Software program as a Service (SaaS) has gone from the innovative to a core know-how for a lot of companies. However given the large scope of cloud providers firms have interaction in below the umbrella of SaaS, additionally it is essential to know the attendant dangers these providers current. This text describes these dangers in addition to one of the best practices for controls accessible to managers.
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Now not an rising or potential know-how, cloud computing is now a vital answer for a lot of organizations. This know-how various supplies Software program as a Service (SaaS) customers with the pliability to adapt to quickly altering demand whereas offering managers with various monetary options that facilitate introducing or enhancing service supply methods. The associated fee for these advantages could embrace the SaaS consumer compromising on how know-how dangers are addressed. Earlier articles (see the sidebar, Background Studying on Cloud Computing) have supplied readers with cloud computing foundations and basic danger administration approaches for assessing cloud environments. This text supplies readers with a extra direct understanding of the SaaS-related cloud computing actions that they could have interaction in, and the resultant dangers that require administration’s consideration to attain the specified advantages and enterprise targets.
Non-technology division customers (typically known as “finish” or “enterprise” customers) are most definitely to interface immediately with a SaaS answer, because it incessantly represents an software or knowledge processing exercise immediately below the enterprise consumer’s purview. SaaS providers embrace e-mail and workplace instruments (e.g., Workplace 365 or Google Workspace). Enterprise accounting and monetary administration software program, akin to SAP, NetSuite, and Oracle Financials, presents a SaaS supply mannequin, as do Intacct, Xero, and Quickbooks within the small and midsize enterprise market. Different well-known software program firms present SaaS fashions which have change into integral to enterprises, together with Salesforce, Slack, ServiceNow, Github, and Workday. It’s the authors’ expertise that the bigger SaaS consumer organizations that may afford to make one of the best use of those options additionally present danger administration oversight of those distributors.
But a big good thing about SaaS contributes to heightened danger administration considerations, particularly when the answer’s use falls outdoors the enterprise-wide purview, as a result of SaaS options don’t require the preliminary capital expenditure and oversight required by conventional software program options. For instance, an govt can decide what to purchase and which know-how instruments to make use of, particularly in a decentralized group that shifts decision-making and supporting buying energy away from central administration and management. With a manageable subscription price that may circumvent the actions of know-how steering committee and established coverage limits on capital expenditures, the manager can introduce the know-how with minimal interference from danger administration and compliance officers. Sadly, the danger is just not restricted to spending; the better publicity is the storage and processing of information by an unvetted or unmanaged SaaS vendor or service group whose actions might negatively impression the SaaS consumer’s popularity and, in some instances, its survival.
SaaS Computing is an Enterprise-wide Threat
In some ways, SaaS computing represents the priority expressed within the Committee of Sponsoring Group’s (COSO) Enterprise Threat Administration framework of a danger “in a single a part of the entity however impression a unique half. Consequently, administration identifies and manages these entity-wide dangers to maintain and enhance efficiency” (COSO Enterprise Threat Administration Govt Abstract, p. 3). Threat managers should tackle the inner political problem of business-line executives migrating purposes from on-premises legacy purposes to SaaS that will profit their line of enterprise (and bonuses). They accomplish that to a third-party entity over which the group could have little to no sensible management or affect. Different enterprise items could depend on the output generated by the enterprise unit partaking the SaaS vendor or service group with no assurance over the standard of knowledge, nor the safety, availability, and confidentiality of such info, utilizing the SaaS consumer’s requirements and expectations.
Information integrity.
In consequence, the integrity of the info processed and saved by the entity could increase dangers in different enterprise items. In a graduate course at Texas A&M Regulation College, Richard Kravitz describes the challenges going through enterprise danger managers making an attempt to mitigate these threats particularly after they end in “black swan” occasions:
Aircraft crashes, oil spills, the Lehman Brothers meltdown, Colonial Financial institution, the bankruptcies of insurance coverage firms like Penn Treaty … the sale of illiquid insurance coverage portfolios to 3rd events by MetLife… Three Mile Island, the Challenger and Fukushima all have one thing sadly in widespread from a danger administration perspective. Underlying these entities are complicated methods whose integration is rarely totally examined or below one centralized danger administration command—separate methods with separate subcontractors who could have carried out methods at completely different instances leading to cross-functional errors that any person could overlook. Advanced, disaggregated methods could have imperfect controls, lack redundancy, or can’t talk throughout disciplines, departments, or methods—and, as a consequence, exponentially create catastrophic danger; these are the widespread parts that bind all of those failures. Threat managers don’t give attention to catastrophic failure and mitigate it. Separate subcontractors often develop these methods, and the result’s that executives overlook cross-functional danger mitigation as a result of there isn’t a central oversight over all of those disaggregated, disconnected actions. Even the senior company govt doesn’t perceive the necessity for a centralized cross-functional danger administration. (dialog with the authors)
With cloud computing on the whole, and SaaS specifically, executives face challenges much like these described above. When one SaaS vendor or service group acquires one other, or two merge, it may possibly take years to combine the assorted software program instruments successfully. Unsophisticated SaaS customers could consider that as a result of two completely different options share the identical company mother or father, integration and interface between the 2 options are doable with out particular assurances associated to the SaaS software. Expertise integrators or contractors often assume processing integrity when combining SaaS purposes to justify minimizing time commitments. Many executives consider gross sales pitches from SaaS distributors that danger is minimized as a result of the appliance runs on a widely known cloud infrastructure (e.g., AWS, Azure, Google Cloud).
For a lot of, using SaaS has change into an enterprise-wide concern with rising consideration from the danger administration group. In its “2022 Cloud Safety Survey Report,” the Cloud Safety Alliance, a well-respected trade group, reported that “on common, organizations report utilizing 102 purposes. The utmost variety of purposes reported was over 5,000” (p. 3).
From an enterprise danger administration (ERM) perspective, operations, reporting, and compliance are the three classes of enterprise targets, and SaaS computing represents dangers to every.
Operational danger.
For instance, an operational danger could be relying upon a SaaS vendor or service group that provides enterprise analytics providers that generate info to assist in advertising and marketing funding choices. If the info generated by the SaaS vendor or service group is unreliable, the danger {that a} SaaS consumer could not obtain its gross sales targets could be elevated. The management on the enterprise to scale back this danger could be shut and frequent monitoring of gross sales traits earlier than and after implementing the SaaS vendor or service group’s enterprise analytics providers. The outcomes could be in comparison with administration’s expectations; if expectations weren’t met, there ought to be an investigation as to “why.”
Reporting danger.
An instance of a reporting danger could be an organization that utilized a SaaS vendor or service group to document, course of, and report monetary info. This SaaS consumer determined to terminate the contract with the SaaS vendor or service group and transfer to a competitor. Upon informing the previous SaaS vendor or service group that they wanted emigrate their knowledge to a brand new vendor or service group, the previous vendor or service group knowledgeable the consumer that in accordance with the settlement, the previous SaaS vendor or service group, not the SaaS consumer, owned the info. If SaaS customers needed emigrate the info to a different platform, they must purchase it again from the previous SaaS vendor or service group. This case dragged on because the SaaS consumer and the previous SaaS vendor or service group negotiated over the discharge of the info. When it got here time for the annual monetary audit, the SaaS consumer didn’t have entry to their knowledge, had no accounting information, and was unable to generate monetary statements. That’s the reason a current American Bar Affiliation article advisable that prospects clearly state of their agreements that they personal the info and at all times have entry to it (“SaaS Agreements Key Contractual Provisions,” Enterprise Regulation In the present day, H. Ward Classen, November 15, 2021, https://bit.ly/3SGWIBj).
Compliance danger.
Take into account the instance of an insurance coverage firm or monetary establishment that makes use of a SaaS vendor or service group that makes use of synthetic intelligence (AI) to make choices akin to whether or not to just accept or deny an software for insurance coverage or a mortgage. If the SaaS service group’s vendor or service group’s AI system is biased, whether or not deliberately or not, and sure protected courses are denied insurance coverage or loans, the insurance coverage firm or monetary establishment could possibly be in noncompliance with antidiscrimination legal guidelines, guidelines, and laws and topic to fines, penalties, class motion lawsuits, and reputational injury. The management to scale back the danger is for the insurance coverage firm or monetary establishment to carry out their very own evaluation of the selections to determine the presence or lack of bias.
SMEs Are Particularly Susceptible
Too typically, small and medium-size entities (SME) give attention to the advantages of what SaaS can present however not on their dangers, which should be understood and managed. Many SMEs depend on distributors to assist facilitate SaaS options. Typically, these efforts are centered on gross sales and implementation. Sadly for SMEs, they could not have entry to expertise or assets that would assist them appropriately assess these distributors and oversee their efficiency as soon as implementation happens. They have to cope with a scaled-down model of bigger firms’ enterprise points, however they need to additionally try to take action with much less subtle expertise. For instance, many SMEs could not recognize the nuances of contract phrases or the wordsmithing of controls represented by aggressive distributors.
Managing Cyber and Data Safety Threat
Earlier CPA Journal articles (see the sidebar, Background Studying on Cloud Computing) addressed the cyber-security implications of cloud computing. As one of many three main fashions of cloud providers, SaaS shares lots of the cybersecurity threats relevant to all cloud providers. One distinctive side of SaaS in contrast with the opposite cloud service fashions [e.g., Infrastructure as a Service (IaaS), Platform as a Service (PaaS)] is the involvement and possession of the connection in SaaS consumer organizations by a enterprise govt fairly than a know-how govt.
As a result of nature of providers supplied, the know-how govt is often the first govt liable for IaaS and PaaS relationships. Expertise professionals, many with no less than some information of cybersecurity or info safety, help the manager in managing the connection. In lots of instances, the enterprise govt, fairly than the know-how govt, maintains the duties for the connection for the enterprise. Though cybersecurity specialists could also be consulted on the enterprise govt’s choice, incessantly they don’t seem to be. Sadly, the cloud-shared accountability mannequin requires important involvement for SaaS customers for knowledge classification, endpoint safety, identification/entry administration, application-level controls, and safety structure.
Though a lot of the literature has historically centered on cloud computing dangers on the whole, fairly than SaaS specifically, the rising demand and use of SaaS is starting to vary this. Customers entry SaaS providers by means of the Web. Threat managers reply to this inherent danger by rising consideration to cybersecurity and knowledge safety issues. These issues embrace defending knowledge at relaxation or in transit (often by means of encryption), guaranteeing acceptable entry controls, utilizing log evaluation purposes, and deploying vulnerability scanners. But, in accordance with the 2021 Thales International Cloud Safety Research, commissioned by Thales and carried out by 451 Analysis, “40% of organizations have skilled a cloud-based knowledge breach prior to now 12 months. Regardless of rising cyber-attacks focusing on knowledge within the cloud, the overwhelming majority (83%) of companies are nonetheless failing to encrypt half of the delicate knowledge they retailer within the cloud, elevating even better considerations as to the impression cybercriminals can have” (https://bit.ly/3A6NzLd). Given the accountabilities for knowledge mentioned above, this statistic implies that knowledge classification, endpoint safety, application-level controls, and safety configuration might have stronger oversight from SaaS consumer executives.
Background Studying on Cloud Computing
“Managing the Influence of Cloud Computing—Views on Vulnerabilities, ERM, and Audit Providers,” by Meredith Stein, Vincent Campitelli, and Steven Mezzio, June 2020. The article checked out figuring out cloud computing alternatives and operationalizing cloud actions. It additionally outlined the stakeholders concerned within the enterprise’s danger administration technique and shared accountability mannequin. The article supplied recommendation on managing the disruption attributable to the adoption of cloud computing and lowering dangers going through cloud customers. The article pressured the impression of cloud computing on ERM methods and actions. Steerage for CPA corporations and practitioners was additionally offered.
“Cloud Computing Buddy or Foe?” by Joel Lanz, June/July 2021. The article supplied a extra technical overview, describing the completely different cloud service supply fashions and cybersecurity considerations and discussing the shared accountability mannequin used to assist differentiate cloud vendor or service group and consumer duties. The article additional mentioned cybersecurity issues for every of the cloud service supply fashions. It additionally addressed regulatory and compliance cloud issues.
Based on the Cloud Safety Alliance’s 2022 SaaS Safety Survey Report (https://bit.ly/3bD7fwP), “many current breaches and knowledge leaks have been tied again to misconfigurations, inflicting it to be a prime concern for a lot of organizations. Most analysis associated to misconfigurations has centered strictly on the IaaS layers and ignores the SaaS stack solely.” The report additional explains that this problem outcomes from the dearth of know-how experience in implementing and sustaining these purposes. Different challenges embrace variations within the task of duties and accountabilities within the organizations surveyed.
The UK’s Nationwide Cyber Safety Centre (NCSC) supplies particular and sensible steerage by means of its SaaS safety steerage. The recommendation targets organizations of all sizes, together with SMEs. Threat managers will discover two distinctive options of the strategies particularly useful. The primary contains an inventory of 11 standards for assessing the safety of the SaaS answer that the group is contemplating (see the sidebar, NCSC and SaaS). The NCSC supplies a quick consultant query and outline of the necessities to contemplate. Within the second distinctive function, the NCSC delivers the outcomes of its evaluation of its safety standards for 12 fashionable SaaS purposes. Utilizing this steerage, danger managers can jump-start their efforts for these fashionable purposes and assess the danger for gaps recognized within the options. Ought to the appliance not be one of many 12 ready assessments, danger managers can use the generic 11 standards to develop a due diligence guidelines earlier than contracting for the SaaS software.
Take into account SOC Stories
System and Group Controls (SOC) is a collection of providers CPAs could present in reference to system-level controls of a service group or entity-level controls of different organizations. Consumer entities leverage the SOC reviews issued by CPAs to reinforce their advertising and marketing, governance, and inner management efforts. The SaaS consumer group should think about the dangers of two separate cloud relationships. The first consideration is to overview and think about the SOC report of the cloud vendor or service group used. Relying on the circumstances, the SaaS consumer group could decide that its vendor or service group must carry out a overview and different oversight procedures over the SaaS subservice organizations; these providers embrace IaaS and PaaS. Normally, however not at all times, the SaaS vendor or service group will enter into and preserve that relationship, whereas the SaaS consumer won’t recognize {that a} subservice group is concerned. Alternatively, to speak to SaaS customers that their knowledge is saved safe, accessible, and confidential, the SaaS vendor or service group could state that the appliance is processed and knowledge saved in a longtime cloud group’s infrastructure. SaaS vendor or service organizations leverage these cloud organizations’ (IaaS or PaaS) SOC or ISO 27001 reviews. One other problem exists when a SaaS consumer makes use of a big cloud service group vendor or service group providing many providers (e.g., tons of), however presents one SOC report that covers solely a number of the providers supplied to its prospects. This confusion might result in SaaS customers not appropriately contemplating points mentioned within the SOC report as relevant to the providers they use.
SaaS customers ought to be certain that they perceive how the scope and applicability of the SaaS subservice group’s vendor or service group’s SOC report apply to their state of affairs. Particularly, they need to have the ability to determine the identify of the providers they use within the SOC report. They need to additionally decide whether or not the carve-out methodology was used within the SOC report and perceive its implications. The carve-outs might help determine the sub-service organizations relied upon by the SaaS group vendor or service group. SaaS customers must also overview the complementary consumer entity management (CUEC) and complementary subservice group management (CSOC) issues offered within the SOC report back to assess the use, acceptable implementation, and working effectiveness of essential CUECs and CSOCs. If the SOC report identifies using a subservice group, SaaS customers ought to inquire concerning the SaaS group’s vendor administration oversight practices.
SaaS customers must also think about whether or not the SOC report supplied considers relevant regulatory and compliance points. These points have been mentioned in prior articles (see the sidebar).
Traditional Enterprise Points Additionally Want Consideration
Shifting to the cloud creates new “twists” on traditional technology-related governance controls. Thankfully, organizations can overcome these challenges by managing three widespread misconceptions associated to SaaS: acquisition and implementation, sustaining inventories, and managing contracts. The Exhibit describes distinctive SaaS points that will impression a company and the issues for resolving them.
Exhibit
Overcoming Traditional Expertise-Associated Governance Controls
Alternatives Include Dangers
SaaS purposes present large alternatives for SaaS customers. They provide the power to reinforce service supply and considerably ease entry into markets; additionally they ship efficiencies and strengthen an entity’s means to attain organizational targets. Earlier articles have additionally addressed the impression and alternatives for corporations and their practitioners; but, their impression can affect all the group, from knowledge reliability to popularity within the market. Bringing enterprise danger administration (ERM) practices into the equation permits the danger managers of SaaS customers to seek out the steadiness between the entrepreneurial wishes of managers to do what it takes to attain their targets, but assist shield organizational popularity and stakeholder relationships. Efficient governance permits managers to attain their targets cost-effectively inside the constraints of anticipated habits whereas assembly the need to guard belongings.
NCSC and SaaS
NCSC SaaS Standards
- Information-in-transit safety between shoppers and repair
- Trade good follow exterior certificates configuration
- Information-in-transit safety between microservices
- Trade good follow inner certificates configuration
- API authentication and safety
- Privilege separation
- Multifactor authentication
- Logging and occasion assortment
- Availability of logs
- Clear incident response to patching and safety points
- Clear and clear particulars on a product’s security measures
Standard SaaS Functions for which NCSC Supplies an Evaluation
- Basecamp
- Confluence
- G Suite
- Jira
- Mailchimp
- Workplace 365
- Slack
- Smartsheet
- Stride
- Trello
- Yammer
- Zendesk