A couple years ago I wrote:
“I am told by many in my industry (and some vendors) that ‘if we put it in the cloud it will work better, cheaper, be safer, and always be available.’ Under most general financial services use cases (as opposed to niche functionality) that statement seems without foundation.”
Although many individuals have become more sophisticated in the ways they pitch ‘the cloud’ I still hear versions of this story on a fairly regular basis…
Today I learned about a recent Office 365 service outage that reminded me that issues concerning our use of ‘cloud’ technology and the commitments we in the Global Financial Services business make to our customers, prospects, marketers, investors, and regulators seem to remain very much unresolved.
According to Microsoft, sometime before 11:30 PM (UTC) on August 3rd 2017, the company introduced an update to the Activity Reports service in the Office 365 admin center which resulted in customers usage reports of one tenant being displayed in another tenant’s administrative portal.
Some customer o365 administrators noticed that the reported email and SharePoint usage for their tenants had spiked. When they investigated, the o365 AdminPortal (https://portal.office.com/adminportal/) displayed activity for users from one or more AzureAD domains outside their tenant. In the most general terms, this was a breach. The breach displayed names and email addresses of those users along with some amount of service traffic detail, for example, user named X (having email address userNameX@domainY.com) sent 193 and received 467 messages, as well as uploaded 9 documents to SharePoint, and read 45 documents in the previous week.
Some subset of those 0365 customers reported the breach to Microsoft.
Microsoft reported that at they disabled the Activity Reports services at 11:40 PM UTC the same day, and that they had a fix in place by 3:35 AM UTC.
Why should I care?
As Global Financial Services Enterprises we make a lot of promises (in varying degrees of formality) to protect the assets for which we are responsible and we promote our ethical business practices. For any one or our companies, our risk profile is rapidly evolving in concert with expanded use of a range of cloud services. Those risks appear in many forms. All of us involved in Global Financial Services need our security story-telling to evolve in alignment with the specific risks we are taking when we choose to operate one or another portion of our operations in ‘the cloud.’ In addition, our processes for detecting and reporting candidate “breaches” also need to evolve in alignment with our use of all things cloud.
In this specific situation it is possible that each of our companies could have violated our commitments to comply with the European GDPR (General Data Protection Regulations: http://www.eugdpr.org/), had it happened in August 2018 rather than August 2017. We all have formal processes to report and assess potential breaches. Because of the highly-restricted access to Office 365 and Azure service outage details, is seems easy to believe that many of our existing breach detection and reporting processes are no longer fully functional.
Like all cloud stuff, o365 and Azure are architected, designed, coded, installed, hosted, maintained, and monitored by humans (as is their underlying infrastructure of many and varied types).
Humans make mistakes, they misunderstand, they miscommunicate, they obfuscate, they get distracted, they get tired, they get angry, they ‘need’ more money, they feel abused, they are overconfident, they believe their own faith-based assumptions, they fall in love with their own decisions & outputs, they make exceptions for their employer, they market their services using language disconnected from raw service-delivery facts, and more. That is not the whole human story, but this list attempts to poke at just some human characteristics that can negatively impact systems marketed as ‘cloud’ on which all of us perform one or another facet of our business operations.
I recommend factoring this human element into your thinking about the value proposition presented by any given ‘cloud’ opportunity. All of us will need to ensure that all of our security and compliance mandated services incorporate the spectrum of risks that come with those opportunities. If we let that risk management and compliance activity lapse for too long, it could put any or all of our brands in peril.
“Data Breach as Office 365 Admin Center Displays Usage Data from Other Tenants.”
By Tony Redmond, August 4, 2017
European GDPR (General Data Protection Regulations)