The Impact Of EU Cyber- Security Act On Cloud
The impact of EU CyberSecurity Act on CloudDaniele Catteddu, CSA Chief Technology Officer
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CSA’s activities in Cloud Assurance andCertification
BackgroundThe EU Cybersecurity Act (EUCA) sets the ground to establish an EUframework for cybersecurity certification of ICT product and servicesOne of the objectives of the EUCA is to increase the level of trust in ICTservices and products by introducing an EU-wide security certificationproviding for common cybersecurity requirements and evaluationcriteria across national markets and sectors.ENISA will play a key role. It has been tasked with developing andmaintaining a cybersecurity certification framework, building onexisting best practices, with a view to increasing the transparency ofthe cybersecurity assurance of ICT products, ICT services and ICT
Certification Scheme: the Process
Proliferation of Schemes
Lack of Clarity
Uneven Landscape
Levels of Assurance – Art. 52 Basic: “a level which aims tominimise the known basicrisks for cyber incidents andcyber attacks.” Substantial: “a level whichaims to minimise knowncyber risks, cyber incidentsand cyber attacks carried outby actors with limited skillsand resources.” High: “level which aims tominimise the risk of state-ofthe-art cyber attacks carriedout by actors with significantskills and resources”BasicSubstantialHigh
CSPCERT WGThe Cloud Service Provider Certifications Workinggroup (CSPCERT WG) was created on December 12th2017 to provide expert recommendations to theEuropean Commission for a scheme on cybersecuritycertification of cloud services.The objective of the CSPCERT WG is to explore thepossibility of developing a European CloudCertification Scheme in the context of theCybersecurity Act and come up with arecommendation that will be presented to theEuropean Commission and ENISA.
Assurance Dimensions
Recommendations: Assurance LevelsThe assurance level shall be commensurate with the level of the riskassociated with the intended use of the cloud service.ENISA should provide a clear guidance on: tailored description of what the basic/substantial/high assurance levelindicate, and examples of which level of assurance should be associated to whichservices.
Recommendations: Evaluation CriteriaThe evaluation criteria (AKA security controls/requirements) should bebased on a taxonomy so to allow the mapping between existinginternational standards and certifications (SecNumCloud, C5, ISO 27017,ISO 27018, CSA CCM, and NIST 800-53).ENISA should create EU taxonomy so as to remain flexible for futureupdates, modifications or additions to new or existing internationalstandards and certifications.
Recommendations: Evaluation CriteriaA baseline certification that could optionally be enhanced with furtherregulatory requirements coming from regulators, supervisors or theindustry such as: GDPR certifications, Outsourcing requirements from the EBA, e-evidence, eIDAS, e-privacy ETC
Recommendations: Conformity AssessmentThe CSPCERT WG proposes 3 suitable conformity assessment approaches: Evidence Based Conformity Assessment ISO-based ISAE-based (assurance-based)The objective is to: reduce the level of auditor bias ensure that the level of trust provided by conformity assessment bodiesand individual auditors is within acceptable ranges everywhere.
Recommendations:Assessment For Assurance levels High andConformitySubstantial an annualaudit is a min.requirement. For High level it is recommended to adopt a continuous auditing approach soto increase the frequency of the evaluations and ensures a level of assurancethat goes beyond “point in time” or “over-a-period-of-time”. Audit must measure operational effectiveness, and not merely controlexistence. ENISA should clarify what would trigger a new out-of-cycle review.
Conclusions The current cloud certification landscape suffers of issues, such us: proliferation of schemes,lack of clarify, difficulties to compare existing schemes, lack of guidance of which scheme issuitable for what level of assurance.The cloud certification framework under the CyberSec Act should: Foster simplification and clarity Guide private and public companies to obtain the right level of assurance Increase user’s trust in cloud services Facilitate free flow of data and support competitivenessLikely the new cloud framework: Wont increase the compliance effort of mature CSP Will force less mature CPS to improve their security posture Increase the level of transparency and accountability across the cloud supply chain
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Helpful LinksV I A W W W. C L O U D S E C U R I T YA L L I A N C E . O R GCloud Controls MatrixCSA ps/cloud-controlsmatrix/# downloadshttps://cloudsecurityalliance.org/star/# overviewOpen Certification FrameworkGDPR Center of g-groups/opencertification/# ource-center/EU-SEC Projecthttps://www.sec-cert.eu 2019 CLOUD SECURITY ALLIANCE
Contactdcatteddu@cloudsecurityalliance.orgSeattle Bellingham Berlin SingaporeVisit us on the web atwww.cloudsecurityalliance.orgFollow and like us @cloudsa 2019 CLOUD SECURITY ALLIANCE
Resources CLOUD CONTROL MATRIX: rolsmatrix/# overview STAR PROGRAM OVERVIEW: https://cloudsecurityalliance.org/star/# overview CSA STAR REGISTRY: https://cloudsecurityalliance.org/star/# registry EU-SEC Project: https://www.sec-cert.eu CSA Code of Conduct for GDPR public-registry/ CSA GDPR Center of Excellence: https://gdpr.cloudsecurityalliance.org
risks for cyber incidents and cyber attacks.” Substantial: “a level which aims to minimise known cyber risks, cyber incidents and cyber attacks carried out by actors with limited skills and resources.” High: “level which aims to minimise the risk of state-of-the-art cyber attacks carried out by actors with significant skills and .
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