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Related Topics: Sarbanes Oxley on Ulitzer

Article

Cloud Security Series | Sarbanes Oxley Compliance

Ensuring SOX compliance for SaaS applications

Security #1 Concern for Cloud Adoption
An analysis of several CIO surveys about cloud adoption reveals two things.

  1. There is a growing adoption toward Cloud Computing
  2. Security concerns remain on top of CIOs' minds

Either as a SaaS provider or an IT services provider who develops applications on PaaS platforms, we should address the security concerns,  and this series of articles aims to do this.

Sarbanes Oxley & Cobit IT Security Controls
In 2001, Congress enacted the Sarbanes-Oxley (SOX) Act of 2002.This act affects how public companies report financials, and significantly impacts IT. Sarbanes-Oxley compliance requires more than documentation and/or establishment of financial controls

COBIT stands for Control Objectives for Information and Related Technology. While the COBIT guidelines have been around since 1996, the guidelines and best practices have almost become the de facto standard for auditors and SOX compliance, mostly because the COBIT standards are platform independent.

While these acts are complex enough  to  have an certified auditor to do the assessment, but there are  much required IT Controls that can be exercised  on  the SaaS Enabled applications or the applications built on PaaS platform.

Certifying the Cloud Applications with these controls  will make a big difference for CEO,CIO of the organizations to have confidence on Cloud sourcing and will act as a big differentiator in winning the clients for the cloud.

1. SOX COBIT  Control /  Changes To Application Configuration & Business Logic

All the configuration changes to the application  whether requested by the Cloud consumer or done by the SaaS Provider should be logged and reported on, some of the important attributes to be logged are :

  • Application level Access Control Changes
  • Which Event Changed the Configuration
  • Date and Timestamp
  • Operation Performed
  • Transaction Type
  • User ID

Who is the Actual User In A SaaS Applcation
In a multi-tenant world,  the Logging of events should be based on the  actual real life user who sit across some part of the globe and issue the commands and not the  internal  software user which actually runs the  script.

For example in a SqlAzure PaaS database , certain configuration script may run with dbo account, but we should log the actual user who triggered the configuration change and not dbo. We need to be careful in  using the built in functions like,  CURRENT_USER to log changes, as these may be internal Sql Server user id and not the physical ID of a person who invoked the command from external to the system.

Ideally the front end application captures the user's identify and  forward the same to the back-end logging process, so that the actual user is logged.

2. SOX COBIT IT Control /  Security Violation Report

All the  attempts for unauthorized  access to the application should be logged and reported. Some of the important information to be logged are,

  • Time Stamp
  • IP Address

In a virtualized environment, some times capturing the IP address using the standard functions may give wrong values which cannot be tracked back, so the actual end user IP address should be trapped and logged. We should consider  capturing details like static IP or a Elastic IP (EC2) which can be traced back rather than virtual IPs which may be assigned and reclaimed over a period.

3. SOX COBIT IT Control / Changes To Application Data
Here is the most important transaction logging of all the important functions of the application, so that we get the complete coverage and accountability of who performed what functions. We should log both the successful as well as failed transactions. Again most of the details that needs to be logged are :

  • Application Menu Option or function that is affected (Like Accounts Payable)
  • Date and Timestamp
  • Operation Performed (Create New Purchase Order)
  • Transaction Type like (Read, Insert, Delete, Update)
  • User ID

4. SOX COBIT IT Control / Fine Grained Access To Data
Apart from  strict authentication and authorization needs, multi tenancy  requires  data segregation among its tenants and also within a particular tenant, so that each user able to see only the data that the user is entitled to look into it. This is  the most important aspect of SaaS security and a strict compliance and adherence and reporting on it is necessary. While there could be some out of the box features that can help in Fine Grained Access (like the Oracle Virtual Private Database),  it is required that the database design itself supports this property so that the application is fully complaint.

Summary
Security compliance on the ground rules of SOX/Audit and other governing acts is very important for any enterprise application and for Cloud enabled application it is even more important and in fact an utmost priority.  There should be no tolerance on auditing, logging and reporting aspects of the SaaS applications and  a 100% compliance only will enforce  confidence and a more rapid adoption of Cloud.

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Highly passionate about utilizing Digital Technologies to enable next generation enterprise. Believes in enterprise transformation through the Natives (Cloud Native & Mobile Native).