I first want to apologize to my friends and followers for seemingly falling off the face of the earth. While I would love to say it is because I've been sitting on a beach in some exotic location, the truth is I've been living in compliance hell. Think guiding a startup through IS0 27001 and a PCI DSS audit is difficult? Try doing it in an environment where 100% of your data center is located in public cloud. Then add in a SOC 2 type 2 and SOC 3 compliance check... just because you're a glutton for punishment. While I'm a firm believer that that public cloud can be just as secure as a private environment, the technology is still cutting edge so compliance is still playing catch up.
However there is light at the end of the tunnel, and I honestly don't think its a train. I was fortunate enough to take part in the PCI Council's Cloud Special Interest Group. This has resulted in a new 50+ page guidance document on deploying and auditing PCI DSS v2 in a cloud environment. And yes, the guidance does include many cool pointers on how to achieve compliance in public cloud, not just private.
However don't exhale that sign of relief just yet. Check out this interesting article where I'm sandwiched between a rock and a hard place. The "rock" is a current QSA auditor implying that you can't achieve PCI compliance in public space, even though the article is specifically about the PCI cloud guidance that explains how to achieve compliance in public space. The "hard place" is some unnamed "retail security executive" who spews complete FUD about introspection and obviously does not even have a remedial understanding of the technology. Don't get me wrong, I'm on record as saying that introspection has serious problems in public space that can potentially prohibit its use, but what's needed is dialog and fresh ideas to solve real operational problems, not FUD that does little more than muddy the issue.
So I would love to turn my pain into your gain. As I spin this blog back up, expect lots of tasty nuggets on my compliance journey. Hopefully I can help you avoid some of the same pitfalls I've already had to navigate. To quote one of the great sages of our age: "There's a difference between knowing the path, and walking the path".
--Chris Brenton

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