Assuring Compliance in the Cloud: Paper by Google Cloud’s Office of the CISO

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Cloud transformation and the adoption of modern DevOps technology presents both opportunities and challenges for IT compliance functions. With DevOps style application development, the feedback loop for developers and engineers is much tighter than with traditional application development pipelines, enabling speed and agility of application release cycles. While speedy CI/CD is a critical advantage of DevOps, it also shifts compliance left in the development timeline, and therefore puts pressure on the IT risk & compliance organization to modernize their approach to regulatory compliance as well. With the ongoing shift towards cloud technologies and DevOps, modernization of regulatory compliance is no longer optional for an IT compliance function
Compliance modernization is a broad mandate that spans the way the function is governed; the tools, technology, and analytics it uses; the number and nature of its connections to other parts of the business; verifiability and auditability of the controls’ evidence, the expectations assigned to it; and more.
Public cloud technology is becoming a core part of many industries today, and with this comes some potential risks such as cloud misconfigurations exposing intellectual property, loss of physical control of assets, skillset scarcity around cloud based security and compliance.
Given the constantly changing risk landscape, it is critical that regulations more closely align to address these risks. As regulations and risks evolve, the aim of a modern compliance function is to help an organization stay compliant as it goes through a digital transformation. As organizations go through digital transformation, IT compliance also needs to transform — via upgrading the technology stack, modifying the business processes and most importantly re-skilling people to become cloud aware.
Today we are releasing the new paper by Google Cloud’s Office of the CISO. In the paper we reveal a new approach for modernizing your compliance approach using modern approaches and Google Cloud toolsets. Your team can leverage the paper to add value to enterprises, both by charting a course to the safe use of cloud technology and by reducing risk through the use of the public cloud.
Read the paper “Assuring Compliance in the Cloud.”
Also, review these related resources:
- “Risk Governance of Digital Transformation in the Cloud“ paper
- “Making Compliance Cloud-native” (episode 14) with Zeal Somani
- Google Cloud Compliance resource center
- Our compliance blueprints: PCI DSS on GKE and GCP FedRAMP Blueprint
- Google Cloud security best practices center
Latest News: Secure Digital Infrastructure Services with Apigee Advanced API Security for Google Cloud

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Organizations in every region and industry are developing APIs to enable easier and more standardized delivery of services and data for digital experiences. This increasing shift to digital experiences has grown API usage and traffic volumes. However, as malicious API attacks also have grown, API security has become an important battleground over business risk.
To help customers more easily address their growing API security needs, Google Cloud is announcing today the Preview of Advanced API Security, a comprehensive set of API security capabilities built on Apigee, our API management platform. Advanced API Security enables organizations to more easily detect security threats. Here’s a closer look at the two key functionality included in this launch: identifying API misconfigurations and detecting bots.
Identify API misconfigurations
Misconfigured APIs are one of the leading reasons for API security incidents. In 2017, Gartner® predicted that by 2022 API abuses will be the most frequent attack vector resulting in data breaches for enterprise web applications. Today, our customers tell us application API security is one of their top concerns, which is supported by an independent study from 2021 by Fugue and Sonatype. The report found that misconfigurations are the number one cause of data breaches, and that “too many cloud APIs and interfaces to adequately govern” are frequently the main point of attack in cyberattacks.
While identifying and resolving API misconfigurations is a top priority for many organizations, the configuration management process can be time consuming and require considerable resources.
Advanced API Security can make it easier for API teams to identify API proxies that do not conform to security standards. To help identify APIs that are misconfigured or experiencing abuse, Advanced API Security regularly assesses managed APIs and provides API teams with a recommended action when configuration issues are detected.

Advanced API Security identifies misconfigured API proxies, including the missing CORS policy.
APIs form an integral part of the digital connective tissue that make modern medicine run smoothly for patients and healthcare staff. One common healthcare API use case occurs when a healthcare organization inputs a patient’s medical coverage information into a system that works with insurance companies. Almost instantly, that system determines the patient’s coverage for a specific medication or procedure, a process which is enabled by APIs. Because of the often-sensitive personal healthcare data being transmitted, it is important that the required authentication and authorization policies are implemented so that only authorized users, such as an insurance company, can access the API.
Advanced API Security can detect if those required policies have not been applied, an alert which can help reduce the surface area of API security risks. By leveraging Advanced API Security, API teams at healthcare organizations can more easily detect misconfiguration issues and can reduce security risks to sensitive information.
Detect Bots
Because of the increasing volume of API traffic, there is also an increase in cybercrime in the form of API bot attacks—the automated software programs deployed over the Internet for malicious purposes like identity theft.
Advanced API Security uses pre-configured rules to help provide API teams an easier way to identify malicious bots within API traffic. Each rule represents a different type of unusual traffic from a single IP address. If an API traffic pattern meets any of the rules, Advanced API Security reports it as a bot.
Additionally, Advanced API Security can speed up the process of identifying data breaches by identifying bots that successfully resulted in the HTTP 200 OK success status response code.

Financial services APIs are frequently the target of malicious bot attacks due to the high-value data that is processed. A bank that has adopted open banking standards by making APIs accessible to customers and partners can use Advanced API Security to make it easier to analyze traffic patterns and identify the sources of malicious traffic. You may experience this when your bank allows you to access your data with a third-party application. While a malicious hacker could try to use a bot to access this information, Advanced API Security can help the bank’s API team to identify and stop malicious bot activity in API traffic.
API Security at Equinix
Equinix powers the world’s digital leaders, bringing together and interconnecting infrastructure to fast-track digital advantage. Operating a global network of more than 240 data centers with a 99.999% or greater uptime, Equinix simplifies global interconnections for organizations, saving customers time and effort with the Apigee API management platform.
“A key enabler of our success is Google’s Apigee, delivering digital infrastructure services securely and quickly to our customers and partners,” said Yun Freund, senior vice president of Platform at Equinix. “Security is a key pillar to our API-first strategy and Apigee has been instrumental in enabling our customers to securely bridge the connections they need for their businesses to easily identify potential security risks and mitigate threats in a timely fashion. As our API traffic has grown, so has the amount of time and effort required to secure our APIs. Having a bundled solution in one managed platform gives us a differentiated high-performing solution.”
Getting started
To learn more, check out the documentation or contact us to request access to get started with Advanced API Security.
To learn more about API security best practices, please register to attend our Cloud OnAir webcast on Thursday, July 28th, 2:00 pm PT.
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Trusted Collaboration for Hybrid Workplace with Google Workspace
Hybrid workspace need high levels of security, data privacy, and trust for seamless collaboration across workforce. As we navigate to the new normal, your enterprise can learn about the security and privacy specific innovations Google Workspace utilizes to help customers realize powerful, trusted, cloud-native collaboration.
4 Cloud Security Trends to Watch Out for in 2022

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When it comes to cloud security, 2022 will be the year that the past catches up with the future. Trends that businesses have been ignoring for too long will force organizations large and small to confront and control their security debt.
That’s according to Google Cloud’s own cybersecurity experts, who have identified four security trends that organizations need to watch out for—and get ahead of. We have predictions on what to expect in the coming year from MK Palmore, director of the Office of the CISO; Brian Roddy, vice president of engineering for Cloud Security; Tim Dierks, engineering director for data protection; and Panos Mavrommatis and Vikram Makhija, senior directors of security engineering for Google Cloud.
Supply chain shenanigans

“We will see continued asymmetric attacks from adversaries as they exploit supply chains and other previously ‘trusted’ third-party entities,” says Palmore.
Supply-chain problems in cloud computing should be easily solvable, right? Software versions and any vulnerabilities they contain should be trackable and patchable, but the reality of fixing software is that “just patch it” is hard to execute—just look at the challenges posed by the Log4j 2 vulnerability. Supply chain is such a huge problem that President Biden addressed it in an Executive Order in May 2021. Customers can expect the issue to be top of mind at Google Cloud.
Not exactly many happy returns (to the office)
“Return to office around the world will drive changes as office infrastructure has not been invested in for a year and a half while the focus has been on remote users. This likely will drive a short-term boom in traditional on-prem security, but it will be the last boom for that as people adapt their remote, zero-trust style strategies to a more modern on-prem approach,” says Roddy.
The misconception that on-prem infrastructure is categorically more secure than cloud is driven by the desire to have physical access to servers and backups so that only the organization which owns the data controls it and has access to it, even in cases of a catastrophic failure or successful cyberattack. In the early years of cloud computing, that may even have been true. But the conditions that drove the myth of on-prem security primacy changed years ago, and the needs driving secure cloud infrastructure help ensure that cloud stays more secure.
Paying down your security debt
“While there’s all the new hotness of cutting-edge concerns, many enterprises still carry security risks and security debt from not yet fully adopting controls which have been broadly accepted as important for years. For example, loads of companies are still not using phishing-resistant two-factor authentication such as FIDO keys,” says Dierks.
Authentication keys such as those made by Yubico and Google’s own Titan Security key support the zero-trust security principles that require user identities to be authenticated, authorized, and then continuously validated before they can access applications and data. Strong authentication is such an important part of contemporary user security that even weaker forms of it that rely on text messages are significantly more secure than not using it at all. That said, why use a less-secure standard when you can reduce risks to your data and bottom line even further by requiring a phishing-resistant hardware key?
Dierks stresses another challenging but important part of eliminating security debt: using social connections to encourage best security practices. “It’s important for CISOs to use their business relationships to emphasize the importance of baseline controls [such as 2FA] for their partners. Enterprises have close relationships that attackers can leverage, so it’s critical that partners hold each other accountable to maintain high security.”
KYD (Know Your Data)
The impact of a data breach can harm organizations as they currently are as well as far into the future. Current tough-to-crack encryption standards protecting data could become easier to decode in the years ahead, so even if cybercriminals can’t access stolen data now there’s no guarantee that paradigm will hold. This means it’s crucially important that organizations understand what data they’re storing, how they’re storing it, and where they’re storing it, say Mavrommatis and Makhija.
“You can’t secure what you don’t know about, and not all data breaches are equal. Stolen machine logs are not as bad as customer data. But how many security teams know the difference? So you have to crawl your own data to automatically classify and discover where sensitive data lives,” they say.
Makhija adds that the shared fate model requires the cloud providers and cloud customers to have a mutual understanding of the quantitative risks each faces. “Shared fate models will pick up significantly in 2022,” he says, as more organizations move to the cloud, and those already using cloud infrastructure improve their security postures.
“To date, there’s been a disparate set of tools for understanding your posture. It’s difficult for third-party tools to stitch together what cloud services should be providing from the start,” he says.
What you can do to make your organization more secure
One cloud security trend that’s ever-present is the ever-increasing importance of keeping cloud deployments secure. As cloud infrastructure becomes more commonplace across businesses and industries of all sizes, it will continue to grow as an attractive target for cybercriminals and other threat actors.
- Because enterprise data has expanded exponentially, the ability to identify and detect threats have become increasingly challenging. To better secure the enterprise software supply chain, use advanced threat detection and analysis tools—especially those designed to catch anomalies.
- The faster that organizations adopt a zero-trust architecture, the more secure the new normal can be. Zero trust helps limit the blast radius of any potential intrusion, while maximizing new enterprise access expectations. Part of adopting zero trust means many end-users can abandon legacy technology like VPNs, but the benefits of segmentation and context-aware access for both identity and device will make all the difference for large scale enterprises. When coupled with a full zero-trust approach and the use of a zero-trust maturity model for improvement, organizations will be better positioned to manage their digital risks.
- Security debt can come in many forms and one critical payoff that needs to be made is for organizations to migrate en masse to hardware two-factor authentication keys. They make user accounts significantly more resistant to takeovers, and are much harder to circumvent than two-factor authentication over SMS.
- It’s past time to get to know your data, and a bouquet of flowers and a bottle of red wine won’t help. There are third-party tools that can do this, but for Google Cloud customers who use BigQuery there’s automatic Data Loss Prevention. It continuously monitors existing tables and profiles new ones; it can be customized for selected folders or projects, or for an entire organization; and it generates data profiles in the same geographic region as the original data.
Understanding and managing the security challenges of cloud infrastructure helps maximize its benefits, and makes for a safer security landscape in 2022—and beyond.
Securing Sensitive Data in the Cloud: Google Cloud’s CDMC-Certified Solution

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As enterprises accelerate adoption of cloud-based services and products, they face a common challenge: How can they effectively secure and govern rapidly expanding volumes of their most sensitive data in new environments?
Today, Google Cloud released an architectural whitepaper and accompanying source code for a solution which successfully completed an assessment facilitated by KPMG LLP and has been accredited by the Enterprise Data Management Council (EDM Council) as a Cloud Data Management Capabilities (CDMC) Certified Cloud Solution. The architecture, which includes Google Cloud’s BigQuery and Dataplex Data Catalog, has been validated against CDMC’s control framework and can be used by new or existing Google Cloud clients wanting to migrate their sensitive data to the cloud with greater confidence.
“This is an exciting milestone for Google Cloud and the CDMC framework,” said John Bottega, president of EDM Council. “Google is advancing cloud adoption across all industries. Now as a CDMC Certified Cloud Solution, their clients can have the added certainty that Google’s architecture has the key controls and accepted best practices in place to protect their data in the cloud.”
Introducing CDMC
The CDMC framework, developed and published by EDM Council, provides a set of data management capabilities, standards, and best practices for securing their cloud implementations. Contributors to the framework include large global enterprises across regulated industries, major cloud service providers, technology service organizations, and advisory firms.
The EDM Council also provides a data management assessment framework which includes a framework composed of 14 key controls and corresponding assessment procedures, which are used to validate that sensitive data is being managed effectively. To become a CDMC Certified Cloud Solution, the Google Cloud team designed, implemented, and documented a reference architecture which met the control requirements and was then assessed by KPMG LLP.

Using the solution, customer data assets are automatically classified and tagged with business metadata, their lifecycle is managed, and a reporting engine that proactively scans and publishes findings provides security administrators information about misconfigurations and security issues via a single dashboard.
Who should use this framework?
- CDOs and CISOs: The CDMC framework provides a systematic approach to handling sensitive data in the cloud and is a good starting point for chief digital officer-level discussions around what governance and security controls should be applied to different types of sensitive data. The Google Cloud CDMC assets can help with determining practical scope and efforts needed to implement the CDMC controls within your organization.
- Data platform architects and engineers: The Google Cloud reference architecture provides reusable patterns that can be adopted and customized to suit the particular needs of your organization, as well as your existing architecture and technology stack.
- Data owners and data stewards: Once implemented, the resulting classification, automation, findings, and reports should reduce the manual burden of effectively governing sensitive data at scale.

Architecture
The architecture combines a number of Google Cloud’s services with built-in platform capabilities and data-protection services to protect data at scale.
These services include:
- BigQuery, which can fully manage a serverless data warehouse that enables scalable analysis for petabytes of data.
- Dataplex’s Data Catalog, which can fully manage highly scalable data discovery and metadata management with built-in data lineage features.
- Cloud Data Loss Prevention, which provides tools to classify and mask sensitive data.
- VPC Service Controls, which defines a security perimeter around Google Cloud resources to mitigate data exfiltration risks.
- Looker Studio, which provides a sample dashboard to visualize the overall health of the environment.
Additionally, the architecture leverages:
- Secure Data Warehouse Blueprint, which adheres to practices for data governance when creating, deploying, and operating a data warehouse in Google Cloud.
- Tag Engine, which automates the process of creating and populating metadata tags in Data Catalog.
The diagram below highlights the Google Cloud services used and how they mapped to the 14 CDMC key controls:

Further information
To get started, Google Cloud customers can:
What’s in Line for Google Cloud’s Europe Customers in Regards to the E.U.-U.S. Data Transfer Framework

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Last week, the European Commission and U.S. Government agreed on a new E.U.-U.S. data transfer framework. Earlier today, Google shared that it welcomes these efforts by the U.S. government to enhance privacy protections for E.U. data and facilitate trusted transatlantic data flows. For our Google Cloud customers, we intend to make the protections offered by this new framework available once it is implemented.
Last year, we reaffirmed our commitment to E.U. businesses after the European Data Protection Board (EDPB) issued its Recommendations on Supplementary Measures, following Europe’s top court ruling invalidating the E.U.-U.S. Privacy Shield Framework and upholding the E.U. Standard Contractual Clauses (SCCs).
Since then, we’ve continued to help our customers meet stringent data protection requirements by offering industry-leading technical controls, contractual commitments, and risk assessment resources. We’ve also continued our advocacy to create more legal certainty around transatlantic data flows.
Today, we would like to provide an update to our customers on this work.
A customer-controlled cloud
Google Cloud1 continues to be a leading provider of technical and security controls to help meet customers’ data protection requirements, as well as their increasing data sovereignty expectations.
We are committed to building our Cloud on Europe’s terms, including by offering customer-managed encryption and data localization for a growing list of key products and collaborating with local partners to provide the highest levels of sovereignty, all while enabling the next wave of growth and transformation for Europe’s businesses and organizations.
Google Cloud Platform
We recently announced the general availability of Assured Workloads for the E.U. This product helps Google Cloud Platform (GCP) customers protect their data by allowing them to:
- Store their data in their choice of E.U. Google Cloud region(s)
- Ensure that only E.U. persons – located in the E.U. – have access to the data and provide customer support
- Deploy cryptographic control for data access, including customer-managed encryption keys
Cloud External Key Manager (EKM) enables customers to encrypt data in a variety of services with keys that are stored and managed in a third-party key management system deployed outside of Google’s infrastructure. Google Cloud continues to be the only cloud provider to enable customers to store and manage encryption keys for cloud-resident data outside the provider’s infrastructure with customer’s control over decryption based on specific justifications, including government access requests.
Key Access Justifications greatly advances the control that GCP customers have over their data by giving customers a justification every time their externally hosted keys have to be used to decrypt data. Signed Access Approval (SAA) adds a layer of extra assurance that requires explicit customer consent for any administrative access to customer data or configurations.
Google Cloud’s Confidential Computing portfolio is a breakthrough technology that allows customers to encrypt their most sensitive data in the cloud while in-use. Ubiquitous Data Encryption further extends data protection by providing cryptographic protection for this data at-rest, in-transit, and in-use. The keys used to encrypt customer data outside of GCP using Cloud EKM are securely shared with applications operating within Confidential environments.
Google Workspace
Our Google Workspace (including Workspace for Education) customers can choose to store their covered data in Europe. Additionally, with Client-Side Encryption, we offer customers direct control of encryption keys and the identity service they choose to access those keys. With Client-Side Encryption, customer data is indecipherable to Google, while users can continue to take advantage of Google’s native web-based collaboration, access content on mobile devices, and share encrypted files externally. Client-Side Encryption is currently available in Public Beta for Google Drive, Docs, Sheets, and Slides, and we plan to extend it to Gmail, Calendar and Meet. Additionally, customers can also benefit by choosing third party solutions that offer similar encryption capabilities with select Google Workspace services.
Legal Basis for International Data Transfers
We updated our data processing terms for GCP and Google Workspace and Cloud Identity to reflect various modules of the new E.U. Standard Contractual Clauses (SCCs) approved by the European Commission on June 4, 2021, as well as separate U.K. SCCs.
Google Cloud plans to adopt the new E.U.-U.S. data transfer framework and offer it as a transfer solution to our cloud customers, as further detailed in our data processing terms.
Advocacy and Additional Helpful Resources
We have adopted the Trusted Cloud Principles with industry peers to demonstrate our commitments to protect the rights of our Google Cloud customers. We will continue to support the ongoing work of the Organisation for Economic Co-operation and Development on government access to data and the negotiation of CLOUD Act Agreements — including between the U.S. and E.U. — as vehicles for surveillance reform.
We will continue to publish additional materials on our Cloud Privacy Resource Center, such as our whitepaper on safeguards for international data transfers with Google Cloud.
Millions of organizations with users in Europe rely on our cloud services to run their businesses every day, and we remain steadfastly committed to helping them meet their regulatory requirements by maintaining a diverse set of compliance tools.
Google Cloud: Google Workspace (including Google Workspace for Education) and Google Cloud Platform (GCP)
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