Case Studies: Compliance

Alice's Private Cloud Alice is building an OpenStack private cloud for the United States government, specifically to provide elastic compute environments for signal processing. Alice has researched government compliance requirements, and has identified that her private cloud will be required to certify against FISMA and follow the FedRAMP accreditation process, which is required for all federal agencies, departments and contractors to become a Certified Cloud Provider (CCP). In this particular scenario for signal processing, the FISMA controls required will most likely be FISMA High, which indicates possible "severe or catastrophic adverse effects" should the information system become compromised. In addition to FISMA Moderate controls Alice must ensure her private cloud is FedRAMP certified, as this is a requirement for all agencies that currently utilize, or host federal information within a cloud environment. To meet these strict government regulations Alice undertakes a number of activities. Scoping of requirements is particularly important due to the volume of controls that must be implemented, which will be defined in NIST Publication 800-53. All technology within her private cloud must be FIPS certified technology, as mandated within NIST 800-53 and FedRAMP. As the U.S. Department of Defense is involved, Security Technical Implementation Guides (STIGs) will come into play, which are the configuration standards for DOD IA and IA-enabled devices / systems. Alice notices a number of complications here as there is no STIG for OpenStack, so she must address several underlying requirements for each OpenStack service; for example, the networking SRG and Application SRG will both be applicable (list of SRGs). Other critical controls include ensuring that all identities in the cloud use PKI, that SELinux is enabled, that encryption exists for all wire-level communications, and that continuous monitoring is in place and clearly documented. Alice is not concerned with object encryption, as this will be the tenants responsibility rather than the provider. If Alice has adequately scoped and executed these compliance activities, she may begin the process to become FedRAMP compliant by hiring an approved third-party auditor. Typically this process takes up to 6 months, after which she will receive an Authority to Operate and can offer OpenStack cloud services to the government.

Bob's Public Cloud Bob is tasked with compliance for a new OpenStack public cloud deployment, that is focused on providing cloud services to both small developers and startups, as well as large enterprises. Bob recognizes that individual developers are not necessarily concerned with compliance certifications, but to larger enterprises certifications are critical. Specifically Bob desires to achieve SOC 1, SOC 2 Security, as well as ISO 27001/2 as quickly as possible. Bob references the Cloud Security Alliance Cloud Control Matrix (CCM) to assist in identifying common controls across these three certifications (such as periodic access reviews, auditable logging and monitoring services, risk assessment activities, security reviews, etc). Bob then engages an experienced audit team to conduct a gap analysis on the public cloud deployment, reviews the results and fills any gaps identified. Bob works with other team members to ensure that these security controls and activities are regularly conducted for a typical audit period (~6-12 months). At the end of the audit period Bob has arranged for an external audit team to review in-scope security controls at randomly sampled points of time over a 6 month period. The audit team provides Bob with an official report for SOC 1 and SOC 2, and separately for ISO 27001/2. As Bob has been diligent in ensuring security controls are in place for his OpenStack public cloud, there are no additional gaps exposed on the report. Bob can now provide these official reports to his customers under NDA, and advertise that he is SOC 1, SOC 2 and ISO 27001/2 compliant on his website.