After mounting concerns relating to the security of cloud computing, a new online platform is to enable users to assess the security features of registered cloud providers. The Security, Trust & Assurance Registry (STAR) hopes to encourage providers to improve their data protection security thanks to this increased transparency, as well as aid organisations using the providers to comply with data protection laws.
The Working Party drew attention to firm’s lack of control over customer’s personal data when using cloud services. As cloud computing uses an internet based network in place of local computing resources, they stated that there is risk of "loss of governance, insecure or incomplete data deletion, insufficient audit trails or isolation failures," by organisations using these providers. Operated by not-for-profit body the Cloud Security Alliance (CSA), STAR hopes to limit such risks to data protection. The CSA’s members include Google, Microsoft and many other global businesses. They provide education on the uses of cloud computing to work towards securing all other forms of computing. Through STAR, cloud providers are able to submit "self assessment reports" which document their compliance with "best practices" as stated by CSA. This searchable registry opens the gates for customers to review providers security practices, so lead hopefully to the improvement of organisations’ their quality of security. The platform is free for both submission and reviewing of entries.
The CSA said that they were driven to launch STAR as they believe voluntary self regulation is needed during the early days of cloud computing, in place of, "heavy handed governmental regulation." They state they support transparency and competition between cloud providers, with security as a market differentiator.
In December last year the first cloud providers, including Microsoft, submitted their reports through STAR. More recently, Amazon published details of the steps they take to ensure the security of user’s information, which is stored in ‘Amazon Web Services’. Amazon also stated that their provider, "engages with external certifying bodies and independent auditors to provide customers with considerable information regarding the policies, processes, and controls established and operated by AWS."
However, the information available from cloud providers or other external certifications is not sufficient to ensure organisations’ own compliance with UK data protection laws. Organisations storing personal data through cloud are still responsible for the safety of the data they store. Such organisations have been told by the EU privacy watchdog, the Article 29 Working Party, that they must “guarantee” compliance with EU data protection laws.
A spokesperson for the ICO made clear that while the overseas transfer of personal data is not prohibited by the Data Protection Act, it is necessary that this information is adequately protected no matter where, or by who, it is being processed. EU data protection law also requires that when sending personal data, through cloud, outside of the European Economic Area (EEA), organisations must ensure that there are sufficient data protection safeguards in place, prior to processing. As an exception to this, countries whose data protection has been pre-approved by the European Commission as being adequate, do not require checking by the organisation itself.
In order that companies are able to meet their own data protection requirements relating to cloud services, The Working Party provides specific guidance. They provide advice on safeguarding contracts between ‘data controllers’ and cloud providers so as to work towards eliminating the risk of non-compliance with data protection law. Such contracts are encouraged to include details of how cloud providers would keep data secure, by what means access to the private information would be restricted and enable the controller to monitor the providers’ data protection compliance.
Concerns had been raised relating to the risk of new vectors, created by a public registry, as targets for exploitation by hackers. The CSA reassured that such risks were not a matter of concern. The documents submitted by cloud providers are designed so that security practices can be clearly documented without exposing sensitive information. This is done through the use of a Consensus Assessments Initiative Questionnaire (CAIQ).
As for the future, the CSA believe that for the meantime STAR will continue as a simple registry for providers. However, they expect the major developments to eventually arise from third party solution providers extending and automating CSA STAR by integrating their GRC Stack directly into their products and services. The GRC Stack refers to the CSA’s toolkit for enterprises, cloud providers, security solution providers and others to instrument and asses clouds against established best practices, standards and critical compliance requirements.
© Brian Miller, solicitor, 2012.
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