Archive for the ‘Assurance / Service Audits’ Category

Colocation Strategies – Perspectives from Data Center World

I was delighted to be invited to speak on security and compliance during the Colocation Tutorial at Data Center World last week in Las Vegas, Nevada.  The tutorial was an all-day session for enterprise data center operations executives – mostly data center operators from large corporations that currently outsource to a colocation facility.  I had the privilege of joining a panel comprising of executives from RagingWire, Equinix, Schneider Electric, Dominion Virginia Power, Transitional Data Center Services, and Neustar.

I wanted to give the readers who were not able to attend the conference or tutorial session some of my key takeaways from the event:

Not all colos are created equal – Fundamentally most individuals think that a colo facility just provides power and space.  However, those of us familiar with the business know that there can be embedded service providers and data centers within data centers.  Then, add a layer of complexity to the increased prominence of real estate companies, such as Digital Realty Trust, that specialize in data center property management.    Lee Tamassia from Equinix provided an excellent overview of the different models from wholesale to retail up to and including cloud services.  Mr. Tamassia then discussed how these models integrate with different data center standards.  I was then able to add onto these comments to discuss compliance responsibility between a data center and its tenants.

Data center operators may not think compliance is #1 priority – Imagine that!  When Jim Leach from RagingWire asked the audience who either managed or was exposed to compliance initiatives on a frequent basis – very few raised their hands.  Make no mistake – everyone expects the environment to be secure and more importantly reliable.  A few participants stated that compliance often was mandated from legal, IT security, or external auditors.  However, the day-to-day activities for these operation executives typically only revolve around topics such as power consumption, utilization, and resources – which affect the bottom line.

Security and compliance should be a topic of focus early on (during the selection and procurement process) – Steve Gunderson from Transitional Data Center Services and Jim Weber from Neustar walked through a template and evaluation process that included looking at security and availability features as well as available audits.  One participant from a manufacturing company stated that “I don’t handle credit card information, but the fact that the data center has gone through PCI, in my mind puts them at a higher level.”

The different compliance and certification acronyms can be confusing – I believe I was able to provide insight with this topic.  At a minimum, the participants walked away understanding that “SSAE 16 certified” was technically incorrect and could be an indication of misleading marketing.  We also discussed HIPAA, FISMA, and how a data center plays a role when its tenants (or the tenants’ customers) are the ones mandated to comply.

In summary, we auditors, just like those in security, can get so ingrained in the details of SOC reporting standards, PCI compliance requirements, FedRAMP authorizations, etc. that we often need reminding of the end-user’s perspective.  This conference brought a lot of insight to the auditor in me, and I hope the attendees took away some tangible recommendations and action points from the Colocation Tutorial.

On May 15th, I get another opportunity to speak – this time at the Uptime Institute conference in Santa Clara, CA. Hope to see you there!

SocialTwist Tell-a-Friend

BrightLine a Sponsor at The Payroll Group’s 2013 Annual Conference in Austin, Texas

 
via BusinesWire

TAMPA, FL— May 2, 2013- BrightLine CPAs & Associates, Inc., a leading provider of attestation and compliance services, is pleased to announce their sponsorship of The Payroll Group’s (TPG) 2013 Annual Conference.  The conference will take place from May 8th through May 11th in Austin, Texas.

The conference is designed to help independent payroll service providers from across the country to reduce overhead costs, share business best practices, and discuss challenges and success stories.  This year’s conference will also highlight the utilization of state of the art technology in providing payroll services.

“BrightLine is honored to sponsor the TPG Annual Conference as we have seen the requests from payroll service providers for SOC  1 examinations and other related compliance services increase in recent years,” said Greg Miller, BrightLine’s attending Principal.  “This will be an ideal venue for us to share the market trends and compliance solutions with payroll providers.”

 

SocialTwist Tell-a-Friend

BrightLine Joins Top Data Center Industry Experts To Discuss “Colocation Strategies Tutorial” at AFCOM Data Center World 2013

Via BusinessWire

TAMPA, FL — April 23, 2013 — BrightLine CPAs & Associates, Inc., a leading provider of compliance and attestation reporting services, will be part of the Colocation Strategies Tutorial Session at the AFCOM Spring Data Center World 2013 conference.  The conference will be held on April 29th, 2013, at The Mandalay Bay Resort and Casino in Las Vegas.

Doug Barbin, a BrightLine Principal, will join a panel of industry experts to discuss best practices for selecting a colocation provider.  He will be joined by leaders from other companies, including RagingWire Data Centers, Schneider Electric, Transitional Data Services, Dominion Virginia Power, Neustar and Equinix.  Mr. Barbin will focus specifically on the various assurance and compliance alternatives available to data center and colocation providers, such as the SOC examinations, PCI validation, ISO certification, and FedRAMP security assessment.

“Our goal in leading the Colocation Strategies Tutorial at AFCOM Data Center World is to educate enterprise IT and data center leaders so they can make informed decisions as buyers of data center colocation,” said Jim Leach, vice president of marketing at RagingWire.  “We are delighted to have Doug share his expertise on the critical topics of security and compliance.”

For more information about the Data Center World tutorials, please visit:

http://www.datacenterworld.com/spring2013/tutorials/

 

SocialTwist Tell-a-Friend

World Lottery Assoc. Accredits BrightLine as Nation’s 1rst Certification Service Entity

Via Business Wire

BrightLine becomes the first US based company accredited by the WLA as an approved Certification Service Entity (CSE)

TAMPA, FLORIDA – BrightLine CPAs & Associates is pleased to announce its approval by the World Lottery Association’s Security and Risk Management Committee (SRMC) to certify compliance with the WLA’s Security Control Standards.  BrightLine is the first US based company accredited by the WLA as an approved Certification Service Entity (CSE) and is now the only CSE in the world that is also a licensed CPA firm, a Payment Card Industry Qualified Security Assessor (PCI QSA) company, ISO 27001 certification body, and FedRAMP 3PAO.

The WLA Security Control Standards help provide confidence in a lottery operation. To retain the confidence of players and other stakeholders, lottery organizations need to develop and maintain a visible and documented security environment. The WLA Security Control Standard incorporates baseline requirements and controls within the organization’s overall security and risk management process – and avoids overlaps with more general security certifications. It provides lottery security professionals with a process to formally manage, update, and continuously improve its security controls.

“BrightLine is well known for performing SSAE 16 examination services, formerly known as SAS 70 audits, to many of the state lotteries,” stated Jason Rhoades, Practice Leader for BrightLine’s WLA SCS certification services. “As a Certification Service Entity, BrightLine provides WLA members with the unique opportunity to obtain both SOC examination services and WLA SCS certification through a single provider.”

Inquiries regarding BrightLine’s WLA SCS certification services can be made by calling 1-866-254-0000 or click here to submit a request for a professional consultation.

About BrightLine

BrightLine CPAs & Associates, Inc. is a leading provider of attestation and compliance services. We are the only company in the world that is a CPA firm, a globally licensed PCI Qualified Security Assessor, an ISO Certification Body, a FedRAMP 3PAO, and a SRMC Certification Service Entity.  Renowned for expertise tempered by practical experience, BrightLine’s professionals provide superior client service balanced by steadfast independence.  Our approach builds successful, long-term relationships and allows our clients to achieve multiple compliance objectives using a single third party assessor.

 

SocialTwist Tell-a-Friend

HR and Payroll Service Providers Benefit from Attestation and Compliance Reports

Source – Workforce Management Channel

Today’s business environment is compliance heavy, under continuous scrutiny and intertwined with customer and legislative requirements. However, companies must still ensure compliance with the myriad of standards, requirements, laws, and regulations, such as SSAE 16 Examination (SOC 1), SOC 2/3 Examination, ISO Certification, FedRAMP Assessment, and hundreds more, across all areas of governance and programs.

As human resource and payroll service providers, or provider of any workforce management solutions, you must reassure customers about the security and integrity of their data stored within your environment. Being able to deliver a level of comfort to customers around financial, corporate, and personal information is the foundation of information security compliance and can be a significant differentiator from competitors.

That said, the compliance method highlighted here is the SSAE 16 examination, also referred to as a Service Organization Control (SOC 1) report. The SOC 1 report is an internationally accepted third party attestation report that is specifically designed for service organizations. A SOC 1 report provides service organizations and customers with a benchmark to compare internal controls and processes to industry standards. SOC 1 examinations are performed when the provider’s services are relevant to their customers’ internal controls over financial reporting. For human resource and payroll service providers, the report would include both information technology controls and transactional controls, for example, to help ensure that records are complete and accurate in recording account balances.

There are two types of SOC 1 reports. The service organization is responsible for specifying whether or not a “Type 1” or “Type 2” will be performed. A “Type 1” SOC 1 examination is performed when management requires a report on the fairness of presentation of the service organization’s internal controls over financial reporting and the suitability of the design of controls as of a specified date. A “Type 2” SOC 1 examination is performed when management requires a report on the fairness of presentation of the service organization’s internal controls over financial reporting and the suitability of the design and operating effectiveness of controls over a period of time, typically six months.

Service providers going through the examination process for the first time may opt to perform a readiness assessment, which simulates a SOC 1 examination. The readiness assessment identifies the controls that are believed to be in place and operating effectively for each applicable objective, and identifies relevant controls that are either not in place, or that are believed to be in place but are judged to be ineffective.

Your company may decide down the path of a SOC 1 report  based on a request or a contract, however don’t let that cloud your views on the several key benefits of obtaining the report:

  • Build trust and confidence with current and potential customers
  • Attain independent, third party assessment of controls
  • Provide a single examination to fulfill multiple customer requests
  • Obtain confirmation that controls in place are as management expects
  • Increase of market share

We have seen the requests for human resource and payroll service providers to obtain a SOC 1 report increase with the heightened awareness of outsourcing risks,  internal controls, data security incidents, regulatory compliance, and contractual obligations. Corporate governance boards and even shareholders want to see third party assurance over companies’ outsourced operations because of the inherent risk of outsourcing business functionality. The most efficient way to give comfort to customers is providing a third party assurance report. As such, many organizations have found it to be worthwhile to complete a SOC 1 examination before customers require it.

 

SocialTwist Tell-a-Friend

Auditing DevOps – Developers with Access to Production

 

DevOps, like Agile development before it, accents the continuous evolving state of software development, particularly in cloud-base software.  Like any technology change, there is no surprise that auditor and security professionals are challenged as the traditional separation of duties line becomes more and more gray.  As someone who oversaw product management in an Agile / SaaS development environment and now manages audits and certifications for leading edge cloud solution providers, I offer my perspective.

Agile and DevOps are similar in the sense that they both emphasize communication, collaboration, and integration among software developers and IT operations personnel.  However, Agile also puts a heavy emphasis on the roles of the product owner (product manager) and end user.  We also must keep in mind that Agile has also been around for several years and has the luxury of multiple documented methodologies and frameworks.

DevOps is a response to the interdependence of software development and IT operations. Its goal is to help an organization rapidly produce software products and services. DevOps has actually been in practice for a few years, although gained US prominence with its use by companies such as Google and Facebook.  A good overview of the newer DevOps concept can be found on Gene Kim’s website as part of a book he, Patrick Debois, and others are is writing on the topic.  There is also a good presentation here.  In short DevOps includes the following key characteristics:

  • Use of Agile development processes
  • Increased collaboration between development and IT operations personnel going as far to create the blended “DevOps” role
  • Rapid and frequent releases (elevation to production), sometimes multiple times throughout the day
  • Increased automation for application development and production management, including heavy use of cloud and virtualized environments
  • Ability for development personnel to access production systems to troubleshoot and remediate issues that arise

So what does this mean to an auditor?  Testing separation of duties is as customary to IT auditing as testing password configurations.  Whether it is PCI, ISO 27001 certification, or an SSAE 16 examination, almost all assessments include some type of comparison between who has the ability to generate source code and who has the ability to promote it to production.  These controls are still important to the fundamentals of IT auditing and the underlying compliance requirements still hold true, that software development controls must provide reasonable assurance against unauthorized changes to production systems.

So now what?  Failed PCI assessments?  Qualified SSAE 16 opinions?  While it is true that separation of duties is one of the common reasons for SSAE 16 report qualifications, it is also an area that BrightLine has seen emerging trends towards heavy use of compensating controls for both SSAE 16 examinations and PCI validation.  The following are some examples:

  • Automated and traceable authorizations for promotion of code to production
  • Role-based access controls that acknowledge when DevOps personnel have access to production systems and document the specific use cases
  • Encryption and logical access controls which essentially “lock-out” the cloud provider from the data of its tenant customers
  • File integrity monitoring (and alerting) on changes to production code versus the traditional focus on critical operating system executable
  • File access monitoring on the source code itself with appropriate alerting
  • Extensive logging and daily, if not real-time, log review of the above data sources

It is important to note that from a monitoring perspective, changes to files must create notifications that span across functional groups.  In other words, a change alert must be sent not only to the DevOps team but to management and/or an independent security or compliance function within the company.  From a process perspective, the increased communication and collaboration inherently creates an environment whereby an unscheduled or unauthorized change is more likely to be noticed.  It goes without saying that there should be a documented follow-up and response process for any such notifications. Furthermore, daily deployments, coupled with necessary roll-back procedures allow the potential impact of an unauthorized change to be reduced.

Several people may argue that some of these compensating controls would be detective in nature and not preventative.  But what is the alternative?  Fail the control, qualify the opinion?  More importantly, was your organization really that much more secure under the traditional waterfall model?

As auditors, we need to do what we are supposed to do – understand the processes, evaluate the controls, identify the potential impacts / risks, and provide an independent report.  Then the users of the reports can make an intelligent decision as to whether or not they were better off with a traditional development methodology.  From my vantage point, DevOps and Agile are here and will continue to be so until a new approach that bends the rules even more is introduced.

 

SocialTwist Tell-a-Friend