User:Shawndouglas/sandbox/sublevel45

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Before we move on to choosing an MMSP, we need to briefly mention the shared responsibility model and how it relates to both the MSSP's (and CSP’s) services and assuring quality within the laboratory. Back in Chapter 2, we discussed the shared responsibility model, occasionally referred to as the "shared security model." We said the shared responsibility model is useful because it clarifies elements of responsibility for information security between the laboratory and the CSP in regards to provided cloud services. A trusted CSP should be able to make both levels of responsibility clear at every step of the way, from early contract discussions to late-stage changes to customer services. The CSP remains responsible for certain levels of the IT infrastructure and software, while the laboratory remains responsible for the security of the guest OS, account security, firewall settings, and more. This delineation of responsibility varies from provider to provider, but optimally the information is related clearly to the lab by each.

When it comes to MSSPs and the cloud, they are capable of further reducing the burden of responsibility the laboratory has in regards to not only their cloud services but also any networked on-premises systems. An MSSP can take on the responsibility of the guest OS, network configuration, firewall settings, and server-side encryption, as well as a select portion of client-side data encryption, data integrity authentication, application hardening, and network traffic monitoring and protection.[1][2] This frees the laboratory from even more security detail, providing monetary, quality, and time investment benefits. As noted earlier, however, the laboratory is not completely free from worrying about security. A company culture of cybersecurity and quality must continue to be driven by strong management buy-in, well-documented business and quality policies, well-considered and -enforced operational policies, and regular quality training.

That said, how does the shared responsibility model affect the work of the QAO and laboratory's overall efforts to ensure security in the cloud, particularly with an MSSP? Primarily, shared responsibility says that the laboratory can't take a "set it and forget it" approach to security, even with a CSP and MSSP taking a significant portion of the responsibility off the laboratory's hands. Going back to the Wyoming Department of Health and its accidental upload of patient data to a public server, neither a cloud provider nor an MSSP could do much in this situation. We don't know the circumstances and technology surrounding their incident, but let's imagine that the public health lab was using a CSP and an MSSP. Certainly, the CSP would have no real say in how the lab uploaded content to a server outside its domain. The MSSP largely would have no blame either, as they likely wouldn't even be aware of the public server being uploaded to. No, that would be an internal policy issue, a solid example of how the laboratory would still have a shared stake in the responsibility of security at the lab.

From that example, we'd have to turn to the work of laboratory staff and management, including the QAO. Again, imagining a scenario where the lab was using both a CSP and an MSSP, a number of questions would arise, primary among them being "were they fully aware of and committed to the security responsibility they shared with their service providers?" That level of responsibility would include engaging in cybersecurity discussions among management and key IT personnel, having frank discussions about risk, and bringing in outside help where expertise was lacking. It would also include having a thorough understanding of how lab workers do their job, including learning about any public servers they were using. And it would also, ideally, involve discussion about that laboratory workflow with the MSSP. With all these elements, the likelihood of foreseeing the risk associated with uploading data to public servers from laboratory computers would be optimistically high. Finally, if we add the element of either a laboratory QAO or "cybersecurity quality and compliance officer," one could imagine the scenario turning out differently for the Department of Health. In the end, however, it would have still required knowledgeable personnel, a strong laboratory-wide focus on cybersecurity, and a committed QAO familiar with the importance of the shared responsibility model—and at least the basics of information security—to help ensure the quality of laboratory operations and the information security required of them.

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