CCAK Certificate of Cloud Auditing Knowledge Questions and Answers

 When developing a cloud compliance program, the primary reason for a cloud customer to determine how those services will fit within its policies and procedures is to ensure that the cloud services are aligned with the customer’s business objectives, risk appetite, and compliance obligations. Cloud services may have different characteristics, features, and capabilities than traditional on-premises services, and may require different or additional controls to meet the customer’s security and compliance requirements. Therefore, the customer needs to assess how the cloud services will fit within its existing policies and procedures, such as data classification, data protection, access management, incident response, audit, and reporting. The customer also needs to identify any gaps or conflicts between the cloud services and its policies and procedures, and implement appropriate measures to address them. By doing so, the customer can ensure that the cloud services are used in a secure, compliant, and effective manner12.

References:

ISACA, Certificate of Cloud Auditing Knowledge (CCAK) Study Guide, 2021, p. 19-20.

Cloud Compliance Frameworks: What You Need to Know

Transparent data encryption (TDE) is used for data and log files at rest. This means that TDE encrypts the database files on the disk and decrypts them when they are read into memory. TDE protects the data from unauthorized access or theft if the physical media, such as drives or backup tapes, are stolen or lost. TDE does not encrypt data across communication channels, data currently being processed, or data in random access memory (RAM). These types of data require different encryption methods, such as SSL/TLS, column encryption, or memory encryption12.

References:

Transparent data encryption (TDE) - SQL Server | Microsoft Learn

Transparent Data Encryption - Oracle Help Center

 Cloud service providers offer application programming interfaces (APIs) to encourage clients to extend the cloud platform. APIs are sets of rules and protocols that define how different software components or applications can communicate and interact with each other. APIs enable clients to access the cloud services and data, integrate them with their own applications or systems, and customize or enhance their functionality and performance. APIs also allow clients to leverage the cloud platform’s features and capabilities, such as scalability, reliability, security, and analytics.12

Some examples of cloud service providers that offer APIs are Google Cloud, Microsoft Azure, Amazon Web Services (AWS), IBM Cloud, and Oracle Cloud. These providers offer various types of APIs for different purposes and domains, such as compute, storage, database, networking, artificial intelligence, machine learning, big data, internet of things, and blockchain. These APIs help clients to build, deploy, manage, and optimize their cloud applications and solutions.34567

References := What is an API? - Definition from WhatIs.com1; What is a Cloud API? - Definition from Techopedia2; Cloud APIs | Google Cloud3; Cloud Services - Deploy Cloud Apps & APIs | Microsoft Azure4; AWS Application Programming Interface (API) | AWS5; IBM Cloud API Docs6; Oracle Cloud Infrastructure API Documentation

Organizations maintain mappings between the different control frameworks they adopt to avoid duplication of work when assessing compliance. This is because different control frameworks may have overlapping or equivalent controls that address the same objectives or risks. By mapping these controls, organizations can streamline their compliance assessment process and reduce the cost and effort involved. Mappings also help organizations to identify any gaps or inconsistencies in their control coverage and address them accordingly. This is part of the Cloud Control Matrix (CCM) domain COM-03: Control Frameworks, which states that "The organization should identify and adopt applicable control frameworks, standards, and best practices to support the cloud compliance program."1 References := CCAK Study Guide, Chapter 3: Cloud Compliance Program, page 54

Understanding the organization’s past is crucial for individuals in charge of cloud compliance, particularly to address any open findings from previous external audits. This historical perspective is essential because it allows the compliance team to identify recurring issues, understand the context of past non-compliances, and ensure that corrective actions have been taken and are effective. It also helps in anticipating potential future compliance challenges based on past trends and patterns.

References = The importance of understanding an organization’s past for cloud compliance is supported by best practices in cloud security and compliance, which emphasize the need for continuous improvement and learning from past experiences to enhance security measures123.

During the cloud service provider evaluation process, benchmark controls lists BEST help identify baseline configuration requirements. Benchmark controls lists are standardized sets of security and compliance controls that are applicable to different cloud service models, deployment models, and industry sectors1. They provide a common framework and language for assessing and comparing the security posture and capabilities of cloud service providers2. They also help cloud customers to define their own security and compliance requirements and expectations based on best practices and industry standards3.

Some examples of benchmark controls lists are:

The Cloud Security Alliance (CSA) Cloud Controls Matrix (CCM), which is a comprehensive list of 133 control objectives that cover 16 domains of cloud security4.

The National Institute of Standards and Technology (NIST) Special Publication 800-53, which is a catalog of 325 security and privacy controls for federal information systems and organizations, including cloud-based systems5.

The International Organization for Standardization (ISO) / International Electrotechnical Commission (IEC) 27017, which is a code of practice that provides guidance on 121 information security controls for cloud services based on ISO/IEC 270026.

Vendor requirements, product benchmarks, and contract terms and conditions are not the best sources for identifying baseline configuration requirements. Vendor requirements are the specifications and expectations that the cloud service provider has for its customers, such as minimum hardware, software, network, or support requirements7. Product benchmarks are the measurements and comparisons of the performance, quality, or features of different cloud services or products8. Contract terms and conditions are the legal agreements that define the rights, obligations, and responsibilities of the parties involved in a cloud service contract9. These sources may provide some information on the configuration requirements, but they are not as comprehensive, standardized, or objective as benchmark controls lists.

References:

CSA Security Guidance for Cloud Computing | CSA1, section on Identify necessary security and compliance requirements

Evaluation Criteria for Cloud Infrastructure as a Service - Gartner2, section on Security Controls

Checklist: Cloud Services Provider Evaluation Criteria | Synoptek3, section on Security

Cloud Controls Matrix | CSA4, section on Overview

NIST Special Publication 800-53 - NIST Pages5, section on Abstract

ISO/IEC 27017:2015(en), Information technology — Security techniques …6, section on Scope

What is vendor management? Definition from WhatIs.com7, section on Vendor management

What is Benchmarking? Definition from WhatIs.com8, section on Benchmarking

What is Terms and Conditions? Definition from WhatIs.com9, section on Terms and Conditions

In the context of cloud operationalization, “below the waterline” refers to the aspects of cloud services that are managed and controlled by the cloud service provider (CSP) rather than the customer. This analogy is often used to describe the shared responsibility model in cloud computing, where the CSP is responsible for the infrastructure’s security and stability, akin to the submerged part of an iceberg that supports the structure above water. The customer, on the other hand, is responsible for managing the controls and security measures “above the waterline,” which include the applications, data, and access management they deploy in the cloud environment.

References = The information provided is based on standard cloud computing models and the shared responsibility concept, which is a fundamental principle discussed in cloud auditing and security literature, including the CCAK curriculum and related resources1.

The Egregious 11 refers to a list of top threats to cloud computing, as published by the Cloud Security Alliance (CSA) in 2019. The CSA is a leading organization dedicated to defining standards, certifications and best practices to help ensure a secure cloud computing environment. The Egregious 11 report ranks the most critical and pressing cloud security issues, such as data breaches, misconfigurations, insufficient identity and access management, and account hijacking. The report also provides recommendations for security, compliance, risk and technology practitioners to mitigate these threats. The Egregious 11 is based on a survey of industry experts and a review of current literature and media reports. The report is intended to raise awareness of the risks and challenges associated with cloud computing and promote strong security practices.12 References := CCAK Study Guide, Chapter 5: Cloud Auditing, page 961; CSA Top Threats to Cloud Computing: Egregious 11

The primary purpose of the Open Certification Framework (OCF) for the CSA STAR program is to provide global, accredited, and trusted certification of the cloud service provider. According to the CSA website1, the OCF is an industry initiative to allow global, trusted independent evaluation of cloud providers. It is a program for flexible, incremental and multi-layered cloud provider certification and/or attestation according to the Cloud Security Alliance’s industry leading security guidance and control framework. The OCF aims to address the gaps within the IT ecosystem that are inhibiting market adoption of secure and reliable cloud services. The OCF also integrates with popular third-party assessment and attestation statements developed within the public accounting community to avoid duplication of effort and cost. The OCF manages the foundation that runs and monitors the CSA STAR Certification program, which is an assurance framework that enables cloud service providers to embed cloud-specific security controls. The STAR Certification program has three levels of assurance, each based on a different type of audit or assessment: Level 1: Self-Assessment, Level 2: Third-Party Audit, and Level 3: Continuous Auditing. The OCF also oversees the CSA STAR Registry, which is a publicly accessible repository that documents the security controls provided by various cloud computing offerings2. The OCF helps consumers to evaluate and compare their providers’ resilience, data protection, privacy capabilities, and service portability. It also helps providers to demonstrate their compliance with industry standards and best practices.

References:

Open Certification Framework Working Group | CSA

STAR | CSA

 The greatest risk associated with hidden interdependencies between cloud services is the lack of visibility over the cloud service providers’ supply chain. Hidden interdependencies are the complex and often unknown relationships and dependencies between different cloud services, providers, sub-providers, and customers. These interdependencies can create challenges and risks for the security, availability, performance, and compliance of the cloud services and data. For example, a failure or breach in one cloud service can affect other cloud services that depend on it, or a change in one cloud provider’s policy or contract can impact other cloud providers or customers that rely on it.12

The lack of visibility over the cloud service providers’ supply chain means that the customers do not have enough information or control over how their cloud services and data are delivered, managed, and protected by the providers and their sub-providers. This can expose the customers to various threats and vulnerabilities, such as data breaches, data loss, service outages, compliance violations, legal disputes, or contractual conflicts. The customers may also face difficulties in monitoring, auditing, or verifying the security and compliance status of their cloud services and data across the supply chain. Therefore, it is important for the customers to understand the hidden interdependencies between cloud services and to establish clear and transparent agreements with their cloud providers and sub-providers regarding their roles, responsibilities, expectations, and obligations.3

References := How to identify and map service dependencies - Gremlin1; Mitigate Risk for Data Center Network Migration - Cisco2; Practical Guide to Cloud Service Agreements Version 2.03; HIDDEN INTERDEPENDENCIES BETWEEN INFORMATION AND ORGANIZATIONAL …

Establishing ownership and accountability most enhances the internal stakeholder decision-making process for the remediation of risks identified from an organization’s cloud compliance program. Cloud compliance refers to the principle that cloud-delivered systems must comply with the standards required by their customers. Compliance requirements may include data protection regulations such as HIPAA, PCI DSS, GDPR, ISO/IEC 27001, NIST, and SOX. A cloud compliance program is a set of policies, procedures, and controls that help an organization to achieve and maintain compliance with these requirements12.

A cloud compliance program involves identifying, assessing, prioritizing, and mitigating the risks associated with using cloud services. To effectively manage these risks, an organization needs to establish ownership and accountability for each risk and its remediation. Ownership and accountability mean assigning clear roles and responsibilities to the internal stakeholders who are involved in the cloud compliance program, such as the cloud service provider, the cloud customer, the cloud users, the cloud auditors, and the cloud regulators. By doing so, an organization can ensure that the internal stakeholders have the authority, resources, and incentives to make timely and informed decisions for the remediation of risks123.

The other options are not the most effective ways to enhance the internal stakeholder decision-making process for the remediation of risks. Option A, automating risk monitoring and reporting processes, is a good practice for improving the efficiency and accuracy of the cloud compliance program, but it does not address the issue of who is responsible for making decisions based on the monitoring and reporting results. Option B, reporting emerging threats to senior stakeholders, is a good practice for increasing the awareness and visibility of the cloud compliance program, but it does not address the issue of how to prioritize and respond to the emerging threats. Option D, monitoring key risk indicators (KRIs) for multi-cloud environments, is a good practice for measuring and tracking the performance and effectiveness of the cloud compliance program, but it does not address the issue of how to align and coordinate the decisions across different cloud environments123. References :=

Cloud Compliance Frameworks: What You Need to Know1

Cloud Compliance: What It Is + 8 Best Practices for Improving It2

Cloud Computing: Auditing Challenges - ISACA

 Under the General Data Protection Regulation (GDPR), organizations are required to report a data breach to the appropriate supervisory authority within 72 hours of becoming aware of it. This timeframe is critical to ensure timely communication with the authorities and affected individuals, if necessary, to mitigate any potential harm caused by the breach.

References = This requirement is outlined in the GDPR guidelines, which emphasize the importance of prompt reporting to maintain compliance and protect individual rights and freedoms12345.

To ensure a cloud service provider is complying with an organization’s privacy requirements, a cloud auditor should first review the organizational policies, standards, and procedures that define the privacy objectives, expectations, and responsibilities of the organization. The organizational policies, standards, and procedures should also reflect the legal and regulatory requirements that apply to the organization and its cloud service provider, as well as the best practices and guidelines for cloud privacy. The organizational policies, standards, and procedures should provide the basis for evaluating the cloud service provider’s privacy practices and controls, as well as the contractual terms and conditions that govern the cloud service agreement. The cloud auditor should compare the organizational policies, standards, and procedures with the cloud service provider’s self-disclosure statements, third-party audit reports, certifications, attestations, or other evidence of compliance123.

Reviewing the adherence to organization policies, standards, and procedures (B) is a subsequent step that the cloud auditor should perform after reviewing the organizational policies, standards, and procedures themselves. The cloud auditor should assess whether the cloud service provider is following the organization’s policies, standards, and procedures consistently and effectively, as well as whether the organization is monitoring and enforcing the compliance of the cloud service provider. The cloud auditor should also identify any gaps or deviations between the organization’s policies, standards, and procedures and the actual practices and controls of the cloud service provider123.

Reviewing the legal and regulatory requirements © is an important aspect of ensuring a cloud service provider is complying with an organization’s privacy requirements, but it is not the first step that a cloud auditor should take. The legal and regulatory requirements may vary depending on the jurisdiction, industry, or sector of the organization and its cloud service provider. The legal and regulatory requirements may also change over time or be subject to interpretation or dispute. Therefore, the cloud auditor should first review the organizational policies, standards, and procedures that incorporate and translate the legal and regulatory requirements into specific and measurable privacy objectives, expectations, and responsibilities for both parties123.

Reviewing the IT infrastructure (D) is not a relevant or sufficient step for ensuring a cloud service provider is complying with an organization’s privacy requirements. The IT infrastructure refers to the hardware, software, network, and other components that support the delivery of cloud services. The IT infrastructure is only one aspect of cloud security and privacy, and it may not be accessible or visible to the cloud auditor or the organization. The cloud auditor should focus on reviewing the privacy practices and controls that are implemented by the cloud service provider at different layers of the cloud service model (IaaS, PaaS, SaaS), as well as the contractual terms and conditions that define the privacy rights and obligations of both parties123. References :=

Cloud Audits and Compliance: What You Need To Know - Linford & Company LLP

Trust in the Cloud in audits of cloud services - PwC

Cloud Compliance & Regulations Resources | Google Cloud

The shift-left concept of code release cycles is a practice that aims to integrate testing, quality, and performance evaluation early in the software development life cycle, often before any code is written. This helps to find and prevent defects, improve quality, and enable faster delivery of secure software. One of the key aspects of the shift-left concept is the incorporation of automation to identify and address software code problems early, such as using continuous integration, continuous delivery, and continuous testing tools. Automation can help reduce manual errors, speed up feedback loops, and increase efficiency and reliability123

The other options are not correct because:

Option A is not correct because large entities with slower release cadences and geographically dispersed systems are more likely to face challenges in adopting the shift-left concept, as they may have more complex and legacy systems, dependencies, and processes that hinder agility and collaboration. The shift-left concept requires a culture of continuous improvement, experimentation, and learning that may not be compatible with traditional or siloed organizations4

Option C is not correct because a waterfall model is the opposite of the shift-left concept, as it involves sequential phases of development, testing, and deployment that are performed late in the software development life cycle. A waterfall model does not allow for early detection and correction of defects, feedback, or changes, and can result in higher costs, delays, and risks5

Option D is not correct because maturity of start-up entities with high-iteration to low-volume code commits is not a sign of the shift-left concept, but rather a sign of the agile or lean software development methodologies. These methodologies focus on delivering value to customers by delivering working software in short iterations or sprints, with frequent feedback and adaptation. While these methodologies can support the shift-left concept by enabling faster testing and delivery cycles, they are not equivalent or synonymous with it6

References: 1: AWS. What is DevSecOps? - Developer Security Operations Explained - AWS. [Online]. Available: 4. [Accessed: 14-Apr-2023]. 2: Dynatrace. Shift left vs shift right: A DevOps mystery solved - Dynatrace news. [Online]. Available: 2. [Accessed: 14-Apr-2023]. 3: BMC Software. Shift Left Testing: What, Why & How To Shift Left – BMC Software | Blogs. [Online]. Available: 3. [Accessed: 14-Apr-2023]. 4: GitLab. How to shift left with continuous integration | GitLab. [Online]. Available: 4. [Accessed: 14-Apr-2023]. 5: DZone. DevOps and The Shift-Left Principle - DZone. [Online]. Available: 5. [Accessed: 14-Apr-2023]. 6: Devopedia. Shift Left - Devopedia. [Online]. Available: 6. [Accessed: 14-Apr-2023].

 The management review of the information security framework is an activity that typically occurs outside the regular scope of information security monitoring. This review is a strategic exercise that involves evaluating the overall direction, effectiveness, and alignment of the information security program with the organization’s objectives and risk appetite. It is more about governance and ensuring that the security framework is up-to-date and capable of protecting the organization against current and emerging threats. This contrasts with the operational nature of security monitoring, which focuses on the day-to-day oversight of security controls and the detection of security events.

References = The answer provided is based on general knowledge of information security practices and the typical separation between strategic management activities and operational monitoring tasks. Direct references from the Cloud Auditing Knowledge (CCAK) documents and related resources by ISACA and the Cloud Security Alliance (CSA) are not included here, as my current capabilities do not allow me to access or verify content from external documents or websites. However, the concept of separating strategic management reviews from operational monitoring is a well-established practice in information security management.

According to the ISACA CCAK Study Guide, the auditor should report the findings to the management of the organization being audited, as they are the primary stakeholders and decision makers for the cloud service. The management is responsible for ensuring that the cloud service meets the requirements and expectations of the community, as well as complying with any relevant laws and regulations. The auditor should also communicate the findings to the cloud service provider, as they are the secondary stakeholders and service providers for the cloud service. The cloud service provider should be aware of any issues or gaps identified by the auditor and work with the management to resolve them. The auditor should not report the findings to the public, shareholders, or interested parties, as they are not directly involved in the cloud service or its governance. The auditor should respect the confidentiality and privacy of the community and its data, and only disclose the findings to those who have a legitimate need to know. References :=

ISACA, Certificate of Cloud Auditing Knowledge (CCAK) Study Guide, 2021, p. 971

ISACA, Cloud Auditing Knowledge: Preparing for the CCAK Certificate Exam, 2021, p. 36

 Deleting subscription owner accounts is an activity that MUST obtain a client’s approval in the context of cloud service provider activities. Subscription owner accounts are critical as they hold the ownership and control over the resources and services within a cloud subscription. Deleting these accounts can have significant implications, including loss of access, control, and potential data loss. Therefore, it is essential for a cloud service provider to seek explicit approval from the client before proceeding with such an action to ensure transparency, maintain trust, and avoid any unintended consequences.

References:

Microsoft Trust Center, Cloud Services Due Diligence Checklist1.

Google Cloud, What is a Cloud Service Provider?2.

Partner Center, CSP agreements, price lists, and offers3.

Microsoft Azure, How to choose a cloud service provider4.

FCA, FG16/5 Guidance for firms outsourcing to the ‘cloud’ and other third-party IT services

ISO/IEC 27017:2015 is a standard that provides guidelines for information security controls applicable to the provision and use of cloud services by providing additional implementation guidance for relevant controls specified in ISO/IEC 27002, as well as additional controls with implementation guidance that specifically relate to cloud services1. ISO/IEC 27017:2015 is designed to be used by organizations for cloud services that intend to select controls within the process of implementing an information security management system based on ISO/IEC 27001, which is the international standard for information security management systems1. ISO/IEC 27017:2015 can help organizations to establish, implement, maintain and continually improve their information security in the cloud environment, as well as to demonstrate compliance with contractual and legal obligations1.

ISO/IEC 27002 is a code of practice for information security controls that provides best practice recommendations on information security management for use by those who are responsible for initiating, implementing or maintaining information security management systems2. However, ISO/IEC 27002 does not provide specific guidance for cloud services, which is why ISO/IEC 27017:2015 was developed as an extension to ISO/IEC 27002 for cloud services1.

Cloud Security Alliance (CSA) Cloud Controls Matrix (CCM) is a set of security controls that provides organizations with a detailed understanding of security concepts and principles that are aligned to the cloud model. The CCM is not a standard, but rather a framework that can be used to assess the overall security risk of a cloud provider. The CCM can also be mapped to other standards, such as ISO/IEC 27001 and ISO/IEC 27017:2015, to facilitate compliance and assurance activities.

NIST SP 800-146 is a publication from the National Institute of Standards and Technology (NIST) that provides an overview of cloud computing, its characteristics, service models, deployment models, benefits, challenges and considerations. NIST SP 800-146 is not a standard, but rather a reference document that can help organizations to understand the basics of cloud computing and its implications for information security. NIST SP 800-146 does not provide specific guidance or controls for cloud services, but rather refers to other standards and frameworks, such as ISO/IEC 27001 and CSA CCM, for more detailed information on cloud security. References :=

ISO/IEC 27017:2015 - Information technology — Security techniques …

ISO/IEC 27017:2015(en), Information technology ? Security techniques …

ISO 27017 Certification - Cloud Security Services | NQA

An introduction to ISO/IEC 27017:2015 - 6clicks

ISO/IEC 27017:2015 - Information technology — Security techniques …

[Cloud Controls Matrix | Cloud Security Alliance]

[NIST Cloud Computing Synopsis and Recommendations]

Credential scanning is a technique that can be used to detect and prevent the exposure of access keys and other sensitive information in the source code or any other configuration files during development. Credential scanning tools can scan the code repositories, files, and commits for any hardcoded credentials, such as access keys, passwords, tokens, certificates, and connection strings. They can also alert the developers or security teams of any potential leaks and suggest remediation actions, such as rotating or revoking the compromised keys, removing the credentials from the code, or using secure storage mechanisms like vaults or environment variables. Credential scanning can be integrated into the development pipeline as part of the continuous integration and continuous delivery (CI/CD) process, or performed periodically as a security audit. Credential scanning can help reduce the risk of credential leakage, which can lead to unauthorized access, data breaches, or account compromise. References:

Protecting Source Code in the Cloud with DSPM

Best practices for managing service account keys

Protect your code repository

The CSA Cloud Controls Matrix (CCM) is the best tool to perform cloud security control audits, as it is a cybersecurity control framework for cloud computing that is aligned to the CSA best practices and is considered the de-facto standard for cloud security and privacy1. The CCM provides a set of 197 control objectives that are structured in 17 domains covering all key aspects of cloud technology, such as identity and access management, data security, encryption and key management, business continuity and disaster recovery, audit assurance and compliance, and risk management1. The CCM also maps the controls to various industry-accepted security standards, regulations, and control frameworks, such as ISO 27001/27002/27017/27018, NIST SP 800-53, PCI DSS, GDPR, and others1. The CCM can be used as a tool for the systematic assessment of a cloud implementation, and provides guidance on which security controls should be implemented by which actor within the cloud supply chain1. The CCM also includes the Consensus Assessment Initiative Questionnaire (CAIQ), which provides a set of “yes or no” questions based on the security controls in the CCM that can be used to assess a cloud service provider2.

The other options are not the best tools to perform cloud security control audits, as they are either not specific to cloud computing or not comprehensive enough. GDPR is a regulation that aims to protect the personal data and privacy of individuals in the European Union and the European Economic Area3, but it does not provide a framework for cloud security controls. FIPS 140-2 is a standard that specifies the security requirements for cryptographic modules used by federal agencies in the United States, but it does not cover other aspects of cloud security. ISO 27001 is a standard that specifies the requirements for establishing, implementing, maintaining and continually improving an information security management system within the context of the organization, but it does not provide specific guidance for cloud services. References:

Cloud Controls Matrix (CCM) - CSA

Cloud Controls Matrix and CAIQ v4 | CSA - Cloud Security Alliance

General Data Protection Regulation - Wikipedia

[FIPS 140-2 - Wikipedia]

[ISO/IEC 27001:2013]

Controls mapping found in the Scope Applicability column of the Cloud Controls Matrix (CCM) may help organizations to realize cost savings by avoiding duplication of efforts in the compliance evaluation and for the eventual control design and implementation. The Scope Applicability column is a feature of the CCM that indicates which cloud model type (IaaS, PaaS, SaaS) or cloud environment (public, hybrid, private) a control applies to. This feature can help organizations to identify and select the most relevant and appropriate controls for their specific cloud scenario, as well as to map them to multiple industry-accepted security standards, regulations, and frameworks. By doing so, organizations can reduce the time, resources, and costs involved in achieving and maintaining compliance with various cloud security requirements123.

The other options are not directly related to the question. Option B, by implementing layered security, thus reducing the likelihood of data breaches and the associated costs, is not a valid reason because layered security is a general principle of defense in depth, not a specific feature of the CCM or the Scope Applicability column. Option C, by avoiding the need to hire a cloud security specialist to perform the periodic risk assessment exercise, is not a valid reason because using the CCM or the Scope Applicability column does not eliminate the need for a cloud security specialist or a periodic risk assessment exercise, which are essential for ensuring the effectiveness and adequacy of the cloud security controls. Option D, by avoiding fines for breaching those regulations that impose a controls mapping in order to prove compliance, is not a valid reason because controls mapping is not a mandatory requirement for proving compliance, but a voluntary tool for facilitating compliance. References :=

What is CAIQ? | CSA - Cloud Security Alliance1

Understanding the Cloud Control Matrix | CloudBolt Software2

Cloud Controls Matrix (CCM) - CSA

A centralized risk and controls dashboard is the best option for ensuring a coordinated approach to risk and control processes when duties are split between an organization and its cloud service providers. This dashboard provides a unified view of risk and control status across the organization and the cloud services it utilizes. It enables both parties to monitor and manage risks effectively and ensures that control activities are aligned and consistent. This approach supports proactive risk management and facilitates communication and collaboration between the organization and the cloud service provider.

References = The concept of a centralized risk and controls dashboard is supported by the Cloud Security Alliance (CSA) and ISACA, which emphasize the importance of visibility and coordination in cloud risk management. The CCAK materials and the Cloud Controls Matrix (CCM) provide guidance on establishing such dashboards as a means to manage and mitigate risks in a cloud environment12.

 Supply chain agreements between a cloud service provider and cloud customers should, at a minimum, include audits, assessments, and independent verification of compliance certifications with agreement terms. This is because cloud services involve multiple parties in the supply chain, such as cloud providers, sub-providers, brokers, carriers, and auditors. Each party may have different roles and responsibilities in delivering the cloud services and ensuring their quality, security, and compliance. Therefore, it is important for the cloud customers to have visibility and assurance of the performance and compliance of the cloud providers and their sub-providers. Audits, assessments, and independent verification of compliance certifications are methods to evaluate the effectiveness of the controls and processes implemented by the cloud providers and their sub-providers to meet the agreement terms. These methods can help the cloud customers to identify any gaps or risks in the supply chain and to take corrective actions if needed. This is part of the Cloud Control Matrix (CCM) domain COM-04: Audit Assurance & Compliance, which states that "The organization should have a policy and procedures to conduct audits and assessments of cloud services and data to verify compliance with applicable regulatory frameworks, contractual obligations, and industry standards."12 References := CCAK Study Guide, Chapter 3: Cloud Compliance Program, page 551; Practical Guide to Cloud Service Agreements Version 2.02

When an organization is moving to the cloud, responsibilities are shared based upon the cloud service provider’s model and accountability is maintained. This means that the organization remains accountable for the security and compliance of its data and applications in the cloud, even if some of the security responsibilities are delegated to the cloud service provider (CSP). The organization cannot transfer or avoid its accountability to the CSP or any other third party, as it is ultimately responsible for its own business outcomes, legal obligations, and reputation. Therefore, the organization must understand the shared responsibility model and which security tasks are handled by the CSP and which tasks are handled by itself. The organization must also monitor and audit the CSP’s performance and security, and mitigate any risks or issues that may arise12.

References:

Shared responsibility in the cloud - Microsoft Azure

Understanding the Shared Responsibilities Model in Cloud Services - ISACA

An example of integrity technical impact refers to an event where the accuracy or trustworthiness of data is compromised. Option D, where a hacker uses a stolen administrator identity to alter the discount percentage in the product database, directly affects the integrity of the data. This action leads to unauthorized changes to data, which is a clear violation of data integrity. In contrast, options A, B, and C describe breaches of confidentiality, availability, and security, respectively, but do not directly impact the integrity of the data itself123.

References = The concept of data integrity in cloud computing is extensively covered in the literature, including the importance of protecting against unauthorized data alteration to maintain the trustworthiness and accuracy of data throughout its lifecycle123.

The CSA STAR Certification is based on criteria outlined in the Cloud Security Alliance (CSA) Cloud Controls Matrix (CCM) in addition to ISO/IEC 27001 implementation. The CCM is a cybersecurity control framework for cloud computing that covers 17 domains and 197 control objectives that address all key aspects of cloud technology. ISO/IEC 27001 is a standard for information security management systems that specifies the requirements for establishing, implementing, maintaining, and continually improving an information security management system within the context of the organization. The CSA STAR Certification demonstrates that a cloud service provider conforms to the applicable requirements of ISO/IEC 27001, has addressed issues critical to cloud security as outlined in the CCM, and has been assessed against the STAR Capability Maturity Model for the management of activities in CCM control areas1. The CSA STAR Certification is a third-party independent assessment of the security of a cloud service provider and provides a high level of assurance and trust to customers2.

References:

CSA STAR Certification - Azure Compliance | Microsoft Learn

STAR | CSA

Trust in a cloud service provider is fundamentally based on the assurance that the provider can deliver secure and reliable services. The level of proven technical skills is a critical factor because it demonstrates the provider’s capability to implement and maintain robust security measures, manage complex cloud infrastructures, and respond effectively to technical challenges. Technical expertise is essential for establishing trust, as it directly impacts the security and performance of the cloud services offered.

References = The importance of technical skills in establishing trust is supported by the resources provided by ISACA and the Cloud Security Alliance (CSA). These resources emphasize the need for cloud service providers to have a strong technical foundation to ensure the fulfillment of internal requirements, proper controls, and compliance with regulations, which are crucial for maintaining customer trust and mitigating risks1234.

Implementing service level agreements (SLAs) around changes to baseline configurations is the most important way to manage risk from cloud vendors who might accidentally introduce unnecessary risk to an organization by adding new features to their solutions. A service level agreement (SLA) is a contract or a part of a contract that defines the expected level of service, performance, and quality that a cloud vendor will provide to an organization. An SLA can also specify the roles and responsibilities, the communication channels, the escalation procedures, and the penalties or remedies for non-compliance12.

Implementing SLAs around changes to baseline configurations can help an organization to manage the risk from cloud vendors who might add new features to their solutions without proper testing, validation, or notification. Baseline configurations are the standard or reference settings for a system or a network that are used to measure and maintain its security and performance. Changes to baseline configurations can introduce new vulnerabilities, errors, or incompatibilities that can affect the functionality, availability, or security of the system or network34. Therefore, an SLA can help an organization to ensure that the cloud vendor follows a change management process that includes steps such as risk assessment, impact analysis, approval, documentation, notification, testing, and rollback. An SLA can also help an organization to monitor and verify the changes made by the cloud vendor and to report and resolve any issues or incidents that may arise from them.

The other options are not the most effective ways to manage the risk from cloud vendors who might add new features to their solutions. Option A, deploying new features using cloud orchestration tools, is not a good way to manage the risk because cloud orchestration tools are used to automate and coordinate the deployment and management of complex cloud services and resources. Cloud orchestration tools do not address the issue of whether the new features added by the cloud vendor are necessary, secure, or compatible with the organization’s system or network. Option B, performing prior due diligence of the vendor, is not a good way to manage the risk because prior due diligence is a process that involves evaluating and verifying the background, reputation, capabilities, and compliance of a potential cloud vendor before entering into a contract with them. Prior due diligence does not address the issue of how the cloud vendor will handle changes to their solutions after the contract is signed. Option C, establishing responsibility in the vendor contract, is not a good way to manage the risk because establishing responsibility in the vendor contract is a process that involves defining and assigning the roles and obligations of both parties in relation to the cloud service delivery and performance. Establishing responsibility in the vendor contract does not address the issue of how the cloud vendor will communicate and coordinate with the organization about changes to their solutions. References :=

What is an SLA? Best practices for service-level agreements | CIO1

Service Level Agreements - Cloud Security Alliance2

What is Baseline Configuration? - Definition from Techopedia3

Baseline Configuration - Cloud Security Alliance4

Change Management - Cloud Security Alliance

Incident Response - Cloud Security Alliance

What is Cloud Orchestration? - Definition from Techopedia

Due Diligence - Cloud Security Alliance

Contractual Security Requirements - Cloud Security Alliance

The Architectural Relevance feature within the Cloud Controls Matrix (CCM) allows for the filtering of security controls based on relevant delivery models like SaaS, PaaS, and IaaS. This feature is crucial because it aligns the security controls with the specific cloud service models being used, ensuring that the controls are applicable and effective for the particular cloud architecture in place.

References = The CCM’s focus on delivery models is supported by the CSA Enterprise Architecture Working Group, which helps define the organizational relevance of each control, including the alignment with different cloud service models1.

Role-based access control (RBAC) is a method of restricting access to resources based on the roles of individual users within an organization1 RBAC can help ensure adequate restriction on the number of people who can access the pipeline production environment, as it can limit the permissions and actions that each user can perform on the pipeline resources, such as code, secrets, environments, etc. RBAC can also help enforce the principle of least privilege, which states that users should only have the minimum level of access required to perform their tasks2

The other options are not correct because:

Option A is not correct because ensuring segregation of duties in the production and development pipelines is not sufficient to ensure adequate restriction on the number of people who can access the pipeline production environment. Segregation of duties is a practice that aims to prevent fraud, errors, or conflicts of interest by dividing responsibilities among different people or teams3 However, segregation of duties does not necessarily limit the number of people who can access the pipeline resources, as it depends on how the roles and permissions are defined and assigned. Segregation of duties is also more relevant for preventing unauthorized changes or deployments to the production environment, rather than restricting access to it4

Option B is not correct because periodic review of the continuous integration and continuous delivery (CI/CD) pipeline audit logs to identify any access violations is not a proactive measure to ensure adequate restriction on the number of people who can access the pipeline production environment. Audit logs are records of events or activities that occur within a system or process5 Audit logs can help monitor and detect any unauthorized or suspicious access to the pipeline resources, but they cannot prevent or restrict such access in the first place. Audit logs are also dependent on the frequency and quality of the review process, which may not be timely or effective enough to mitigate the risks of access violations6

Option D is not correct because separation of production and development pipelines is not a direct way to ensure adequate restriction on the number of people who can access the pipeline production environment. Separation of production and development pipelines is a practice that aims to isolate and protect the production environment from any potential errors, bugs, or vulnerabilities that may arise from the development process. However, separation of pipelines does not automatically imply restriction of access, as it depends on how the roles and permissions are configured for each pipeline. Separation of pipelines may also introduce challenges such as synchronization, coordination, and communication among the pipeline teams and stakeholders.

References: 1: Wikipedia. Role-based access control - Wikipedia. [Online]. Available: 1. [Accessed: 14-Apr-2023]. 2: Microsoft Learn. Set pipeline permissions - Azure Pipelines | Microsoft Learn. [Online]. Available: 1. [Accessed: 14-Apr-2023]. 3: Investopedia. Segregation Of Duties Definition - Investopedia.com Blog. [Online]. Available: . [Accessed: 14-Apr-2023]. 4: Cider Security. Insufficient PBAC (Pipeline-Based Access Controls) - Cider Security Blog. [Online]. Available: . [Accessed: 14-Apr-2023]. 5: Wikipedia. Audit trail - Wikipedia. [Online]. Available: . [Accessed: 14-Apr-2023]. 6: Microsoft Learn. Securing Azure Pipelines - Azure Pipelines | Microsoft Learn. [Online]. Available: . [Accessed: 14-Apr-2023]. : AWS DevOps Blog. How to implement CI/CD with AWS CodePipeline - AWS DevOps Blog | Amazon Web Services Blog. [Online]. Available: . [Accessed: 14-Apr-2023]. : LambdaTest. What Is Parallel Testing? with Example - LambdaTest Blog. [Online]. Available: . [Accessed: 14-Apr-2023].

According to the ISACA Cloud Auditing Knowledge Certificate Study Guide, a cloud auditor should use statistical sampling rather than judgment (nonstatistical) sampling when the probability of error must be objectively quantified1. Statistical sampling is a sampling technique that uses random selection methods and mathematical calculations to draw conclusions about the population from the sample results. Statistical sampling allows the auditor to measure the sampling risk, which is the risk that the sample results do not represent the population, and to express the confidence level and precision of the sample1. Statistical sampling also enables the auditor to estimate the rate of exceptions or errors in the population based on the sample1.

The other options are not valid reasons for using statistical sampling rather than judgment sampling. Option A is irrelevant, as generalized audit software is a tool that can facilitate both statistical and judgment sampling, but it is not a requirement for either technique. Option B is incorrect, as statistical sampling does not avoid sampling risk, but rather measures and controls it. Option D is illogical, as the tolerable error rate is a parameter that must be determined before conducting any sampling technique, whether statistical or judgmental. References:

ISACA Cloud Auditing Knowledge Certificate Study Guide, page 17-18.

From an auditor’s perspective, shadow IT is best described as a risk that jeopardizes business continuity planning. Shadow IT refers to the use of IT-related hardware or software that is not under the control of, or has not been approved by, the organization’s IT department. This can lead to a lack of visibility into the IT infrastructure and potential gaps in security and compliance measures. In the context of business continuity planning, shadow IT can introduce unknown risks and vulnerabilities that are not accounted for in the organization’s disaster recovery and business continuity plans, thereby posing a threat to the organization’s ability to maintain or quickly resume critical functions in the event of a disruption.

References = The answer is based on general knowledge of shadow IT risks and their impact on business continuity planning. Specific references from the Cloud Auditing Knowledge (CCAK) documents and related resources by ISACA and the Cloud Security Alliance (CSA) are not directly cited here, as my current capabilities do not include accessing or verifying content from external documents or websites. However, the concept of shadow IT as a risk to business continuity is a recognized concern in IT governance and auditing practices1234.

According to the CCAK Study Guide, the business continuity management and operational resilience strategy of the cloud customer should be formulated jointly with the cloud service provider, as they share the responsibility for ensuring the availability and recoverability of the cloud services. The strategy should cover all aspects of business continuity and resilience planning, taking inputs from the assessed impact and risks, to consider activities for before, during, and after a disruption. These activities include prevention, mitigation, response, recovery, restoration, and improvement. The strategy should also define the roles and responsibilities of both parties, the communication channels and escalation procedures, the testing and exercising plans, and the review and update mechanisms1

The other options are not correct because:

Option B is not correct because the strategy should not only be developed within the acceptable limits of the risk appetite, but also aligned with the business objectives and stakeholder expectations of both parties. The risk appetite is only one of the factors that influence the strategy formulation1

Option C is not correct because the strategy should not only cover the activities required to continue and recover prioritized activities within identified time frames and agreed capacity, but also consider the activities for before and after a disruption, such as prevention, mitigation, improvement, etc. The strategy should also include other elements such as roles and responsibilities, communication channels, testing plans, etc1

References: 1: ISACA, Cloud Security Alliance. Certificate of Cloud Auditing Knowledge (CCAK) Study Guide. 2021. pp. 83-84.

The most relevant question in the cloud compliance program design phase is who owns the cloud governance strategy. Cloud governance is a method of information and technology (I&T) governance focused on accountability, defining decision rights and balancing benefit, risk and resources in an environment that embraces cloud computing. Cloud governance creates business-driven policies and principles that establish the appropriate degree of investments and control around the life cycle process for cloud computing services1. Therefore, it is essential to identify who owns the cloud governance strategy in the organization, as this will determine the roles and responsibilities, decision-making authority, reporting structure, and escalation process for cloud compliance issues. The cloud governance owner should be a senior executive who has the vision, influence, and resources to drive the cloud compliance program and align it with the business objectives2.

References:

Building Cloud Governance From the Basics - ISACA

[Cloud Governance | Microsoft Azure]

Attribute-based access control (ABAC) is a cloud-native solution that uses attributes (such as user role, location, or device) to dynamically control access. This method is highly flexible for the cloud, where user attributes and environmental factors vary, unlike traditional enterprise security models. ISACA’s CCAK emphasizes ABAC in cloud environments for its adaptability to multi-tenant architectures and complex access control requirements, aligning with CCM controls in Domain IAM-12 (Identity and Access Management) for flexible, secure access mechanisms.

=========================

 When applying the Top Threats Analysis methodology following an incident, the scope of the technical impact identification step is to determine the impact on confidentiality, integrity, and availability of the information system. The Top Threats Analysis methodology is a process developed by the Cloud Security Alliance (CSA) to help organizations identify, analyze, and mitigate the top threats to cloud computing, as defined in the CSA Top Threats reports. The methodology consists of six steps1:

Scope definition: Define the scope of the analysis, such as the cloud service model, deployment model, and business context.

Threat identification: Identify the relevant threats from the CSA Top Threats reports that may affect the scope of the analysis.

Technical impact identification: Determine the impact on confidentiality, integrity, and availability of the information system caused by each threat. Confidentiality refers to the protection of data from unauthorized access or disclosure. Integrity refers to the protection of data from unauthorized modification or deletion. Availability refers to the protection of data and services from disruption or denial.

Business impact identification: Determine the impact on the business objectives and operations caused by each threat, such as financial loss, reputational damage, legal liability, or regulatory compliance.

Risk assessment: Assess the likelihood and severity of each threat based on the technical and business impacts, and prioritize the threats according to their risk level.

Risk treatment: Select and implement appropriate risk treatment options for each threat, such as avoidance, mitigation, transfer, or acceptance.

The technical impact identification step is important because it helps to measure the extent of damage or harm that each threat can cause to the information system and its components. This step also helps to align the technical impacts with the business impacts and to support the risk assessment and treatment steps.

References := CCAK Study Guide, Chapter 4: A Threat Analysis Methodology for Cloud Using CCM, page 81

Shadow IT refers to the use of IT resources (hardware, software, or cloud services) within an organization without the explicit approval of the IT or governance team. This practice is often flagged in cloud audits due to potential risks of compliance violations and security threats. The CCAK documentation from ISACA highlights the need for visibility and governance over all IT assets, with specific controls listed in the CSA CCM for Cloud Governance (GOV-09). Shadow IT poses risks to data security, compliance, and can introduce vulnerabilities, as systems are not subject to organizational standards and oversight.

=========================

 The cloud auditor should check if there is explicit documented approval from all customers whose data is affected by the transfer of production data to the test environment. This is because production data may contain sensitive or personal information that is subject to privacy and security regulations, such as the General Data Protection Regulation (GDPR) or the Health Insurance Portability and Accountability Act (HIPAA). Therefore, using production data for testing purposes without the consent of the data owners may violate their rights and expose the organization to legal and reputational risks. This is also stated in the Cloud Controls Matrix (CCM) control DSI-04: Production / Non-Production Environments12, which is part of the Data Security & Information Lifecycle Management domain. The CCM is a cybersecurity control framework for cloud computing that can be used by cloud customers to build an operational cloud risk management program.

The other options are not directly related to the question. Option A, approval of the change by the change advisory board, refers to the process of reviewing and authorizing changes to the system or software before they are implemented in the production environment. This is a good practice for ensuring the quality and reliability of the system or software, but it does not address the issue of using production data for testing purposes. Option C, training for the librarian, refers to the process of providing adequate education and awareness to the staff who are responsible for managing and transferring data between different environments. This is a good practice for ensuring the competence and accountability of the staff, but it does not address the issue of obtaining consent from the data owners. Option D, verification that the hardware of the test and production environments are compatible, refers to the process of ensuring that the system or software can run smoothly and consistently on both environments. This is a good practice for ensuring the performance and functionality of the system or software, but it does not address the issue of protecting the privacy and security of the production data. References :=

Certificate of Cloud Auditing Knowledge (CCAK) Study Guide, Chapter 6: Cloud Security Controls

Cloud Controls Matrix (CCM) - CSA3

DSI-04: Production / Non-Production Environments - CSF Tools - Identity Digital1

DSI: Data Security & Information Lifecycle Management - CSF Tools - Identity Digital

It is most important for the auditor to be aware that the client organization has a clear understanding of the provider’s suppliers. The provider’s suppliers are the third-party entities that provide services or products to the provider, such as infrastructure, software, hardware, or support. The provider’s suppliers may have a significant impact on the quality, security, reliability, and performance of the cloud services that the provider delivers to the client organization. Therefore, the auditor should ensure that the client organization knows who the provider’s suppliers are, what services or products they provide, what risks they pose, and what contractual or regulatory obligations they have123.

The other options are not correct. Option A, the client organization does not need to worry about the provider’s suppliers, as this is the provider’s responsibility, is incorrect because the client organization cannot rely solely on the provider to manage its suppliers. The client organization has to perform due diligence and oversight on the provider’s suppliers, as they may affect the client organization’s own security, compliance, and business objectives12. Option B, the suppliers are accountable for the provider’s service that they are providing, is incorrect because the suppliers are not directly accountable to the client organization, but to the provider. The provider is ultimately accountable to the client organization for its service delivery and performance12. Option C, the client organization and provider are both responsible for the provider’s suppliers, is incorrect because the responsibility for the provider’s suppliers depends on the shared responsibility model, which defines how the security and compliance tasks and obligations are divided between the provider and the client organization. The shared responsibility model may vary depending on the type and level of cloud service that the provider offers12. References :=

Cloud Computing: Auditing Challenges - ISACA1

Cloud Computing: Audit Considerations - ISACA2

Top 16 Cloud Computing Companies & Service Providers 2023 - Datamation

 According to the cloud shared responsibility model, the cloud customer is responsible for managing the access controls for the SaaS functionality and operations, and this should be audited by the cloud auditor12. Access controls are the mechanisms that restrict and regulate who can access and use the SaaS applications and data, and how they can do so. Access controls include identity and access management, authentication, authorization, encryption, logging, and monitoring. The cloud customer is responsible for defining and enforcing the access policies, roles, and permissions for the SaaS users, as well as ensuring that the access controls are aligned with the security and compliance requirements of the customer’s business context12.

The other options are not the aspects of SaaS functionality and operations that the cloud customer is responsible for and should be audited. Option B is incorrect, as vulnerability management is the process of identifying, assessing, and mitigating the security weaknesses in the SaaS applications and infrastructure, and this is usually handled by the cloud service provider12. Option C is incorrect, as patching is the process of updating and fixing the SaaS applications and infrastructure to address security issues or improve performance, and this is also usually handled by the cloud service provider12. Option D is incorrect, as source code reviews are the process of examining and testing the SaaS applications’ source code to detect errors or vulnerabilities, and this is also usually handled by the cloud service provider12. References:

Shared responsibility in the cloud - Microsoft Azure

The Customer’s Responsibility in the Cloud Shared Responsibility Model - ISACA

The first step to switch from the ISO/IEC 27002 control framework to the NIST 800-53 control framework is to map ISO/IEC 27002 and NIST 800-53 and detect gaps and commonalities. This step can help the organization to understand the similarities and differences between the two frameworks, and to identify which controls are already implemented, which controls need to be added or modified, and which controls are no longer applicable. Mapping can also help the organization to leverage the existing work done under ISO/IEC 27002 and avoid starting from scratch or discarding valuable information. Mapping can also help the organization to align with both frameworks, as they are not mutually exclusive or incompatible. In fact, NIST SP 800-53, Revision 5 provides a mapping table between NIST 800-53 and ISO/IEC 27001 in Appendix H-21. ISO/IEC 27001 is a standard for information security management systems that is based on ISO/IEC 27002, which is a code of practice for information security controls2.

References:

NIST SP 800-53, Revision 5 Control Mappings to ISO/IEC 27001

ISO - ISO/IEC 27002:2013 - Information technology — Security techniques — Code of practice for information security controls

A corrective control is a measure taken to correct or reduce the impact of an error, deviation, or unwanted activity1. Corrective control can be either manual or automated, depending on the type of control used. Corrective control can involve procedures, manuals, systems, patches, quarantines, terminations, reboots, or default dates1. A Business Continuity Plan (BCP) is an example of a corrective control.

Unsuccessful access attempts being automatically logged for investigation is an example of a corrective control because it is a response to a potential security incident that aims to identify and resolve the cause and prevent future occurrences2. Logging and investigating failed login attempts can help detect unauthorized or malicious attempts to access sensitive data or systems and take appropriate actions to mitigate the risk.

The other options are examples of preventive controls, which are designed to prevent problems from occurring in the first place3. Preventive controls can include:

A central antivirus system installing the latest signature files before allowing a connection to the network: This is a preventive control because it prevents malware infection by blocking potentially harmful connections and updating the antivirus software regularly4.

All new employees having standard access rights until their manager approves privileged rights: This is a preventive control because it prevents unauthorized access by enforcing the principle of least privilege and requiring approval for granting higher-level permissions5.

Privileged access to critical information systems requiring a second factor of authentication using a soft token: This is a preventive control because it prevents credential theft or compromise by adding an extra layer of security to verify the identity of the user.

References:

What is a corrective control? - Answers1, section on Corrective control

Detective controls - SaaS Lens - docs.aws.amazon.com2, section on Unsuccessful login attempts

Internal control: how do preventive and detective controls work?3, section on Preventive Controls

What Are Security Controls? - F54, section on Preventive Controls

The 3 Types of Internal Controls (With Examples) | Layer Blog5, section on Preventive Controls

What are the 3 Types of Internal Controls? — RiskOptics - Reciprocity, section on Preventive Controls

Regarding cloud service provider agreements and contracts, unless otherwise stated, the provider is responsible only to the cloud customer. This means that the provider has a contractual obligation to deliver the agreed-upon services and meet the service level agreements (SLAs) with the cloud customer, who is the direct payer of the services. The provider is not responsible for any other parties, such as the cloud customer’s clients, end users, or regulators, unless explicitly specified in the contract. The cloud customer is responsible for ensuring that the provider’s services meet their own compliance and security requirements, as well as those of their stakeholders12.

References:

Shared responsibility in the cloud - Microsoft Azure

Cloud security shared responsibility model - NCSC

The three main phases of the Cloud Controls Matrix (CCM) mapping methodology are preparation, execution, and peer review and publication. The CCM mapping methodology is a process to map the CCM controls to other standards, regulations, or frameworks that are relevant for cloud security. The mapping helps to identify the commonalities and differences between the CCM and the other standards, regulations, or frameworks, and to provide guidance for cloud service providers and customers on how to achieve compliance with multiple requirements using the CCM. The mapping methodology consists of the following phases1:

Preparation: This phase involves defining the scope, objectives, and deliverables of the mapping project, as well as identifying the stakeholders, resources, and tools needed. This phase also includes conducting a preliminary analysis of the CCM and the other standard, regulation, or framework to be mapped, and establishing the mapping criteria and rules.

Execution: This phase involves performing the actual mapping of the CCM controls to the other standard, regulation, or framework using a spreadsheet template. This phase also includes documenting the mapping results, providing explanations and justifications for each mapping decision, and resolving any issues or conflicts that may arise during the mapping process.

Peer Review and Publication: This phase involves validating and verifying the quality and accuracy of the mapping results by conducting a peer review with subject matter experts from both the CCM working group and the other standard, regulation, or framework organization. This phase also includes finalizing and publishing the mapping document as a CSA artifact, and communicating and promoting the mapping to the relevant audiences.

References := Methodology for the Mapping of the Cloud Controls Matrix1

 A contract containing the phrase “You automatically consent to these terms by using or logging into the service to which they pertain” is establishing a contract of adhesion. A contract of adhesion is a type of legal agreement that involves one party setting the terms and conditions and the other party having no choice but to accept or reject them without bargaining. These contracts are often used in situations where one party has more power or resources than the other, such as in online services, insurance, leases, or consumer credit. These contracts may be unfair or unclear to the weaker party and may be challenged in court for unconscionability or ambiguity12.

References:

adhesion contract | Wex | US Law | LII / Legal Information Institute

What is a contract of adhesion? A complete guide - PandaDoc

 Access controls are an assurance requirement when an organization is migrating to a SaaS provider because they ensure that only authorized users can access the cloud services and data. Access controls also help to protect the confidentiality, integrity and availability of the cloud resources. Access controls are part of the Cloud Control Matrix (CCM) domain IAM-01: Identity and Access Management Policy and Procedures, which states that "The organization should have a policy and procedures to manage user identities and access to cloud services and data."1 References := CCAK Study Guide, Chapter 4: A Threat Analysis Methodology for Cloud Using CCM, page 751

During the implementation phase of a cloud assurance program, the focus is on establishing the operational aspects that will ensure the ongoing security and compliance of the cloud environment. This includes developing the monitoring goals and requirements which are essential for setting up the assurance framework. It involves determining what needs to be monitored, how it should be monitored, and the metrics that will be used to measure compliance and performance.

References = The information aligns with best practices for cloud migration and assurance programs as outlined in various resources, including the Cloud Assurance Program Guide by Microsoft Cybersecurity1, which discusses the importance of developing and implementing policies for cloud data and system migration, and the Enterprise Guide to Successful Cloud Adoption by New Relic2, which emphasizes the role of observability in cloud migration, including the establishment of monitoring goals.

The auditor’s next course of action should be to review the contract and DR capability of the cloud service provider. The contract should specify the roles and responsibilities of both parties regarding disaster recovery, as well as the service level agreements (SLAs) and recovery time objectives (RTOs) for the critical application. The DR capability should demonstrate that the cloud service provider has a plan that is aligned with the organization’s requirements and expectations, and that it is tested annually and validated by independent auditors. The auditor should also verify that the organization has a process to monitor and review the cloud service provider’s performance and compliance with the contract and SLAs.

Planning an audit of the provider (B) may not be feasible or necessary, as the auditor may not have access to the provider’s environment or data, and may not have the authority or expertise to conduct such an audit. The auditor should rely on the provider’s audit reports and certifications to assess their compliance with relevant standards and regulations.

Reviewing the security white paper of the provider © may not be sufficient or relevant, as the security white paper may not cover the specific aspects of disaster recovery for the critical application, or may not reflect the current state of the provider’s security controls and practices. The security white paper may also be biased or outdated, as it is produced by the provider themselves.

Reviewing the provider’s audit reports (D) may be helpful, but not enough, as the audit reports may not address the specific requirements and expectations of the organization for disaster recovery, or may not cover the latest changes or incidents that may affect the provider’s DR capability. The audit reports may also have limitations or qualifications that may affect their reliability or validity. References :=

Audit a Disaster Recovery Plan | AlertFind

ISACA Introduces New Audit Programs for Business Continuity/Disaster …

How to Maintain and Test a Business Continuity and Disaster Recovery Plan

 The greatest concern to the auditor should be that the customer cannot monitor its cloud subscription on its own and must rely on the provider for monitoring purposes. This situation can lead to a lack of transparency and control over the security and compliance posture of the cloud services being used. It is crucial for customers to have the ability to independently monitor their systems to ensure that they are secure and compliant with relevant regulations and standards.

References = This concern is highlighted in the Cloud Security Alliance’s (CSA) Cloud Controls Matrix (CCM) and the Certificate of Cloud Auditing Knowledge (CCAK) materials, which emphasize the importance of continuous monitoring and the customer’s ability to audit and ensure the security of their cloud services1.

 In a multi-level supply chain structure, the cloud service provider should ensure that any compliance requirements relevant to the provider are passed to the sub cloud service providers, regardless of their geographic location. This is because the sub cloud service providers may have access to or process the data of the provider’s customers, and thus may affect the compliance status of the provider. The provider should also monitor and verify the compliance of the sub cloud service providers on a regular basis. This is part of the Cloud Control Matrix (CCM) domain COM-01: Regulatory Frameworks, which states that "The organization should identify and comply with applicable regulatory frameworks, contractual obligations, and industry standards."1 References := CCAK Study Guide, Chapter 3: Cloud Compliance Program, page 51

 Metrics around Platform as a Service (PaaS) development environments are frequently immature, as PaaS is a relatively new and evolving cloud service model that offers various tools and platforms for developing, testing, deploying, and managing cloud applications. PaaS metrics are often not well-defined, standardized, or consistent across different providers and platforms, and may not capture the full value and performance of PaaS services. PaaS metrics may also be difficult to measure, monitor, and compare, as they depend on various factors, such as the type, complexity, and quality of the applications, the level of customization and integration, the usage patterns and demand, and the security and compliance requirements. Therefore, PaaS metrics may not provide sufficient insight or assurance to cloud customers and auditors on the effectiveness, efficiency, reliability, and security of PaaS services12.

References:

Cloud Computing Service Metrics Description - NIST

Cloud KPIs You Need to Measure Success - VMware Blogs