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CFIT Meeting June 17, 2011 Cloud Assurance “Going forward, we’ll see complete self-service and agility — as a user you should have the quickest, shortest path to getting whatever you want. This shift has been coming in bits and pieces, but now they’re coming together.” Shekar Ayyar, Head of Strategy, VMware “The transformation to a true ‘digital enterprise’ will be the business challenge of the next decade. To achieve this, I see the implementation of a flexible, software based process layer across company departments, suppliers, and partners as the key enabling technology. This transformation has already started and today we are radically changing the way our customers do business. We are opening a whole new world of business models and business opportunities to them.” Karl-Heinz Streibich, CEO, Software AG Entire industries are going through a transformation that leverages cloud capabilities… and with any transformation comes the need to manage change and mitigate risk Business benefits Enhanced customer expectations Strategy Structure People Process Revenue growth Risk and compliance Cost reduction New business models Technology Cloud Computing PwC Consumer loyalty Why “Go Cloud?” • • • • Cost Savings Innovation Agility Efficiency Business Imperative Benefits • • • • PwC Customer Expectation Industry Shift New revenue streams Scalability 3 Realization that the cloud changes industry Yesterday Today 2000: At $6B Blockbuster declined to purchase Netflix $50M for (2011: now Blockbuster is for sale for $290M) Blockbuster owes Tomorrow Downstream It’s more than the Internet technology. Traffic It’s the reality 20% of the need to innovate, Netflix users $21.6M Fox $20M Warner transform and 9.89% $13.3M Sony optimize businesses. Closed 1/3 stores Youtube users + It’s the business partner's need to change interactions and expectations as a result of cloud-based businesses change. PwC Source: Business Insider “How Netflix Bankrupted And Destroyed Blockbuster”, March 2011 Recent predictions of Cloud Computing growth “MarketsandMarkets.com predicts that the global cloud computing market is expected to “Cloud Computing was the #1 inquiry topic from Gartner grow from clients in 2010.” “At the Cloud Connect conference Vijay Bhagavath, technology equity researcher for Deutsche Bank, estimates investment in ‘private clouds’ could be a $20 billion dollar opportunity by 2012.” “Gartner predicts that by 2015, 80% of enterprises using external cloud services will demand independent certification that providers can restore operations and data. “ “Gartner predicts by 2015, 20% of non-IT Global 500 companies will be cloud service providers.” “Joe McKendrick at ZDNet states that “very soon, a third of all software will be delivered via cloud. PwC $37.8 billion in 2010 to $121.1 billion in 2015 at a CAGR of 26.2% from 2010 to 2015.” “Infonetics Research is forecasting spending on security-related SaaS applications will experience a compound annual growth rate of 31% through 2014.” “Renub Research predicts Worldwide Cloud Computing market is growing at a rapid rate and it is expected to cross $25 Billion by the end of 2013 .” 5 Managing Change in Moving to the Cloud Moving to the cloud requires ongoing preparation, planning, management and oversight Adapt capabilities of personnel Assess change in control and compliance Establish new responsibilities PwC Have a clear understanding of the current process Clearly articulate the expected outcome and benefits of the move Identify, communicate and address lost capabilities You still maintain responsibility of processes after the move 6 Managing Change in Moving to the Cloud Adapt capabilities of personnel • Depending on the “XaaS” cloud offering, the nature of processes moved to the cloud may require different skills internally Have a clear understanding of the current process • Moving to the cloud successfully means not losing any capability. Understand current outcomes, including governance and control Clearly articulate the expected outcome and benefits of the move • Service level agreements should reflect specific expectations for services, metrics and responses for non-achievement Identify, communicate and address lost capabilities PwC • With standardization of most “XaaS” solutions, changes in internal processes may be needed to fill any gaps Establish new responsibilities • Update job descriptions, training, performance metrics and documentation Assess change in control and compliance • Inventory requirements to determine information and control assessment needs from service provider 7 Cloud Assurance – Setting the Stage Cloud computing’s potential to lower IT costs and boost efficiencies is unprecedented, however, the reliability of cloud service providers is all but unmeasurable. In PwC’s 2011 Global Information Security Survey, 14% of respondents who had experienced a data breach cited negative impact to brand or reputation—a business impact that has increased 180% in the past three years. Recent examples of data loss, data privacy breaches and availability – Epsilon, Sony Entertainment, Amazon EC2 – to name just a few, continue to remind cloud consumers of the risks. For many organizations, the risk to brand reputation is simply too big to ignore. Among customers, concerns about the cloud’s risks – security, privacy, availability, and data protection, to name a few – have created an atmosphere in which uncertainty and risk are top of mind. Currently, there is no comprehensive framework for cloud controls that enables potential cloud customers to confidently assess and verify a cloud provider’s controls and environments. This lack of reliable control framework has opened a trust gap between cloud providers and customers, and that has impeded the advance of cloud computing. PwC 8 Cloud Assurance – What exists today Currently, most cloud customers are gathering information through a series of highly inefficient activities often led by vendor management or procurement functions: • Provider self-assessments, typically focus on security policies • Responses to customer-prepared questionnaires • Service level agreements (SLAs) describing the provider’s obligations • Third-party SAS 70 (now SSAE 16) reports • Other certifications – PCI, ISO 27002, HIPAA, FISMA, etc. These efforts have been largely unsuccessful because they do not address comprehensively address the service offering and the relevant compliance requirements from the perspective of the customer’s needs or expectations • A globally recognized framework of controls and standard for reporting may come in time, but cloud adopters need something sooner PwC 9 Cloud Assurance – Looking forward Consideration Point AICPA Service Organization Reports SOC 1 / SSAE16 (Replacement for SAS70 6/11) AICPA suggested scope Controls relevant to report users’ financial statements SOC2 Custom Attest SOC3 Controls relevant to compliance or operations, which could include (*) •Security •Availability and processing integrity •Confidentiality •Privacy •Data integrity and ownership (*) Use of AICPA Trust Principles Required Management defined Can include controls relevant and unique to •Operations, •Billing, •Technology •Security, •Privacy •and beyond Intended Audience Restricted; limited distribution General Use (with public seal); unrestricted distribution Generally restricted distribution but may be unrestricted Content of Report •Description of service organization's system •Description of controls •PwC opinion on: •fairness of presentation of description •Control Design (Type I and II) •Control Effectiveness, including description of PwC’s test of controls and results (Type II only) •Unaudited system description •PwC opinion of controls effectiveness •Description of mgmt assertions & control objectives •List of criteria PwC evaluated •Description of controls •PwC opinion AICPA Audit Standard SSAE 16 PwC AT 101, Attest Engagements 10 Summary - Plan for Success • Understand rationale for adopting cloud • Engage with relevant functions leaders to identify changes • Review impacted business activities in ‘as is’ and ‘to be’ state • Assess capabilities of existing personnel to manage transition and to perform roles in new state • Treat the move as a “process” not a project • Assess risk and build a plan to manage accordingly PwC 11 Thank you Cara Beston Cloud Assurance Partner [email protected] Cara is the National Technology sector leader for PwC’s Risk Assurance practice based in San Jose, CA. She is also a member of PwC’s national Cloud Action Committee and the firm’s representative to the Cloud Security Alliance. She specializes in IT and process risk and control assurance services to IT, Internal Audit, finance and business leaders in the Technology sector. Prior to joining the Risk Assurance practice, Cara has spent 15 years serving the financial accounting and reporting needs of clients across a broad array of clients and sectors including manufacturing, real estate, financial services and technology. In her 2w years with PwC, Cara has served over 80 technology clients, including key Cloud enabling enterprises, Cisco Systems, VMware, 3Par, SaaS providers, and a number of on-line businesses including Shutterfly, CBS Interactive, Zappos.com and others. Cara graduated summa cum laude from Bridgewater College, MA and is a member of the AICPA. She lives in Pleasanton, CA with her husband and 3 children. PwC 12