Cloud Risk and Compliance Issues Analysis

As an IT analyst for BallotOnline, a company providing voting solutions to a global client base, you are working to convince the organization to move the current infrastructure to the cloud.

Your supervisor and the director of IT, Sophia, has asked you to summarize for the company executives the potential risks and compliance issues that BallotOnline will have to contend with in the transition to the cloud.

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The final report will be seven to 10 pages that convey your understanding and management of risks associated with cloud computing, as well as ensuring compliance with legal requirements involved in moving BallotOnline systems to the cloud.

 

Step 1: Research Risks Associated With Cloud Adoption

The first step in assessing risk in cloud computing will be to identify and describe risk concepts and cloud computing risk factors associated with cloud adoption. As a software as a service (SaaS) company considering an infrastructure as a service (IaaS) cloud service provider for your hosting needs, consider third party outsourcing issues and the generally accepted best practices for cloud adoption and review relevant cloud risk case studies. You should also consider best practices for cloud adoption.

As part of the risk management process, identify and describe other types of risk, such as risks associated with having a service-level agreement (SLA). An example of a potential risk could be if your company is obligated to protect personal information, and then the cloud provider that you use suffers a security breach exposing that personal information.

 

Step 2: Identify the Most Appropriate Guidelines for Managing Risks

In order to identify guidelines applicable to your company’s industry, you must have an understanding of the different types of risk management guidelines that exist and are frequently applicable in cloud environments.

There are several cybersecurity standards applicable to cloud computing environments such as the NIST Cybersecurity Framework, ISO standards, and US federal government standards (DoD/FIPS), as well as several major sets of risk guidelines for dealing with the risks involved. Also, there are organizations such as the Cloud Security Alliance (CSA) that recommend best practices for managing risks.

Review the different guidelines and determine which are most appropriate for BallotOnline. For example, NIST has responsibility for developing a number of elections industry guidelines within the United States.

Identify why those guidelines are most appropriate and compile these items into a brief (one page or less) recommendation and justification of your choice. Your recommendation will also be incorporated into your final report in the final step.

 

Step 3: Identify Potential Privacy Issues and Mitigation Measures

Now that you have identified the guidelines most applicable to your organization, it is time to discuss privacy protections that may apply.

BallotOnline is now a global organization and may need to contend with several sets of privacy laws since these laws vary from country to country.

Sophia has recommended that you focus on European Union (EU) privacy requirements for now, including the General Data Protection Regulation (GDPR), since those are considered to be the most challenging for compliance. Many companies opt to host data for their European customers entirely within facilities in the European Union, and the companies implement restrictions to prevent data for EU citizens from crossing borders into non-EU zones. This is the approach that you have been asked to take and where you should focus your efforts. Note that some cloud providers, such as Amazon, have received special approval from EU authorities to permit data transfer outside of the EU.

Research EU privacy requirements, identify the requirements that apply to your project and why they apply, and compile your recommendations for complying with these requirements. These will be incorporated into your final report.

 

Step 4: Create Risk Management Matrix

Now that you have identified and described the types of risks that may apply to your organization, create a risk management matrix to assess/analyze that risk and make recommendations for risk mitigation measures.

This Sample Risk Assessment for Cloud Computing will give you an example of a completed risk matrix.

 

Step 5: Describe Cloud Security Issues

Now that you have completed the risk analysis, you can start to identify cloud and network security issues that may apply in BallotOnline’s operating environment, including data in transit vulnerabilities and multifactor authentication.

Consider cloud computing risks, network security design, information security, data classifications, and identity management issues. Your findings will be incorporated into your final report.

 

Step 6: Examine the US Legal System and Intellectual Property Laws

Now that you are familiar with security issues, examine and review the US legal and justice systems. Since BallotOnline is a software as a service (SaaS) company based in the United States and serving a customer base in the United States, you need to understand how the legal and justice systems work in the United States. Your basic understanding of these systems is crucial for understanding the complexities of the legal system in cyberspace, where cloud-based systems reside.

As a practitioner working in the cloud computing field, you should also have an understanding of the complexities of intellectual property law and cyberspace law, including how to identify different venues and methods for resolving disputes (such as the court system, arbitration, mediation), how to define and negotiate cloud hosting agreements to avoid potential cyberspace law issues, how to discuss the regulation of cyberspace, and how to handle electronic agreements and digital signatures.

To gain a better understanding of how cyberspace laws are applied to real issues, participate in the analysis of a relevant legal case with your colleagues in a forum titled Discussion: US Legal System and Cyberspace Law.

 

Step 7: Use Frameworks to Analyze Complex Legal and Compliance Issues

In the previous step, you examined the US legal and justice systems as a building block for understanding the complexities of the legal system in cyberspace, where cloud-based systems reside.

There are several frameworks for analyzing compliance issues used to analyze these complex issues. To provide a manageable set of recommendations to the executives, review the frameworks and select the one that is most helpful to use for analyzing these complex issues.

 

Step 8: Analyze General, Industry, Geographic, Data, and Cloud-Specific Compliance Issues

In the previous step, you examined the complexities of law in cyberspace. In this step, you will expand your understanding of legal and compliance issues related to the cloud by investigating industry-specific compliance issues, geographic-specific compliance issues such as privacy, and cloud-specific compliance issues to determine which are applicable to BallotOnline.

You will also need to analyze data compliance issues applicable to companies operating in the European Union, including the recent GDPR regulations, and determine how BallotOnline can be compliant. The organization is concerned about EU compliance issues because the laws there are the most restrictive that BallotOnline will encounter.

 

Step 9: Create a Proposal for a Compliance Program

In previous steps, you have identified potential legal and compliance requirements that BallotOnline may face in migrating to a cloud computing model. Now, you need to determine how BallotOnline can comply with those requirements.

Create a high-level proposal for a compliance program for BallotOnline that enables the organization and its employees to conduct itself in a manner that is in compliance with legal and regulatory requirements. Management has asked you to model the proposal on existing compliance programs for other companies that have migrated to the cloud.

 

Step 10: Write the Final Risk Assessment and Compliance Report

As you have learned, there are a number of legal and compliance requirements associated with shifting to a cloud computing model.

It’s time to put everything together in a seven- to 10-page report for BallotOnline executives: summarizing the risk assessment and mitigation as well as legal and compliance requirements associated with moving to the cloud, outlining your recommended action plans for meeting those requirements, and developing a high-level proposal for a compliance program to avoid breaches of the requirements.

Use the final risk and compliance report template to complete your report.

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