Cloud compliance is always a hot topic, but recent updates to the HIPAA and PCI regulations, have further enhanced the need to clarify some important points around cloud compliance and regulatory compliance. In this blog post, I would like to address some issues as highlighted in the valuable PCI DSS Cloud Computing Guidelines (available here), around compliance and Infrastructure as a Service cloud computing. (While the trigger is the PCI guideline, the discussion applies to HIPAA as well).
First and foremost, the level of control and your ability as a cloud customer to implement security in your cloud environment is dictated by your cloud type. For example a customer using Software as a Service (SaaS) will have the least amount of control and the SaaS provider will have the greatest level of responsibility for data security, while in Infrastructure as a Service (IaaS), the customer has much more control on data security implemented in his cloud account while the IaaS provider will emphasize “shared responsibility”. And to translate it to compliance: A customer in a SaaS environment must rely heavily on the provider’s compliance (which is either there or not), while in a IaaS environment the customer must take active responsibility for compliance together with tools provided by the IaaS cloud provider.