In this view, virtualization is not a vulnerability, but one of the lines of defense in depth. A virtual machine can isolate a database or other target and its hypervisor can be closely monitored for any sign of intrusion. If such a sign is detected, the virtual machine can be easily shut off from other resources or even shut down, with a clean copy restarted.
The paper, called Mobilizing Intelligent Security Operations for Advanced Persistent Threats, (pdf) illustrates how security professionals, with great effort, can get the upper hand in the arms race between defenders versus attackers.
Puhlmann said a cloud environment can be made as secure as a data center and, when it comes to PCI transactions, "I don't see why they shouldn't become a commonplace" in the cloud. But the PCI standard will have to "adjust itself to the times" before that will be true, he said.
Puhlmann will try to relate security to the process of innovation that is underway, particularly in cloud computing, "which is moving ahead faster and faster. The cloud is a huge disrupter. It's up to us and others to make sure its security is discussed."
Cloud practices that move data between data centers around the world illustrate how archaic the laws governing data management and security have become, he pointed out. In some cases, data arising in Europe can't leave a nation's borders. Canadian healthcare data can't be stored on U.S. servers.
"We have completely conflicting rules of law enforcement," he said, and until Jan. 1, the PCI council hadn't acknowledged that a PCI compliant process could be established, even if part of it was running on a virtual machine.
"Virtualization is just an enabling technology. What's so different with the cloud is the consuming model," with consumers accessing the cloud from a wide variety of locations. The challenge of managing access is about to expand with the advent of many tablets, smart phones and other mobile devices tapping into the cloud.
Only part of the problem is technical complexity. Just as important is getting the people processes straight and having governance in place so the initiator of an operation in the cloud is doing things correctly, he said. Another complexity is lines of responsibility, who's doing what. "Now there are people handling the system and data who are not employed by you. That changes the notion of who works for your company," he noted.
A cloud's APIs need to be secure and only do the things they are designed to do, not leave maneuvering room for interlopers. "It's crucial these interfaces are rock solid," he said.
There's been no publicized breach based on a malformed API but such an event is probably only a matter of time. From Puhlmann's perspective, the cloud isn't inherently insecure, but neither has it matured to the point where users are assured in all cases of its security.