Do Data Center Audits Mean Anything?

1sockchuck writes "Data center service providers often tout certifications such as SAS 70, SSAE 16 and SOC 2 as evidence that they meet lofty operational standards. But some of these certifications are based on self-defined standards, and the entire situation is confusing and frustrating to customers, according to one critic, who says data center shoppers are poorly served by the jumble of acronyms and standards. Do these certifications matter when users are seeking data center space? Should they?"

Not really

[gweihir]

Now, if you get your hands at the detail reports, the audit result may actually tell you something, at least if the auditors are good. But the certifications pretty much only ensure minimal standards low enough to be meaningless.

short answer: no

[Anonymous Coward]

I'm a work at a somewhat large financial services company that provides customer information to various other large financial institutions (chase, wells fargo, capital one, amex, discover, just to name a few). We receive this customer information from pretty much everywhere - those self same banks, government agencies, credit card companies, universities. Basically, if you've ever had a loan or grant, credit card, bank account, paid a utility bill, child support or been in prison then we have that data. Your address, phone number, social security number, bank account information, etc.
    The majority of this information is stored unencrypted on systems that are accessible to any employee, often with 777 permissions. While the majority of the systems are patched pretty regularly, many aren't. I recently had to convert over an old apache 1.3 server that hadn't been patched since 2006 - there's another similar server that is regularly used by outside contributors to drop off customer information.
    We have customer facing IPlanet servers that haven't been patched since 2004 - the software isn't even under support anymore.
    We have session recording software on our unix servers that is so ridiculously trivial to bypass that the company that sells it (centrify) should be ashamed to sell it.
Yet we've had PCI certification for 3 years, we've passed the SAS70 certification every time - they are rubber-stamps, nothing more.

Of course it matters

[ZouPrime]

Well, it certainly matter for regulation purpose. If you handle data that need to be covered under a specific standard (say, PCI), you'll seek out a certified data center. In this context, the certification isn't about security, it's about risk transfer. It's the provider who become liable if there's a breach if it can't show to have respected the standard properly.

Now as security references, they certainly have their problems. We can take solace in the thought that they help enforce the bare minimum at the very least. As a security professional, I would say their best benefit is how well they can be used as a big stick, "encouraging" management to perform necessary changes. It's a hard sell to convince an average manager to invest in security for the sake of security. But if there's a legal penalty associated with whatever standard must be put in place, as well as a big dollar sign attached to it, they'll suddenly start to listen. That's a language they understand.

These are NOT Certifications!

[DaCurryman]

There is a number of problems with how data centers make these statements and what people interpret. The main problem is that people say things like "SAS70 Certified". That is terribly bad wording. There is no such thing. The SAS70 (now SSAE16 or SOC1 report) is not a certification. There is no preset/predetermined criteria that is universal to all companies that receive such a report. Each report is specific to that particular company/data center. It's almost like saying I have a diploma as an independent study major. The next thing is that these reports are not intended for public use. These are auditor-to-auditor reports. They are meant for the auditor for a company that uses said data center (or other service provider) to rely on and not need to audit the data center itself. That is why auditors review these reports to make sure it contains the provisions it's looking for. Otherwise, they're going to go in and audit the data center. Companies that get such reports tend to use it as a marketing tool to show potential customers, when that isn't the purpose. To reduce some blame, I've known auditors guilty of telling data centers that they can do that so that they could convince the data center to pay for the service. Also, SAS70 was designed to reflect controls at a service provider that impact or relate to the processing of financial data, which would have an effect on the financial statements that the auditor is reviewing. Most data centers don't process data (the customers that host stuff there do and they need the SAS70). However, over the years, people have convinced themselves that because the data physically resides at the data center, they impact the financial statements and so they should get a SAS70. This is however, not really true, since with good security controls around the data, the physical hosting of it won't materially misstate the financials. It was for this reason that the AICPA split the old SAS70 into 3 separate services: SOC 1 (SSAE16) which is what the old SAS70 was meant to be, SOC 2, SOC 3. The latter 2 are geared more toward data centers and technology firms that don't impact financial data. The seals that are issued by the AICPA just state that you've had a report done. They do not speak to the content of the report. I could get a SOC report that just says "All employees are entitled to free breakfast". The auditor I hire will come in and test/verify that and then will sign-off saying that they agree. I now have such a report and can boast "SAS70 Certified" everywhere, which doesn't mean squat. It only matters to the company itself, the company that uses their services (depending on context), and the auditors of the company that uses their services.

The answer you need to show your boss

[colonel]

Right here, pure gold: http://www.gartner.com/it/page.jsp?id=1400813 [gartner.com]

Read that 5 times, carefully, and then get your bosses to do the same. Seriously.

SAS70 is a *questionnaire* that the vendor completes, and then the auditors just go in and confirm that their answers are correct.

So I could say "we don't do backups" in my answer to the questionnaire, the auditors would verify that I didn't do backups, and I'd "complete" the SAS70 process (not a certification!) successfully.

It is the client that is resoponsible for reviewing the questionnaire and ensuring that the audited answers are sufficient for the needs of their business. That's called "vendor management" and is a core practice area in ITIL.