9 Cloud Security Questions you need to ask Service Providers

Companies in Ireland and the UK who are considering cloud adoption might already have a general idea of the security risks inherent in cloud computing. However, since different providers may not offer the same levels of risk mitigation, it is important to know which providers can give sufficient assurance on cloud security.

Here are 10 cloud security questions to ask service providers vying for your attention.

1. Where will my data be located?

There are a variety of reasons why you will want to ask this question. One big reason is that there are certain countries that don’t have strict legislation (or any legislation at all) pertaining to cloud computing. In that case, the provider won’t be as motivated to apply high levels of risk mitigation.

So if your data is hosted off shore, then you might want to reconsider or at least conduct a deeper study regarding the security conditions there.

2. Do you have provisions for regulatory compliance?

Certain standards and regulations (e.g. PCI DSS and possibly the EU Data Protection Directive) have specific guidelines pertaining to data stored in the cloud. If your organisation is covered by any of these legislation, then you need to know whether your provider can help you meet requirements for compliance.

3. Who will have access to my data?

In a cloud environment, where your data is going to be managed by people who aren’t under your direct supervision, you’ll have to worry as much about internal threats as you would with external threats.

Therefore, you need to know how many individuals will have access to your data. You also need to know relevant information such as how admins and technicians with data access rights are screened prior to getting hired. You also need to determine what access controls are being implemented.

4. How is data segregated?

Since there will be other clients, you will want to know how your data is going to be segregated from theirs. Is there any possibility of an accidental or intentional data breach due to poor data segregation? Find out if your data is going to be encrypted and how strong the encryption algorithm is.

5. How will you support investigative activities?

Sometimes, even if strong cloud security measures are in place, a data breach can still happen. If it does happen, the provider should have ways to track each user/administrator’s activity that can sufficiently support a detailed data forensics investigation.

Find out whether logs are being kept and how detailed they are.

6. Are we protected by a Disaster Recovery/Business Continuity plan? How?

Don’t be fooled by sales talk of 100% up-time. Even the most robust cloud infrastructures can suffer outages too. But the important thing is that, when they do fail, they should be able to get up and running in the soonest time possible.

Don’t just ask about their guaranteed RPOs and RTOs. Find out whether your data and applications will be replicated across multiple sites. Unless the provider says they will be, you need to find a provider with a better infrastructure.

7. Can I get copies of my VMs?

In a cloud infrastructure, your servers are actually in the form of files known as virtual machines (VMs). Because VMs are just files, they should be easily copied. There may be issues though, like the VMs might be stored in a not-so-popular proprietary format. Another possible issue is that the provider may simply not allow copying.

Having copies of your VMs can be useful should you later on decide to transfer to another provider or even duplicate your cloud infrastructure on your own.

8. What will happen to my data when I scale down?

One outstanding benefit of cloud computing is that when your business demands drop, you can easily scale down computing resources and reduce your cloud spending. ?But what will happen to your data when you decommission virtual servers? Will they be discarded?

You might want your data to be retained up to a certain period. On the other hand, you might also want them to be deleted immediately. Ask about the provider’s data deletion/data retention policies and see if they are in line with yours.

9. What will happen to my data if I decide to close my account?

There might come a time when you’ll want to terminate your contract with your cloud provider. Just like in issue #8, you’ll want to find out more about data deletion/data retention policies.

Although some providers can give you detailed answers, many of these answers can include a lot of technical jargon that can leave you totally confused. If you want someone you can trust to:

  • simplify those answers;
  • help you pick the right cloud service provider, and
  • even make sure cloud security is really upheld once your cloud engagement is ?under way

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK

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How to Reduce Costs when Complying with SOX 404

Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.

Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.

SOX 404 in a nutshell

Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.

This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.

Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.

Why compliance of Section 404 is costly

Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.

Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.

According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.

The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.

Read why spreadsheets post a burden when complying with SOX and other regulations.

Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.

Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:

  • Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
  • Companies with revenues between $1B – $4.9B spent about 0.16%
  • Companies with revenues between $500M – $999M spent about 0.27%
  • Companies with revenues between $100M – $499M spent about 0.53%
  • Companies with revenues less than $100M spent a whopping 2.55% on Section 404

Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.

How to alleviate costs of section 404

If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.

Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?

From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.

For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?

It’s really not a trivial problem.

Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.

Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.

For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

Shared Services ? Are They A Good Idea

Things happen fast in business and we need to stay on top. It does not seem long ago that some enterprises were still hands-on traders or artisans with a few youngsters to help out. People like that did not do admin and their accounting was a matter of making sure there was enough money in the jar.

When Wal-Mart’s Sam Walton took over his first shop in 1945 things had moved on from there, although he did still deal directly with his customers. When he died his legacy was 380,000 jobs, and a business larger than most economies. So there?s plenty we can learn from how he grew his business.

One of Sam?s secrets was his capacity to centralise what needed gathering together, while empowering store managers to think independently when it came to local conditions. His regional warehouses had individual outlets clustered around them within one day?s drive each. This shared service eliminated 90% of safety stock and released capital for expansion.

Wal-Mart took sharing services a step further in February 2006, when it centralised accounts payable, accounts receivable, general accounting and human resources administration at Wal-Mart Stores and Sam?s Clubs in the U.S. and Puerto Rico. The objective was to bring costs down, while allowing local managers more time to focus on their business plans and other initiatives. As a further spin-off, Wal-Mart was able to integrate its data on a single SAP platform and eliminate significant roadblocks.

This is an excellent example of sharing services by creating own centres of excellence.? Of course, this is not the only business possibility. Other corporates have successfully completely outsourced their support activities, and Wal-Mart has no doubt had a variety of similar offers too. But, is the Wal-Mart picture entirely rosy, or is there a catch?

The Association of Chartered Certified Accountants has indicated that top talent may be the loser globally. This is because the Wal-Mart model removes many challenges through standardisation, and offers less scope for internal promotion as a result. Language and cultural differences may also have a long-term detrimental effect on the way the departments work well together.

Local outsourcing ? this is the business model where several firms engage a shared service provider independently- may hence prove to be a more malleable option for smaller companies. It often makes more sense to hunt down made-to-order services. Offerings such as the professional support we offer on this site.

Advanced Business Management

Our consultants are highly trained to provide complex management solutions and strategy planning for your business. You can count on us to improve performance and your business skills, while cutting costs.

We ensure full support in a broad range of business management areas, such as:

Business Strategy

Knowing how and when to make the right strategic move is critical to your success in today?s dynamic environment. Our Strategic Management Consultants provide solutions for a tighter integration of your vision, values, and mission statements with the strategic management process.

The result is a stronger alignment of your operating activities with your goals, and also an improved internal infrastructure to support and manage the strategic management process.

Business Process Improvements

In our years of activity, we have developed a robust process to ensure Business Process Improvements projects are implemented successfully. To achieve a positive outcome a number of factors must exist and we?ll make sure your company manages to get the right mix of: sponsorship management and commitment, process improvement goals, right motivations, cultural issues management, provision of adequate resources and funding, and availability of standards and procedures.

Performance Management

An effective performance management system integrates all aspects of the organisation from a shared vision, through a common language, and establishes a culture of accountability and results. It provides more of a holistic way of managing your organization that is more powerful than its individual parts, and without forsaking the values of the organisation.

Change Management Services

Economic downturns, fast rising new competitors, and even climate change, can force companies to scale down, engage in mergers & acquisitions, or transfer to a new location. We?ll help you through every step of the change process, from: evaluating the required change by conducting diagnostics such as change complexity, causal, structural, and context analysis, managing stakeholders including your sponsors, top executives, managers, and personnel, planning for the change, and managing the change process itself.

Project Management

Whether you need help for a single project or much more, we’ve got you covered. With us you get a coordinated, presence-of-mind approach to project management that will point all of your projects to an overall strategic direction, no matter how complex or simple these might be. Our services incorporate all project-related activities including: programme management, project risk management, project review and audit, project rescue, and project governance.

Interim Management

Our resources have an MBA and/or professional accounting qualifications with an average of 10 ? 30 years of progressive work experience with public companies, in complex private equity environments, and/or privately-held middle market companies. We not only offer the most highly qualified project / interim resources to our clients, but we also allow for an interim-to-hire provision in our contracts.

It has proved mutually beneficial to our consultants and clients to have the option for longer term employment opportunities after having worked together on a project / interim basis.

 

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