FlyingPenguin has posted a good critique of my earlier post about Amazon’s ISO 27001 certification.

Here’s a succinct correction:

To quote Wikipedia, ISO 27001 requires that management:

• Systematically examine the organization’s information security risks, taking account of the threats, vulnerabilities and impacts;
• Design and implement a coherent and comprehensive suite of information security controls and/or other forms of risk treatment (such as risk avoidance or risk transfer) to address those risks that are deemed unacceptable; and
• Adopt an overarching management process to ensure that the information security controls continue to meet the organization’s information security needs on an ongoing basis.

ISO 27002, which details the security best practices, is not required to be used in conjunction with 27001, although this is customary. I forgot this when I wrote my post (when I was reading docs written by my colleagues on our security team, which specifically recommend the 27001 approach, in the context of 27002).

In other words: 27002 is proscriptive in its controls; 27001 is not that specific.

So FlyingPenguin is right — without the 27002, we have no idea what security controls Amazon has actually implemented.

Greetings from Gartner’s Application Architecture, Development, and Integration Summit. There are around 900 people here, and the audience is heavy on enterprise architects and other application development leaders.

One of the common themes of my interaction here has been talking to an awful lot of people who are using or have used Amazon for IaaS. They’re a different audience than the typical clients I talk to about the cloud, who are generally IT Operations folks, IT executives, or Procurement folks. The audience here is involved in assessing the cloud, and in adopting the cloud in more skunkworks ways — but they are generally not ultimately the ones making the purchasing decisions. Consequently, they’ve got a level of enthusiasm about it that my usual clients don’t share (although it correlates with the reported enthusiasm they know their app dev folks have for it). Fun conversations.

So on the heels of Amazon’s ISO 27001 certification, I thought it’d be worth jotting down a few thoughts about Amazon and the enterprise.

To start with, SAS 70 Is Not Proof of Security, Continuity or Privacy Compliance (Gartner clients only). As my security colleagues Jay Heiser and French Caldwell put it, “The SAS 70 auditing report is widely misused by service providers that find it convenient to mischaracterize the program as being a form of security certification. Gartner considers this to be a deceptive and harmful practice.” It certainly is possible for a vendor to do a great SAS 70 certification — to hold themselves to best pratices and have the audit show that they follow them consistently — but SAS 70 itself doesn’t require adherence to security best practices. It just requires you to define a set of controls, and then demonstrate you follow them.

ISO 27001, on the other hand, is a security certification standard that examines the efficacy of risk management and an organization’s security posture, in the context of ISO 27002, which is a detailed security control framework. This certification actually means that you can be reasonably assured that an organization’s security controls are actually good, effective ones.

The 27001 cert — especially meaningful here because Amazon certified its actual infrastructure platform, not just its physical data centers — addresses two significant issues with assessing Amazon’s security to date. First, Amazon doesn’t allow enterprises to bring third-party auditors into its facilities and to peer into its operations, so customers have to depend on Amazon’s own audits (which Amazon does share under certain circumstances). Second, Amazon does a lot of security secret sauce, implementing things in ways different than is the norm — for instance, Amazon claims to provide network isolation between virtual machines, but unlike the rest of the world, it doesn’t use VLANs to achieve this. Getting something like ISO 27001, which is proscriptive, hopefully offers some assurance that Amazon’s stuff constitutes effective, auditable controls.

(Important correction: See my follow-up. The above statement is not true, because we have no guarantee Amazon follows 27002.)

A lot of people like to tell me, “Amazon will never be used by the enterprise!” Those people are wrong (and are almost always shocked to hear it). Amazon is already used by the enterprise — a lot. Not necessarily always in particularly “official” ways, but those unofficial ways can sometimes stack up to pretty impressive aggregate spend. (Some of my enterprise clients end up being shocked by how much they’re spending, once they total up all the credit cards.)

And here’s the important thing: The larger the enterprise, the more likely it is that they use Amazon, to judge from my client interactions. (Not necessarily as their only cloud IaaS provider, though.) Large enterprises have people who can be spared to go do thorough evaluations, and sit on committees that write recommendations, and decide that there are particular use cases that they allow, or actively recommend, Amazon for. These are companies that assess their risks, deal with those risks, and are clear on what risks they’re willing to take with what stuff in the cloud. These are organizations — some of the largest global companies in the world — for whom Amazon will become a part of their infrastructure portfolio, and they’re comfortable with that, even if their organizations are quite conservative.

Don’t underestimate the rate of change that’s taking place here. The world isn’t shifting overnight, and we’re going to be looking at internal data centers and private clouds for many years to come, but nobody can afford to sit around smugly and decide that public cloud is going to lose and that a vendor like Amazon is never going to be a significant player for “real businesses”.

One more thing, on the subject of “real businesses”: All of the service providers who keep telling me that your multi-tenant cloud isn’t actually “public” because you only allow “real businesses”, not just anyone who can put down a credit card? Get over it. (And get extra-negative points if you consider all Internet-centric companies to not be “real businesses”.) Not only isn’t it a differentiator, but customers aren’t actually fooled by this kind of circumlocution, and the guys who accept credit cards still vet their customers, albeit in more subtle ways. You’re multi-tenant, and your customers aren’t buying as a consortium or community? Then you’re a public cloud, and to claim otherwise is actively misleading.