Using cloud services is an increasingly popular business decision; in many cases, a cloud provider can deploy technology in a fraction of the time -- and for a fraction of the cost -- required for a company to set up the same tech internally. This disparity may be due to a lack of in-house expertise, the up-front costs to purchase and deploy the technology or a combination of factors.
However, one thing a cloud provider can't do is relieve you of the responsibility for Payment Card Industry Data Security Standards compliance. While that may seem obvious, I still have merchants ask if outsourcing their cardholder data environments means they don't have to worry about PCI compliance. Unless the service provider has a current report on compliance (ROC) that covers all applicable requirements, the answer is always an emphatic "No!"
The InformationWeek Mobile Commerce Survey asked 895 respondents involved or familiar with their companies' strategies about 13 inhibitors to jumping into mobile commerce. The No. 1 answer: compliance concerns. Part of the problem is that, among nearly 300 of those IT respondents with strategies and timelines for adoption, just 35% say they're very or extremely familiar with PCI Data Security Standards for credit card processing.
Any company on the hook for PCI DSS must review, and if needed, audit, their providers' compliance at least annually. The key is to know how the use of a given cloud service will impact your PCI compliance validation efforts and plan accordingly.
And remember, you must maintain PCI DSS compliance at all times -- not just in time for your Qualified Security Assessor's next visit.
Organizations that take their PCI responsibilities seriously will find that using a cloud provider and staying compliant, while not an insurmountable task, can be a major project. Let's walk through a real-world example. The infosec department for one of our clients found out after the fact that the company had contracted with a cloud services provider to fully manage a second data center. The cloud provider was to supply a variety of managed and professional services, including virtual networks, firewalls and servers (IaaS); database (PaaS); IDS/IPS and file integrity monitoring (SaaS); and security monitoring and incident response (professional services).
download the May 2013 supplemental issue of InformationWeek