CSA STAR Program

©2015 BrightLine CPAs & Associates, Inc. All Rights Reserved
The CSA STAR Program:
Certification & Attestation

01. Background and Overview
02. CCM Framework
03. Cloud Control Matrix
04. STAR Certification
05. STAR Attestation
06. Preparing
07. Q/A
Agenda

Background
& Overview
01

The Cloud Concerns
• Observed loss of control
• Unknown responsibilities / accountability
• Potential liabilities
• Inconsistent legal /compliance framework
• Lack of transparency
• Varying SLA’s

The Beginning
Launched in 2011, the CSA STAR is the first step in improving
transparency and assurance in the cloud.

The Program
• Independent 3rd party validation
• Publicly available registry
• Assurance requirements
• Maturity levels CSPs

The Journey
Prior to issuing the guidance for STAR Certification and STAR Attestation,
a CSP could only perform a self-assessment, which meant completing
the Consensus Assessments Initiative questionnaire (CAIQ) and making
the responses publicly available on the CSA Register. The CAIQ was
completed in several different ways and the content varied from short
answers to full-page responses.

Overview of Open
Certification
Framework02

Framework
OPEN CERTIFICATION FRAMEWORK
LEVEL 3
Continuous Monitoring-Based
Certification
LEVEL 2
Third-Party
Assessment-based
Certification
LEVEL 1
Self-Assessment
ASSURANCE
TRANSPARENCY
CONTINUOUS
CERTIFICATION ATTESTATION
SELF-ASSESSMENT

Cloud Control
Matrix
03

CCM Domains
Application and Interface
Security
Data Security & ILME and Key
Management
Infrastructure and
Virtualization Security
Audit, Assurance and
Compliance
Governance and Risk
Management
Mobile Security
Business Continuity and
Management Resilience
Human Resources Security Security Incident Management
Change Control and
Configuration Management
Identity and Access
Management
Supply Chain Management
Data Center Security Interoperability and Portability
Threat and Vulnerability
Management

CSA STAR
CERTIFICATION
04
CERTIFICATION

Overview
• Rigorous 3rd party independent assessment
• Technology-neutral
• Integration of ISO 27001:2013 and CSA CCM
• Designated an overall maturity score

• Uniform with ISMS
• The Assessors Grid
Scope and Process

Scope and Process

• Management Approach
• Nonconformities and Impact
• Maturity Score and Award
• Registration
Scope and Process

Benefits
• Complements ISO 27001 Certification
• Increased market confidence
• Base maturity level
• Process improvement opportunities
• Increase overall maturity

Challenges
• ISO 27001 Requirement
• Focus on management principles
• Extent of external deliverable
• Subjective score

Certificate

CSA STAR
ATTESTATION
05
ATTESTATION

• 3rd Party independent security assessment
• Integration with SOC 2 examination and CCM
• Testing operational effectiveness of 16 security
domains
Overview

Scope
Application and Interface Security Datacenter Security Interoperability and Portability
Audit Assurance and Compliance Encryption and Key Management Mobile Security
Business Continuity Management
and Operational Resilience
Governance and Risk Management
Security Incident Management,
e-Discovery, and Cloud Forensics
Change Control and Configuration
Management
Human Resources
Supply Chain Management,
Transparency, and Accountability
Data Security and Information Identity and Access Management Threat and Vulnerability Management
Lifecycle Management Infrastructure and Virtualization

• No prerequisites
• Design / operating effectiveness
• Review period of 6+ months
• Standalone / detailed report
• Integration with CCM
• Easy comparability
Benefits

• Full disclosure of exceptions
• Regressive looking report
• No relevance after end of review period
Challenges

Report

Preparing
06

• Define scope and boundaries
• Perform a risk assessment
• Include CCM in risk treatment
• Assess project timeline
RISK ASSESSMENT & SCOPE

• Internally
• Service auditors
READINESS ASSESSMENT

• Policies and procedures
• Segregation of duties
• Monitoring
REMEDIATION

• Licensed CPA firm
• Auditor Certification
• STAR Certification Registrar
• Independent
• Single Vendor Approach
• Audit Team
AUDIT FIRM SELECTION

• Baseline in dynamic environment
• Authoritative source
• Market need
• Trust and assurance with customers
• Leverage current compliance initiatives
It is just the beginning…

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HITRUST for Covered Entities and Business Associates
August 14th
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CSA STAR Program

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