CLD-06: Multi-Tenant Environments

There is no evidence of a capability to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network).
• A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) efforts are requirements-driven and governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity and data privacy-specific tools. o Facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers. o Generate security event logs for its clients. o Facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

• Cloud security management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel:
• A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.
• IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements.
• Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.
• Cloud instances of virtual machines are treated no differently from on-premise VM assets, where no dedicated cloud governance process exists.
• Cybersecurity and data privacy requirements for virtual machines are identified and documented.
• IT personnel use an informal process to govern VM images.
• Cybersecurity and data privacy requirements for multi-tenant CSP environments are identified and documented.
• Contracts ensure multi-tenant CSPs:

Cloud Security (CLD) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs.

• Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned.
• A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.
• IT architects, in conjunction with cybersecurity architects:
• A Change Advisory Board (CAB), or similar function:
• A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CC|P-specific.
• Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations.
• A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.
• Contracts ensure multi-tenant CSPs facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.
• Contracts ensure multi-tenant CSPs facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers.
• Contracts ensure multi-tenant CSPs generate security event logs for its clients.

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.