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Cloud and Offshore Governance

Management · 3 min read

Renting instead of owning

Cloud computing is renting IT instead of owning it.

Like renting a home, the landlord looks after some things and you look after others, and the arguments start when nobody is sure who fixes what. IaaS is renting an empty flat: the building is theirs, everything inside is yours. PaaS is a furnished flat. SaaS is a hotel room: they handle almost everything, but you still decide who gets a key.

ModelProvider managesCustomer manages
IaaS (infrastructure)Buildings, hardware, virtualisationOperating system, middleware, applications, data, access
PaaS (platform)All of the above plus OS and runtimeApplications, data, access
SaaS (software)Almost everything up to the applicationData, users and access, configuration

Deployment models: public (shared infrastructure), private (one organisation), community (a group with shared needs), hybrid (a mix).

Who looks after what

Shared responsibility: the customer always owns data, users and access; the provider takes more layers from IaaS to SaaS.

Whatever the model, the customer stays responsible for:

  • its data: classification, protection, retention
  • users and access: who can log in and what they can do
  • the configuration it controls
  • compliance: regulators hold the customer accountable

Many cloud breaches come from the customer’s own mistakes, such as a storage bucket left open to the internet, not from the provider. The split of responsibilities should be written down so nothing falls between the two sides.

Cloud governance worries

  • Data location: data in another country may be subject to its laws, including government access. Privacy laws may restrict moving personal data abroad.
  • Assurance: large providers rarely let individual customers audit them. Assurance comes from SOC 2 reports, ISO 27001 (and 27017/27018) certificates, and CSA STAR. Check scope, period and the controls you’re expected to run yourself.
  • Multi-tenancy: your data must be kept separate from other customers’.
  • Availability: the provider’s SLAs, regional redundancy, and your own resilience design.
  • Exit and portability: can you get your data back, in a usable format, in a reasonable time?
  • Shadow IT: departments buying cloud services directly, skipping security and procurement. A cloud policy and discovery tools help.

Offshore outsourcing

Outsourcing to another country adds:

  • different legal systems and difficulty enforcing contracts
  • privacy rules on moving personal data abroad
  • political, economic and natural disaster risk
  • language, cultural and time zone differences
  • difficulty doing on-site audits

Mitigations: contracts under home-country law, legal review of data transfers, country risk assessments, strong governance and communication routines, and independent assurance.

Example. The marketing team signs up for a cloud analytics tool on a credit card and uploads customer lists. The provider stores data in another region, and nobody checked its security. The finding is a governance gap: no cloud policy or approval process, and personal data moved abroad without anyone assessing the legal impact.

How the exam asks about it

If the question asks…The answer is usually…
What the customer is always responsible for in the cloudIts data and access management
Main concern with data stored abroadJurisdiction and privacy law compliance
How to get assurance over a large cloud providerIndependent reports (SOC 2, ISO 27001), checked for scope
Risk of departments buying cloud services directlyShadow IT bypassing governance and security review
Key thing to plan before choosing a cloud providerExit strategy and data portability

In short

  • IaaS, PaaS and SaaS shift different amounts of work to the provider, but the customer always owns its data, its users and their access.
  • The shared responsibility split must be understood and written down; gaps appear where each side assumes the other is covering something.
  • Where data is stored decides which laws apply, affecting privacy, government access and disputes.
  • Assurance over large cloud providers usually comes from independent reports (SOC 2, ISO 27001, CSA STAR), not direct audits.
  • Offshore outsourcing adds legal, political, language, time zone and audit-access risks.
  • Plan exit and data portability from the start.

Exam traps

  • Moving to the cloud doesn't transfer accountability for protecting data.
  • In SaaS, the customer still manages user access and data classification.
  • A provider's certificate must cover the services and regions you actually use.
  • Data stored in another country may fall under that country's laws.
  • Shadow IT (departments buying cloud services directly) bypasses governance.

Slides

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CISA · Domain 2 · Management

Cloud and Offshore Governance

Who's responsible for what in the cloud, why data location matters, how to get assurance over a cloud provider, and the extra risks of offshore outsourcing.

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