in an increasingly digital healthcare environment.

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Cloud compliance best practices

There are a host of different best practices you can follow to help meet regulatory requirements, but the following are particularly beneficial to achieving compliance in the cloud:

  • Encryption: You should start by protecting the very data that’s at risk by encrypting it both at rest and in transit. However, your data is only as secure as the keys you use to encrypt it, so you’ll also need to maintain good key management practices.
  • Privacy by default: Privacy should be automatically baked into system design and processing activities. This will make the task of complying with any data protection regulation or standard significantly easier.
  • The principle of least privilege: You should only grant users access to the data and resources they actually need to carry out their duties. Doing so significantly reduces the risk of compromise by both internal and external threat actors and helps demonstrate that you take appropriate measures to meet compliance requirements.
  • Zero Trust: You should enforce strict authentication, authorization, and monitoring of all users, endpoints, and applications that access your network on a “never trust and always verify” basis.
  • Well-architected frameworks: You can leverage modular frameworks — published by leading cloud vendors such as AWS, Microsoft Azure, and Google Cloud — which take customers through a set of guiding principles on how to build resilient, secure, and highly optimized workloads on their platforms.
  • Continuous monitoring and auditing: Implement continuous monitoring and auditing to ensure ongoing compliance. Use automated tools to monitor compliance status in real time and conduct regular audits to promptly identify and address any gaps or issues.
  • Vendor management: Establish strong vendor management practices to ensure your cloud service providers maintain their compliance standards. Regularly review and audit their compliance status and processes to ensure they meet your regulatory requirements.
  • Incident response planning: Develop and maintain a robust incident response plan tailored to cloud environments. Ensure that your plan includes procedures for detecting, responding to, and recovering from security incidents and data breaches.
  • Data residency awareness: Be mindful of data residency requirements and choose cloud regions that comply with applicable data protection laws. If your organization is subject to multiple regulations, consider a multi-cloud strategy to meet all data residency requirements.
  • Documentation and reporting: Maintain comprehensive documentation of your compliance efforts, including policies, procedures, and audit reports. Effective documentation and reporting demonstrate your commitment to compliance and can be critical during regulatory reviews or audits.

By following these best practices, organizations can enhance their cloud compliance posture, ensuring they meet regulatory requirements and protect sensitive data.

How CrowdStrike helps you maintain cloud compliance

CrowdStrike Falcon® Cloud Security, the most comprehensive cloud-native application protection platform (CNAPP) solution, offers a suite of features to help organizations maintain cloud compliance and secure their cloud environments. Key capabilities include continuous monitoring and real-time visibility through cloud security posture management (CSPM), which assesses cloud environments against best practices and compliance frameworks. The solution’s application security posture management (ASPM) features ensure applications adhere to security standards, and its cloud infrastructure entitlement management (CIEM) capabilities enforce the principle of least privilege with robust access controls. Falcon Cloud Security’s pre-runtime security, or shift left security, integrates into the development process, scanning code and infrastructure templates for vulnerabilities before deployment. Through cloud workload protection (CWP), Falcon Cloud Security provides real-time threat detection and automated response for virtual machines, containers, and serverless functions.

The CrowdStrike Falcon® platform’s advanced threat detection uses machine learning to mitigate threats, and its identity protection capabilities safeguard organizations against credential theft. Falcon Cloud Security simplifies compliance reporting through automated reporting and auditing and ensures data protection and encryption through CWP and CIEM. Seamless integration with major cloud providers like AWS, Microsoft Azure, and Google Cloud ensures consistent application of security controls. Leveraging CrowdStrike’s threat intelligence, Falcon Cloud Security keeps organizations ahead of emerging threats, enabling them to meet regulatory standards, protect sensitive data, and mitigate security risks.

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GET TO KNOW THE AUTHOR

Bhavna B. Sehgal is a Senior Manager of Product Marketing for Cloud Security at CrowdStrike. She brings 14 years of experience across product marketing, product management, and consulting, with deep expertise in security, data privacy, and compliance. Prior to Crowdstrike, Bhavna held roles at Coinbase, Meta, Google Cloud, Verizon, and Booz Allen. She holds a Masters of Science in Strategic Communications from Columbia University.