Cloud compliance is always a hot topic, but recent updates to the HIPAA and PCI regulations, have further enhanced the need to clarify some important points around cloud compliance and regulatory compliance. In this blog post, I would like to address some issues as highlighted in the valuable PCI DSS Cloud Computing Guidelines (available here), around compliance and Infrastructure as a Service cloud computing. (While the trigger is the PCI guideline, the discussion applies to HIPAA as well).

Your cloud type dictates the amount of control you have
First and foremost, the level of control and your ability as a cloud customer to implement security in your cloud environment is dictated by your cloud type. For example a customer using Software as a Service (SaaS) will have the least amount of control and the SaaS provider will have the greatest level of responsibility for data security, while in Infrastructure as a Service (IaaS), the customer has much more control on data security implemented in his cloud account while the IaaS provider will emphasize “shared responsibility”. And to translate it to compliance: A customer in a SaaS environment must rely heavily on the provider’s compliance (which is either there or not), while in a IaaS environment the customer must take active responsibility for compliance together with tools provided by the IaaS cloud provider.

(Source: PCI DSS Cloud Computing Guidelines)

Cloud Encryption and Segmentation Considerations
Unlike a traditional data center, where compute environments (i.e., servers and applications) are physically separated from each other, in cloud computing (SaaS, PaaS, or IaaS) the computing environment is shared between customers, and the customer is required to trust the cloud provider with separation and segmentation of the different virtual environments.

There is, however, another option which is entirely under the customer’s control: encryption and key management are probably the most effective ways of segmenting and separating virtual environments.

Cloud encryption does bring new questions around control with it, specifically who manages the encryption keys? If the cloud provider or your encryption vendor is responsible for the encryption and key management, compliance becomes an issue (how can one guarantee that cloud data is safe different entity has access to the encryption keys – hence to the data).

In such cases, solutions such as Porticor cloud security can significantly help. Porticor’s Virtual Private Data system offers the convenience of cloud-based hosted key management without sacrificing trust by requiring someone else to manage the keys. Porticor uses split-key encryption technology, and simultaneously encrypts the key shares using homomorphic encryption technology – even when they are in use, hence protecting the keys and guaranteeing they remain under customer control and are never exposed. (To read more about Porticor click here for the white paper).

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