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ANALYSIS OF DATA SECURITY & MANAGEMENT IN HYBRID CLOUD COMPUTING ENVIRONMENT

ACKNOWLEDGEMENT

I hereby take a chance to express my sense of extreme gratitude towards my Master of


Technology Guide Sarvesh Rai, Head of Dept. Nevdeep Saluja (Computer Science Deptt.),
for his suggestions and constant inspiration at every stage of the research.

He is an extremely sympathetic and principle-centered person. His skills, as a researcher and


guide helped me to overcome all the hurdles. Without his constant support and
encouragement, I would not have been able to complete my research work successfully.

I owe a debt of gratitude to Dr. D. Rao, Director, Infinity Management & Engineering
College Sagar, for encouragement & the Head of Department Nevdeep Saluja.

My parents have their own share in my success. I firmly believe that their blessings always
enlighten my path ahead. I hereby take a chance to salute my father …….. and mother …….
Without all above support and sacrifice this thesis would not have been possible for me. At
last, I thank the one and all, for the divine blessings.

Prashant Namdev

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ANALYSIS OF DATA SECURITY & MANAGEMENT IN HYBRID CLOUD COMPUTING ENVIRONMENT

CERTIFICATE

I hereby certify that Er. Prashant Namdev has completed her Master of Technology
Dissertation titled “Analysis of Data Security & Management in Hybrid Cloud
Computing Environment” under my guidance.

I further certify that the whole work, done by him is of his own, original and tends to general
advancement of knowledge. According to the best of my knowledge, I also certify that he has
not been conferred any degree, diploma and distinction by either the Infinity Management &
Engineering College or any other university for this thesis.

Date: (Sarvesh
Rai)

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ANALYSIS OF DATA SECURITY & MANAGEMENT IN HYBRID CLOUD COMPUTING ENVIRONMENT

DECLARATION

I, Prashant Namdev hereby declare that my Master of Technology dissertation titled


“Analysis of Data Security & Management in Hybrid Cloud Computing Environment”
is written as a partial fulfillment of the requirement for a degree on this topic. The complete
study is based on literature survey, study of periodicals, journals and websites and building a
model for proving the concept studied and designed.

I further declare that the complete thesis work, including all analysis, hypothesis, inferences
and interpretation of data and information, is done by me and it is my own and original work.
Moreover, I declare that no degree, diploma or distinction has been conferred on the basis of
this thesis by the Rajiv Gandhi Technical University or any other university to me before.

Date: (Prashant Namdev)

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प्रपत्र

(एम.ई /एम. टे क /एम. फामाा छात्रों हेतु)

मै …………………………………………..…..आत्मज…………………............... आयु………
वर्ष निवासी…………………………. का होकर शपथपव
ू षक निम्ि कथि / करता करती हूूँ कक :-

1. यह कक मेिे (एम. ई /एम. टे क /एम. फामाष) के ववर्य…………………………...……


सत्र………….…. मै काउं सल ग
ं / संस्था स्तर काउं सल ग
ं (सी. ए . सी.) के माध्यम से श्रेणी
(सामान्य / इस. सी. / इस. टी. / ओ. बी. सी.) ……………. से
……………………………..…………... संस्था मै प्रवेश ल या था |
2. मै दििांक ………………… से नियलमत छात्र / छात्रा के रूप मे स्िातकोत्तर पाठ्यक्रम मै
अध्ययिरत था / थी |
3. मै घोर्णा करता / करती हूूँ कक इस पाठ्यक्रम की अवधि मै ककसी भी अन्य निजी क्षेत्र के संस्थाि /
औिोधगक समूह / ककसी भी कायाष य मै पूणषकाल क रूप से कायषरत िहीं था / थी |

हस्ताक्षर शपथग्रहहता

गाईड एवं संचालक प्राचार्ा द्धारा सत्र्ापपत ककर्ा जावे |

सत्यावपत करते है कक छात्रा / छात्रा का िाम


…………………………………………………….. िामांकि क्रमांक ………………………..… द्िारा
उपरोक्तािुसार भरी गई जािकारी प्रमाणणत एवं सही है |

गाईड के हस्ताक्षर संचालक प्राचार्ा

हस्तक्षर पदनाम सील


सहहत

संस्था का िाम ………………………………………………………….

संस्था का कोड ………………………………………………………….

िरू भार् क्रमांक ………………………………………………………….

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ANALYSIS OF DATA SECURITY & MANAGEMENT IN HYBRID CLOUD COMPUTING ENVIRONMENT

ABSTRACT

Companies offering services on the Internet have led corporations to shift from the high cost
of owning and maintaining stand-alone, privately-owned-and-operated infrastructure to a
shared infrastructure model. These shared infrastructures are being offered by infrastructure
service providers which have subscription, or pay-on-demand, charge models presenting
compute and storage resources as a generalized utility. Utility based infrastructures that are
run by service providers have been defined as “cloud computing” by the National Institute of
Standards and Technology. In the cloud computing model the concerns of security and
privacy protections are exacerbated due to the requirement for an enterprise to allow third
parties to own and manage the infrastructure and be custodians of the enterprises information.
With this new architectural model, there are new hybrid governance models designed to
support complex and uncertain environments. The cloud also requires a common
infrastructure that integrates originally separate computing silos. Privacy and security policy
awareness during provisioning and computing orchestration about data locality across
domains and jurisdictions must be able to obey legal and regulatory constraints. Commercial
use of the Internet for electronic commerce has been growing at a phenomenal rate while
consumer concern has also risen about the information gathered about them. Concern about
privacy of data has been rated as the number one barrier by all industries. The purpose of this
dissertation is to perform an empirical study to determine if existing privacy assessment
instruments adequately assess privacy risks when applied to cloud infrastructures. The
methodology for determining this is to apply a specific set of privacy risk assessments against
a three cloud environments. The assessments are run in the context of a typical web based
application deployed against cloud providers that have the five key cloud tenets - on-
demand/self-service, broad network access, resource pooling, rapid elasticity, and measured
service

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CONTENTS

Chapter 1. Introduction 1 - 12

1.1 Statement of the Problem


Research Goal

Relevance and Significance

Barriers and Issues

Research Questions & Overarching Hypothesis

Limitations

Delimitations

Assumptions

Definition of Terms

Summary

Chapter 2. Literature Survey 13 - 27

Introduction
History of Privacy
What are the Privacy Risks

Security and Privacy Assessment


Cloud Computation
Cloud Benefits
Cloud Privacy Challenges
Cloud Exacerbates Privacy Exposures
Summary
Chapter 3. RESEARCH METHODOLOGY 28 - 43
Introduction
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Design of the Study

Hypothesis Tested

Resources Required

Selection of the Population

Instrumentation Used

Summary

Chapter 4. RESULT 44 - 53
Overview

Inferential Statistics Results

Chapter 5. CONCLUSION 54 - 58
5.1 Summary

5.2 Conclusion

Chapter 6. FUTURE ENHANCEMENT 59 – 60


Appendix - A
References
Appendix – B
List Of Publication

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List of Figures

Chapter 3. RESEARCH METHODOLOGY

Figure 1, Methodology for each cloud provider in the study 31

Figure 2, Proposed Reference Application Architecture 38

Figure 3, Privacy Assessment Cloud Experiment Model 40

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List of Table

Chapter 3 RESEARCH METHODOLOGY

Table 1, Privacy Assessment Types 34

Table 2, Privacy Dimensions for Privacy Assessments 34

Chapter 4 RESULT

Table 3, Total Number of Questions for Each 44

Dimension by Privacy Assessment

Table 4, Answerability Score by Privacy Assessment Type 46

Table 5, Answer Frequency by Phase and Privacy 47

Assessment Type

Table 6, Tenet Relevance Scores by Cloud Tenet, CSP, and PA 50

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CHAPTER 1
INTRODUCTION

1.1 Statement of the Problem


Companies are extending their information processing services from internal datacenters to
external Cloud Service Providers (CSP) enabling companies to improve costs and apply more
focus to their core business (Skene, Raimoni, and Emmerich, 2010). Examples of CSPs are
Google, Amazon, and Microsoft which all currently offer various cloud services. Concern
over the loss of privacy due to technology advancement has existed for decades and one
approach to solving this problem is to institute a “privacy by design” methodology
(Spiekermann and Cranor, 2008). An element of privacy by design is to assess the
environment for privacy risks and mitigate those risks. The goal of this study was to
empirically examine if the most commonly used privacy risk assessment methods in use
today will extend to a company's cloud based infrastructure and continue to expose the risks
when executed in the context of the core cloud characteristics.

Organizations such as National Institute of Standards and Technology (NIST, 2010) and the
Cloud Security Alliance (CSA, 2010) have defined information security lifecycles which
establish process based steps to enable information security by design.

An equivalent information privacy lifecycle standard or best practice is lacking in the


literature. The process steps that the CSA (2010) and NIST (2010) have established include
assessment of the environment or system, prioritizing and planning the mitigation of the
risks, executing the improvements, evaluating the impact of improvements, and rerunning the
process if resources allow. Designing privacy into systems requires similar steps to an
information security lifecycle and due to the desire to manage scope of the study only one
step in the process was tested; the privacy assessment process.

The CSA’s (2010) data security lifecycle recommendation included a recommendation that
assessment tools be updated specifically for cloud environments.

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They go on to state that this is due to the changes in roles and responsibilities that require
collaboration and a modified trust model and that the different deployment models of cloud
may shift the accountability to the provider. The ISO/IEC 27002 (ISO/IEC 27002:2005,
2005) section on external parties control states that information security facilities shouldn’t
be reduced by extending IT processing via outsourced functions.

These two standards groups suggest that assessment methods should be adapted to
externalproviders (e.g. cloud) and this study is designed to apply that same logic to privacy
assessments in cloud environments by evaluating the privacy assessments without modifying
for cloud environments and executing them against CSPs.

Liu, Marchewka, Lu, and Yu (2004) report that consumer and commercial use of the Internet
for electronic commerce have been growing at a phenomenal rate while consumer concern
has risen about the information gathered about them. Kraemer,

Dedrick, Melville, and Zhu (2006) indicated that concern about privacy of data was the
number one barrier across all types of industry. Offering services on the Internet have led
companies to shift from the high cost of owning and maintaining stand-alone,
privatelyowned- and-operated infrastructure to a shared infrastructure model (Candan, Li,
Phan, and Zhou, 2009). Candan, et al. (2009) also stated that these shared infrastructures are
offered by infrastructure service providers which have subscription, or pay-on-demand,
charge models presenting compute and storage resources as a generalized utility. These steps
to an information security lifecycle and due to the desire to manage scope of the study only
one step in the process was tested; the privacy assessment process.

The CSA’s (2010) data security lifecycle recommendation included a recommendation that
assessment tools be updated specifically for cloud environments.

They go on to state that this is due to the changes in roles and responsibilities that require
collaboration and a modified trust model and that the different deployment models of cloud
may shift the accountability to the provider. The ISO/IEC 27002 (ISO/IEC 27002:2005,
2005) section on external parties control states that information security facilities shouldn’t
be reduced by extending IT processing via outsourced functions.

These two standards groups suggest that assessment methods should be adapted to external
providers (e.g. cloud) and this study is designed to apply that same logic to privacy
assessments in cloud environments by evaluating the privacy assessments without modifying
for cloud environments and executing them against CSPs.

Liu, Marchewka, Lu, and Yu (2004) report that consumer and commercial use of the Internet
for electronic commerce have been growing at a phenomenal rate while consumer concern
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has risen about the information gathered about them. Kraemer, Dedrick, Melville, and Zhu
(2006) indicated that concern about privacy of data was the number one barrier across all
types of industry. Offering services on the Internet have led companies to shift from the high
cost of owning and maintaining stand-alone, privatelyowned-and-operated infrastructure to a
shared infrastructure model (Candan, Li, Phan, and Zhou, 2009). Candan, et al. (2009) also
stated that these shared infrastructures are offered by infrastructure service providers which
have subscription, or pay-on-demand, charge models presenting compute and storage
resources as a generalized utility. These privacy technology (Garfinkel, 2007). Garfinkel
(2007) noted encryption as one possible solution before data is transferred to the cloud. What
makes cloud computing so different from other computing methods are the new
characteristics such as multi-tenancy of the storage, networks, and servers that also may
introduce new privacy exposures (Candan, et al., 2009).

A 2007 survey completed by Luftman and Kempaiah (2008) on the top issues for IT
executives placed security and privacy in sixth place of the top 10. Foster, Zhao, Raicu, and
Lu (2008) stated that one of the major challenges for cloud computing providers is
engendering trust within companies when faced with the information security and privacy
risks of cloud-based enterprise information. Bennett and Raab (2006) stated that privacy
exposures cost enterprise customers through the loss of trust; conversely, privacy protections
enhance trust for the enterprise.

Two relevant examples of how privacy breaches can impact a company in terms of cost and
reputation are the Heartland (Zetter, 2009) and TJX Companies, Inc. (TJX) breaches (Horn,
2001). The report by Zetter indicates that enterprise privacy breaches have also had
significant financial impact on enterprises due to fines, lost business, and the cost of
mitigating exposures. The Heartland privacy breach resulted in over 130 million credit cards
stolen and cost Heartland over $12.5 million in fees and fines. In the past, companies felt
secure from privacy exposures by controlling and managing their infrastructures within the
walls of the enterprise (Horn, 2001). Luftman and Kempaiah (2008) estimated that the TJX
privacy breach cost TJX over $1 billion for security upgrades, consulting and attorney fees,
and a large marketing campaign designed to perform damage control. Both of these breaches
occurred within the confines of these businesses’ on-premise IT where they had full control
of their information security controls.

Security evaluation models use knowledge-based ontological methods to establish a


framework for security management (Tsoumas, Dritsas, & Gritzalis, 2005). A guiding
principle in Tsoumas, et al.’s (2005) research was that knowledge-based ontology’s could be
used to collect what they defined as “security knowledge”. They went on to define the
elements that make up Security Knowledge (SK) including security assessments which are
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used to inventory information assets and evaluate the threats to those assets. Security
assessments have matured into de facto and international standards such as ISO/IEC 27002
from the International Organization for Standardization (ISO/IEC 27002:2005, 2005).

Similar to security management, Mont and Thyne (2006) suggested that privacy management
is also important to the enterprise. Privacy management also includes consideration for
compliance with regulations, their reputation, brand, and customer satisfaction. Squicciarini,
Hintoglu, Bertino, and Saygin (2007) found that while service providers publish privacy
practices when service providers federate services, there are no guarantees that all the privacy
protections are transitive such as obligations (e.g. passed from one provider to another). Yee
(2009) defined a requirement that the privacy standard for one provider must be maintained
when information flows and information is stored potentially by another provider.

Futcher and von Solms (2008) acknowledged that standards and best practices often become
the basis for developing a security life-cycle within an organization. They also maintained
that standards development and ratification are designed to reflect industry best practices.
Also according to Fucher and von Solms (2008) the effort of standardizing the best practices
is accomplished by subject matter experts that are authorized and experienced in the specific
area. These information security assessment standards and best practices can be used to add
to the information security knowledge of an organization. By extending Fucher and von
Solms (2008) principle to privacy we can state that information privacy assessment standards
and best practices can be used to add to the information privacy knowledge of an
organization.

Tsoumas, Dritsas, and Gritzalis (2005) supported this concept by pointing out that security
assessments are used by the enterprise to provide them with security knowledge by using a
standardized method for understanding and prioritizing security risk exposures for internal
infrastructure, external infrastructure, and services based resources. The enterprise also uses
Service Level Agreements (SLA) to create a contractual framework between IT and the
business units they serve (Candan, et al., 2009). SLAs define requirements in terms of
services, priorities, and guarantees. Cloud providers also use SLAs to establish an agreed
value for IT services and remediation (Nepal & Zic, 2008).

Doherty and Fulford (2005) reported that these two instruments; security assessments and
service level agreements, combined with security policies, provide a basis for security
knowledge for the enterprise when using external cloud services.

Clarke (2009) suggests that privacy is a strategic variable to the enterprise and that Privacy
Impact Assessments (PIA) adoption is an element of cogent management.

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Privacy impact assessments can be used pre-deployment or after deployment of a system to


determine privacy risks. PIAs have a broad scope which includes the enterprise, its partners,
and the population affected by it. Clarke goes on to suggest that PIAs are anticipatory in
nature (e.g. pre-assess), are broad in scope with regard to the measurement of privacy, and
emphasize the assessment process. Clarke also stated that part of the assessment process in an
organization includes benefits for the organization from the execution of the assessment
process. Results often include organization exchanges of information related to privacy data
and process which in turn broadens context and organizational knowledge.

Clarke’s (2009) research also reviewed privacy impact assessments by jurisdiction including
the United States (US) government and the US private sector. Clarke (2009) stated that the
US government sector uses PIA’s as an outcome instead of a process for improving privacy
design. Clarke additionally stated that the commercial sector only uses a PIA when required
due to regulatory statutes such as the Gramm-Leach-Bliley Act (Gramm-Leach-Bliley Act,
1999). For scope reasons this study will be focused on US privacy law and will therefore only
use either US specific privacy assessments or assessments from international standards
bodies.

The most common PIAs in the US are the ANSI/ISO standard (ISO/IEC 22307:2008, 2008)
and the standardized template used by the Department of Justice (DOJ) and Department of
Homeland Security (DHS) (Clarke, 2009). The ISO standard 22307:2008 differs from the
DOJ PIA in that the ISO standard defines a process that is designed for financial services
evaluation. ISO 22307 PIA is a process that includes a PIA plan, an assessment, competency
evaluation of privacy policy and controls, and a final report. In the ISO, standard internal and
external perspectives are evaluated as part of the process for gaining context of privacy
impact in a project or application.

Yee’s (2009) recent study, which was designed to estimate privacy protection capabilities of
a service provider, noted that research was lacking that dealt with Service Provider (SP)
privacy protections. Yee enumerates the key areas researched on protecting private
information with SPs. Yee defined the providers obligation to build in provisions that gives
users control over the providers collection, retention, and distribution about the user. The
research included an investigation of privacy rights management and privacy compliance.
Yee stated that it is also important to estimate privacy protection capability of SPs for both
the business consumer of the service and the provider. As indicated by Yee, clarity on
privacy protections help the business consumer in the decision making process on which
service provider to use. For the provider it helps them implement services expressed as a
Quality of Service (QoS) requirement.

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In summary, privacy is an area that requires attention for the enterprise due to the risk and
costs of privacy exposure from a breach. Pearson (2009) suggested that the exposures include
loss of governance, isolation failure, compliance risk, and data protection vulnerabilities.
Pearson (2009) went on to show that key characteristics of cloud computing listed by NIST
such as the sharing of resources that are not on premise, and resource pooling technologies
such as multi-tenancy and virtualization introduce new threats to personal and confidential
information. Chow, et al. (2009) suggested that third party data control and transitivity are
key issues when using a service provider.

Methodologies for security risk assessment for cloud computing service providers do exist.
However, a best practices approach that specifically addresses the privacy needs of cloud
computing has yet to be developed and validated via empirical research.

Unlike security assessments which are controls oriented, privacy assessments need to assess
if the information practices sufficiently protect the privacy of a person’s information in the
hands of a custodian (Cavoukian, 2008). Jutla and Bodorick (2005) enumerated seven
specific user privacy protections required for eBusiness including comprehension,
consciousness, choice, consent, context, confinement, and consistency which they based on
the Organization Co-operation of Economic Development (OECD) (Organization Co-
operation of Economic Development [OECD], 1980) guidelines. The seven protections from
the OECD provide us with dimensions for assessing privacy risk.

Research Goal

The purpose of this dissertation is to empirically determine if existing privacy assessment


instruments adequately assess privacy risks when applied to cloud computing service
providers. The hypothesis of this study is that existing privacy instruments do not adequately
assess privacy risk in cloud computing environments. This study helps determine if the
hypothesis is true or false by empirically comparing several privacy assessment instruments
against cloud provider’s environments.

Privacy knowledge can be gained via the use of several instruments. Bennett and Raab (2006)
suggested in their research that laws and regulation define some of the requirements for
access and behaviors with regards to specific types of private information. One example of a
specific type of privacy protection were privacy regulations defined for personal health
information such as the Health Insurance Portability and Accountability Act (HIPAA, 1996).
Financial services companies also have a guideline available which is the ISO/IEC
22307:2008 Financial Services Privacy Impact Assessment (ISO/IEC 22307:2008). The third

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example of privacy assessment lies within existing security assessments which have a subset
of controls that applies to privacy (e.g. ISO/IEC 27002:2005 & NIST SP800-53). While
standards for Privacy Impact Assessments (PIA) do exist, as indicated by Clarke (2009), the
United States currently only requires the government to employ PIA's for government
systems. There is a lack of widespread adoption of privacy assessments by the enterprise in
the U.S.

making it difficult to assess the validity of privacy assessments via empirical data.

Through empirical experimentation this study tested several privacy assessments against
several cloud infrastructures. This study used the privacy impact assessment standards
ISO/IEC 22307:2008, the financial service standard SharedAssessments Privacy Assessment,
and the Department of Homeland Security’s Privacy Impact Assessment (DHS, 2010). The
study produced data that was evaluated to determine if there are significant gaps in these
assessment methods when applied to cloud computing infrastructure services and evaluated
them against the key characteristics of the cloud as outlined by NIST (2009).

Relevance and Significance

Cloud computing provides a new technological and economic model that includes benefits
for IT that reduce cost structure while improving flexibility and reliability (Foster, et al.,
2008). Concern for privacy protection is growing in Internet services (Anton, Earp, and
Young, 2010) which include cloud as a subset (Skene, Raimondi, and Emmerich, 2010).

One approach to solving the privacy risk assessment problem would be to develop domain
specific (e.g. healthcare or financial services) privacy assessments. Huang, Bai, and Nair
(2008) used this approach to develop a risk assessment process for healthcare systems
analyzing privacy in the context of HIPAA requirements. Huang, et al. (2008) mapped their
risk assessment to the Systems Security Engineering Capability Maturity Model (SSE-CMM)
process with the goal of converging HIPPA privacy requirements in a security risk
assessment. The ISO/IEC PIA 22307:2008 standard is designed to assuage the privacy risks
for financial services companies. Clarke (2009) evaluated PIA origins, their development,
and use in public and private sectors in his recent comprehensive survey of global privacy
impact assessments.

Yee’s (2009) claim of a lack of measurement of privacy, Clarke’s (2009) claim that the US
private sector is hostile to being transparent with regards to privacy, combined with the
growth of breaches in size and impact (Williams, 2009) present a case for improved
evaluation as a precursor to deployment of applications in the cloud. While security
assessments provide a basis for understanding the vulnerabilities of the infrastructure they are

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not designed to specifically address the issues related to the privacy of the data which
includes governance, data location (trans-border), compliance with regulations, and
reputation. As the complexity and scale of systems grow due to the adoption of cloud
computing, the threat surface grows as well as new problems such as trusting a third party
with the companies data, resource pooling through virtualization and multi-tenancy, and poor
visibility to controls instituted by the cloud provider. The challenge is to determine if these
same problems create barriers for adequately assessing cloud providers privacy risks.

Barriers and Issues

There were potential barriers to this study. The first barrier was finding and selecting a
sufficiently significant cross-section of privacy assessment methods and creating a
normalized method for comparison. The normalization process is explained in methodology
section. The normalization process provided a method for comparing disparate assessment
methods used to survey the cloud providers. The normalization process was executed before
the assessment process and reevaluated after the assessments were completed to observe the
outcomes and the impact of normalization on the outcomes. The privacy assessment methods
evaluated are qualitative and due to the subjective nature of qualitative methods the
independent variable “privacy assessment” was manipulated by evaluating the different
methods against each cloud provider and correlating them.

The second barrier was the potential reticence of cloud providers to have their environments
evaluated for research purposes. The goal was to find a maximum population of five cloud
providers with a minimum of three providers for the study. The study evaluated their privacy
controls using a privacy survey methodology.

Research Questions & Overarching Hypothesis

Freeman, Darr, and Neely (1997) established that security risk assessment methods have been
a critical part of security programs within the enterprise. The CSA (2010) also recommended
assessment methods adapted to the cloud environment. Yee (2009) defined a quantifiable
measurement system for privacy protection in service provider environments. Yee’s scoring
system for privacy protection established levels of protection so that there can be a
measurable comparison in the quality of privacy protection. Yee commented that research on
measuring privacy protection is needed.

NIST (2009) defined cloud computing main tenets of on-demand self-service, broad network
access, resource pooling, rapid elasticity, and measured service. These cloud specific
characteristics introduce new privacy risks (Caracas & Altmann, 2007; Foster,

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Zhao, Raicu, & Lu, 2008). The purpose of this research is to determine if existing privacy
assessment instruments adequately assess privacy risk in cloud computing environments.

Three privacy assessments instruments will be tested against cloud infrastructures to validate
Yee’s (2009) statement that research on measuring privacy protection is needed.

The research questions that are answered by this study are:

Q1. Do existing privacy assessment methods adequately assess privacy risk exposures of
cloud computing for the enterprise as measured by the privacy assessment comparison
methodology described in the Methodology section?

Q2. By using the scoring system outlined in the methodology section are the new
characteristics in cloud computing such as on-demand/self-service, broad network access,
measured services, shared resources, and elasticity adequately evaluated or accommodated in
existing privacy assessment methods?

In seeking answers to the research questions, the above questions the following directional
research hypothesis was derived:

HA1: The average answerability rate for each privacy assessment (DHS/DOJ Privacy Impact
Assessment, ISO/IEC 22307:2008 Privacy Assessment, and Shared Assessments Privacy
Assessment) at each CSP (CSP1, CSP2, and CSP3) is 95%. Answerability rate is defined as
the ability to acquire a ‘yes’ or ‘no’ response to the privacy assessment question. This
hypothesis then supports the null hypothesis of: H01: The average answerability rate for each
privacy assessment (DHS/DOJ Privacy Impact Assessment, ISO/IEC 22307:2008 Privacy
Assessment, and Shared Assessments Privacy Assessment) at each CSP (CSP1, CSP2, and
CSP3) is > 95%.

Limitations

This study may be limited because its findings may only be generalized for a small
population of cloud-based providers. The restriction on population size is partially due to the
limited number of US based cloud providers at this point in time.

There are also long lists of regulations and localized laws that were not included in this
research. The regulations and laws not included are either not applicable as they pertain to
individuals and this study was done on behalf of companies (from a corporations view).
Second, the key areas of concern to a corporation regarding privacy risk are the information
assets that apply to healthcare information, financial information, and personally identifiable
information as it relates to an individual and their credit card data. Lastly to manage the scope

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of the study 48 of the 50 states in the US have state specific regulations that cannot be
generalized as they are state specific. Generalisability is also potentially a limitation of this
study due to the lack of sufficient study population, the current maturity of cloud computing
and standards, and the evolutionary state of privacy regulation and technology.

Delimitations

This research excludes evaluating cloud providers based in other countries effectively
reducing regulatory and legal ramifications of the study. This study was focused on local to
US installations to keep the scope within privacy practices within the US regulatory realm.

Assumptions

This study assumed that the privacy assessments can also adequately assess privacy risk in
cloud computing environments so the experiment was targeted at commercial cloud
computing providers and how they met the privacy requirements of the enterprise. Privacy
assessments are methods that employ an instrument and a process designed to determine the
risk of privacy exposures to an organization or an individual (Pearson, 2009).

Definition of Terms

For the purposes of this research:

• Amazon Web Services is a cloud computing platform offered over the Internet which
includes a set of standardized infrastructure services including compute, web server, storage,
database, and more (Amazon Web Services AWS, 2010).

• Amazon Elastic Compute Cloud is defined as Amazon Web Services compute service that
scales up and down automatically and provides resources on a pay as you use it basis
(Amazon Web Services EC2, 2010).

• Amazon Simple Queue Services is defined as Amazon Web Services queue service that
provides a scalable message service for developers to connect distributed components of
AWS services together. (Amazon Web Services SQS, 2010).

• Amazon Simple Storage Service is defined as Amazon Web Services storage service that
scales up and down automatically and provides storage resources on a pay as you use it basis
(Amazon Web Services S3, 2010).

• Assessment is defined as a process that provides a systematic review of risks and threats
with measures that lower risk to an acceptable level (Peltier, 2005).

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• Autonomic Computing is defined as computing systems that can manage themselves which
includes self-servicing, self-configuring, self-healing, and auto-scaling (Kephart & Chess,
2003).

• Broad Network Access is defined as the ability to access cloud resources from the network
via heterogeneous thin or thick client platforms including mobile phones, or laptop (NIST,
2011).

• Cloud Computing is defined as a large scale, distributed computing platform that is


dynamically scalable, provides infrastructure, development platforms, and application
services on demand with a pay-as-you-go model to external customers over the Internet
(NIST, 2011).

• Cloud Deployment Models include:

O Private Cloud is defined as a cloud that is operated for one organization and can be
managed by the organization or by a third party. It may reside internally to the organization
or off premise (NIST, 2011). o Community Cloud is defined as a cloud that is shared by
organizations with common concerns such as their mission, security level, or compliance
requirements. Like the private cloud it may be managed by the community or by a third party
and may exist internally to the organizations or off premises (NIST, 2011).

o Public Cloud is defined as a cloud that is shared and available to the general public and is
owned and operated by an organization that sells cloud services (NIST, 2011).

o Hybrid Cloud is a cloud that is a composition of two or more clouds or cloud types (listed
above) that are connected via standards based or proprietary technology that enables data and
applications portability (NIST, 2011).

• Cloud Service Models include: o Software as a Service (SaaS) is defined as a capability for
customers to use applications that reside in the cloud and can be accessed from various
clients such as a web browser. The customer does not manage the application, development
environment, or infrastructure (NIST, 2011).

o Platform as a Service (PaaS) is defined as a capability for customers to deploy or build


applications using programming environments and tools managed and deployed by the
provider. The customer does not manage or control the underlying infrastructure (NIST,
2011).

o Infrastructure as a Service (IaaS) is defined as a capability for customers to provision


processing, storage, networks, and other infrastructure based services that allow the customer

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to deploy and run software supported by the infrastructure. The customer does not have
access to the underlying cloud infrastructure but is a tenant on the shared resources provided
to IaaS customer (NIST, 2011).

• Dynamically Scalable is defined as possessing the ability to manually or automatically,


quickly, and elastically provision resources to scale up, down, out, or in as needed (NIST,
2011).

• Enterprise is defined as one or more organizations with common mission and goals offering
services or products (ISO 15704. 2000).

• Federation is defined as a collection of resources managed as one single domain which


allows interoperability “on the fly” via adaptation (Chen, Doumeingts, & Vernadat, 2008).

• Information Privacy is defined as the ability of a person or organization to decide if, when,
and to whom information about them is released (Saltzer and Shroeder, 1975).

• Instrument is defined as a tool designed to collect and measure an attribute or trait of a


particular entity or entities such as Service Level Agreements efficacy (Skene, Raimondi, and
Emmerich, 2010) or security risk (Hermann, 2007) or privacy risk assessment (Clarke, 2009).

• Location Transparency is defined as the ability to request data without needing to know
where the information is stored. This includes the ability to materialize information by
computing it or transferring on-demand (Foster, Zhao, Raicu, & Lu, 2008).

• Measured Services is defined as metering systems that are in place at the right level of
granularity to provide monitored, controlled, and reported service utilization (NIST, 2011).

• Multi-tenancy is defined as resources pooled with location independence and assigned and
reassigned with control or knowledge of the exact location by the consumer (NIST, 2011).

• On-demand self-service is defined as the ability for the customer to provision resources
available in the cloud automatically without having to engage the cloud service provider
(NIST, 2011).

• Pay-as-you-go is defined as an economic model in which enterprise customers of cloud


service providers use measured services and the cloud providers charge for services the used.
Internal IT departments can use the same mechanisms to offer services on a for-fee
(chargeback) basis (NIST, 2011; Palankar, Iamnitchi, Ripeanu, & Garfinkel, 2008).

• Rapid Elasticity is defined as the property of a system where resources that can be acquired
or released automatically and will rapidly allow the customer to scale up, scale out, or reduce
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scale with the provisioning to appear limitless in terms of the resources available (NIST,
2011).

• Resource Pooling is defined as an arrangement where resources such as computing, storage,


and network bandwidth are provided from collections that are multi-tenant in design and
dynamically assigned to a consumer based on demand (NIST, 2011).

• Security Risk Assessment is defined as an instrument that is used to characterize and


measure threats, probability of occurrence, vulnerabilities, harms, costs, and countermeasure
effectiveness (Freeman, Darr, & Neely, 1997).

• Transitivity is defined as the propagation of something such as trust, privacy protection, or


service level through one or more intermediaries (Weaver & Wu, 2009).

• Trojan is defined as programs that seem useful or needed that contain something harmful to
the security of the system (Tiller, 2007).

• Ubiquitous Network Access is defined as accessibility to cloud services can be accessed via
standard mechanisms on heterogeneous networks and platforms with thin or thick client
capabilities (NIST, 2011).

Summary

In summary, security and privacy risks in the cloud are a key concern for companies
considering using cloud services from a CSP (Skene, Raimoni, & Emmerich, 2010). New
technologies in the cloud such as sharing resources with unknown entities (Pearson, 2009)
and reliance on the service provider’s security and privacy controls (Chow, et al. 2009) imply
that existing assessment methods for measuring and mitigating the risks also need to evolve.
Security risk assessments have been adapted to the cloud (CSA, 2010) while privacy risk
assessments have not been adapted nor have they been evaluated empirically.

This research effort focused on evaluating the adequacy of current privacy risk assessment
instruments in the context of cloud computing to determine whether they sufficiently assess
privacy risks. An additional outcome of this research effort is a list of gaps that need to be
addressed via an improved privacy assessment methodology and instrument. This study was
designed to further the research on privacy risk assessment methods as a part of the
measurement problems (Yee, 2009). It can improve privacy risk measurement as a key
element of a more holistic approach to improving privacy knowledge (Tsoumas, Dritsas, and
Gritzalis, 2005) as it pertains to information technology usage in the enterprise.

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CHAPTER 2
LITERATURE REVIEW
Introduction
The study examined the adequacy of existing privacy assessment instruments for evaluating
cloud service providers. The issues relevant to this study include defining what privacy is and
what the common information technology risks for the enterprise are.
In addition, an examination of the literature and standards bodies is included to identify,
review, and compare privacy assessment instruments and their ability to identify the specific
factors that are required to assure adequate privacy protections.
Next the literature review for this study examined the definition of cloud computing, its
benefits to the enterprise, and the new privacy challenges introduced. Next the review
surveys whether the privacy concerns are exacerbated in the cloud due to the key
characteristics of the cloud. A review of the relevant literature provides a current view of
these topics and reveals open issues that remain unresolved.

History of Privacy

A good starting point is to begin with a clear definition of security and privacy as they relate
to information technology and what the differences are. Saltzer and Shroeder (1975) defined
information security as mechanisms and processes that control who can use or modify
information or the computers in which the information is stored. They defined information
privacy as the ability of a person or organization to decide if, when, and to whom information
about the person or organization is released. Though these definitions are somewhat dated,
they have stood the test of time with contemporary privacy scholars restating them in their
research. As an example, Jutla & Bodorik (2005) defined the “7C’s” of privacy which
included notice, control, and obligations regarding information deemed private. Spiekermann
and Cranor (2008) stated that the risk of personal data abuse is mitigated with appropriate
security controls supporting the Saltzer and Shroeder definition. In the context of the

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enterprise, Smith (2004) stated that private information relates to information that companies
value as intellectual property, information about their customers, and about their employees.
The history of technology-based privacy concerns in the United States began with a historic
paper by Warren and Brandeis (1890). They outlined the right to privacy as a right to be left
alone and were concerned with the advances of modern enterprise and the misuse of
technology. At the time cameras were being used by newspapers that were publishing
pictures in the newspapers without the consent of the photographed individuals. Later,
additional attributes of privacy included allowing the individual to control the collection and
use of personal information (Westin, 1967). The concerns over privacy exposures due to the
misuses of technology in general and, more recently, the result of specifically using computer
based technology, have grown over the last 30 years.
Milne (2000) argued that Internet privacy requires technological improvements and
legislation regarding notice and use between marketers and consumers. Kleinrock’s (2004)
review of the 35th anniversary of the Internet articulates a discussion on the unintended
consequences of a world of networked machines. He elaborated that the Internet has a dark
side invading our privacy, tracking our behavior, and disobeying the laws of countries.
Nemati, & Sadri (2007) specifically raised the issue that with data doubling every two years
combined with the use of data aggregation and mining tools, privacy issues will continue to
be exacerbated by technological innovation. This is due to technological sophistication,
growth in scale, increase in the intrinsic value of information, and the dissemination of
information (Kleinrock, 2004).
Lanier and Saini (2008) defined three corporate privacy issues: privacy policies and notices
via the use of fair information practices (FIPs), challenges in legal and business terms for
consumer privacy protection, and balancing both managing and communicating privacy
protections while competing effectively and efficiently. They went on to suggest that
harmonizing privacy protections in building trust while controlling the cost of compliance is
of critical importance.
Solove (2008) argued that privacy is a concept that is in disarray, pointing out that it means
different things to different people, that no one can define it, and that different roles in society

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have a different conception of privacy. To assist with this confusion of the definition of
privacy, Solove (2008) created a taxonomy for understanding harmful activities: information
collection, processing and dissemination, and invasion. Solove (2008) contended that
information processing problems are systemic and the result of “architectures of
vulnerability” (pg. 178).

What are the Privacy Risks?

The enterprise’s concern for privacy loss in the cloud is based partially on previous history of
privacy breaches of enterprise online services. Examples include AT&T’s loss of 19,000
customers’ credit card data (Ortega, 2006) and Monster.com’s loss of 1.6 million customer
records due to a Trojan installed on its online infrastructure (Ortega, 2007). Data losses can
impact an enterprise’s reputation (Acquisti, Friedman, and Telang, 2006) and can eventually
result in increased regulatory response and economic losses (Spiekermann & Cranor, 2008).
In fact, Smith (1994) suggested that enterprises only respond with privacy policy changes due
to external events such as breaches or regulatory pressure.
Companies realize that cloud computing represents an opportunity to improve efficiency and
reduce costs, yet the risk of breach or data loss is perceived to offset those benefits (Antón,
Earp, & Reese, 2002). The fear of loss is from a general notion that the web does not satisfy
privacy protections of intellectual property and individual rights (Wieztner, Hendler, Berners-
Lee, & Connolly, 2005). Privacy breaches of enterprises can also create long term trust
consequences (Acquisti, Friedman, & Telang, 2006). Privacy loss could also occur due to
unintentional leakage simply due to a lack of diligence such as forgetting to shred discarded
analog information stored on paper or digital information on tape or disk (Security and
Compliance, 2008).
Pearson and Charlesworth (2009) outlined four disadvantages to satisfactorily maintaining
privacy assurance in the cloud: exposures of outsourcing, off shoring, virtualization, and
autonomics. For outsourcing they raised the issues of accountability and governance,
transitivity of bona fides of subcontractors, and lax security practices. With regard to off

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shoring they raised the issue of jurisdictional legal and enforcement challenges. Virtualization
obfuscates the location of data and who has access to it while autonomics allow the cloud to
make decisions about what security levels to employ and where data processing could occur
(2009).
These concerns have recently turned into real costs for companies such as Heartland which
lost $12.6 million so far (Vijayan, 2009) from a privacy breach that had regulatory and legal
ramifications. A study by the Ponemon Institute claimed the average cost of a breach incident
for an enterprise is $6.65 million (Ponemon, 2009) with almost 70% of that cost due to lost
customers. According to Acquisti, Friedman, and Telang (2006), Choicepoint suffered a
breach of 163,000 consumer credit reports costing the company $15 million in penalties and
suffered a temporary drop in stock price of almost 25%. Generally speaking, an enterprise is
not driven to solve privacy exposure issues until an external event, such as a breach, or
regulatory requirements drives it to reduce its risk of exposure (Smith, 1994).
In addition to privacy breaches, there are other non-breach related concerns outlined by
Acquisti, Friendman, and Telang (2006) that include monitoring, aggregation, and lapses in
security (operational) controls. They cited several examples of misuse such as RealNetworks
monitoring the listening habits of its customers, DoubleClick’s prospective purchase of
Abacus Direct that would have allowed merging of offline and online customer data for
profiling, and Amazon’s temporary use of differential pricing based on consumer profiles.
Dulipovici and Baskerville (2007) studied the process of personal information becoming
organizational knowledge, and the treaties (e.g. non-disclosure agreements) that define the
distinction. They concluded that an organization may or may not own what it “knows”
thereby introducing the possibility that some personal knowledge may be protected by
privacy rights and not intellectual property law. They also suggested that information systems
that store and share knowledge must have the ability to protect knowledge as both property
and personal attributes.
Hermann (2007) enumerated 972 international security and privacy metrics which are sub-
categorized into compliance, resilience, and return-on-investment. Hermann’s list of metrics
included several privacy instruments such as the U.S. Privacy Act and the OECD Security

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and Privacy Guidelines (OECD, 1980). Clarke (2009) considers the OECD guidelines as a
critical element of a privacy impact assessment process. Clarke suggested that the U.S.
Privacy Act weakened the standard set forth by the OECD by making the requirements in the
Privacy Act very broad and too generalized. An example of missing privacy knowledge
metric in Hermann’s research is “privacy policy management” that is included in the
ISO/IEC standard 27002:2005 and in the ISO/IEC standard 22307:2008.
Establishing trust in an Internet-based system can be accomplished in several ways which can
include regulation, business process controls (governance), and technology. Absence of trust
can come from the lack of sufficient information to establish a level of trust via an assessment
(Nyre & Jatunn, 2009). Sugianto and Jantavongso (2006) determined in their literature review
of Internet-based businesses that Small to Medium Enterprises (SME) need a framework to
assist in eBusiness adoption and success. They went on to suggest that privacy was one of
three key characteristics required in any business transaction and without it confidence and
trust could not be achieved. Araujo (2005) asserted that ease and inexpensive collection of
information and the absence of sufficient regulations are contributors to the lack of trust in
sharing privacy data with Internet based systems.
The cloud makes privacy more challenging by the fact that privacy risks are consigned to
third party vendors and balance must be established between the costs associated with
supplying information versus the benefits provided by the vendors (Cazier, Wilson, &
Medlin, 2007). Cazier, Wilson, and Medlin (2007) described the additional potential for
exposures via their extension of the Technology Adoption Model (TAM) that privacy risk is a
key contributor to IT acceptance.
An example is regulatory and business process trust mechanisms in the healthcare services
arena. These have an established certification process for healthcare provider participants that
are designed to protect an individual’s privacy (Baker, 2006). The certification process
includes technical safeguards that are designed to mitigate risk using the Internet while
affording ubiquitous availability and support for national health management (Baker, 2006).
Nehf, Pitt, and Watson (2007) discussed the relative ease of collecting, aggregating, relating,
and transferring data on individuals, corporations, and governments and how it is being used.

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They contended that legislation and self-regulation are insufficient. Their conclusion was that
the protection of privacy and the entire privacy ecosystem on the Internet is failing.
According to them privacy is lost and as a result of that loss instability is the logical outcome
forcing individuals, companies, and governments to respond by overreacting, withdrawing,
and taking protectionist postures.
Yongxi (2007) cited as one example of the problem caused by privacy breaches the recent
unauthorized leakage onto the Internet of personal data that Hong Kong Government
agencies use as an external online service to their citizens. He reported that the recent events
have created a loss of trust among Hong Kong citizens due to the impact on their privacy
rights when using Internet based government systems. Yongxi (2007) also suggested that the
benefits of eGovernment as a way to transform and improve public policy need to be weighed
against increased risk. According to Spiekermann and Cranor (2008), new complex systems
require privacy functionality be formally designedin and measured holistically.

Security and Privacy Assessment

Spikerman and Cranor (2008) recommendation that privacy be designed into systems also
implied that there needs to be a balance needs between adequate controls and making a
system unusable. They also suggested that privacy requirements definitions to date have been
targeted at specific domains such as healthcare. Anton, Bertino, Li, and Yu (2008) extended
this concept of privacy requirements definition with a clarified vision of privacy policy
lifecycle and introduced the theory of information flow-control based on privacy policies.
An example of privacy research targeted in a specific domain is the research by Anton, Earp,
and Reese (2002) that defined a framework with 23 healthcare-related privacy policies and
inter-related them with privacy requirements. They went on to classify privacy goals and
specify a privacy goal taxonomy that they posited enables an engineer to define requirements
early on in the development cycle. These goals help with the assessment of privacy policies,
requirements, and practices of e-Commerce applications with respect to healthcare.
Papastergiou and Polemi (2008) developed a trustful e-ordering architecture that is designed

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to instill confidence based on security and privacy requirements with respect to European
Union legislation.
These are examples of a priori research that helped define the requirements for privacy,
improved upon privacy and trust via codified controls, and reduced the privacy risk
associated with Internet-based systems with specific assessments aligned to a regulatory silo
or specific business function. This type of assessment would evaluate the full spectrum of
information privacy protection and go beyond existing security assessment methodologies
such as the Common Criteria (2009) that only assess the privacy characteristics of anonymity,
pseudonymity, unlinkability, and unobservability.
Other research has addressed the state of security assessments although it has not specifically
addressed the issue of privacy assessment. Saleh, Alrabiah, and Bakry (2006) developed a
methodology that included Strategy, Technology, Organization, People and Environment
(STOPE). They found that employing a strategy that leveraged the principles of Six Sigma
(2006), their methodology could provide both a holistic and continuous improvement
approach to security assessment. Gupta, Banerjee, Argrawal, and Rao’s (2008) research on
high-risk components of Internet systems showed that by employing a holistic approach
which included dependencies as opposed to the more common atomic assessment, they could
more accurately evaluate uncertainties in component risks and their effect on the total system.
Futcher and von Solms’ (2008) work on applications assessment using security assessment
standards showed that the ISO/IEC 27002 and NIST security guidelines provided the most
comprehensive approach to security management. They argued that with proper education
and by instilling best
practices into the software development lifecycle, software quality and security would
increase. Futcher and von Solms (2008) also specified that security requirements are a result
of a preliminary security risk assessment.
According to Freeman, Darr, and Neely (1997), risk assessments enable IT decision makers
to clarify what state the systems are in and evaluate efficacy (context), to understand how
much protection there needs to be and its purpose (requirements), and to measure the degree
of confidence in the system (exposure). They also defined a hybrid security assessment

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methodology using a guided, top-down approach with sub-systems for large scale
heterogeneous systems.
Hall (1998) stated that risk is based on probability theories and that risk exposure is the
product of the likelihood of a consequence times the loss, denoted L2. Hall (1998) separated
the two steps of risk identification and risk management; into two separate activities in
software engineering methodologies. Hall (1998) went on to suggest that risk management is
the process of resolving risks. Jaquith (2007) outlined risk management as a four-phased
process that includes assessment, reporting, prioritization, and mitigation.
Hall (1998) also suggested that risk identification mechanisms are systematic and iterative
processes that include checklists, assessments, management forms (reviews and reports) and
a risk database. Jaquith (2007) recommended establishing a risk escalation database for use
by employees to log privacy exceptions so that patterns and potential risk exposures could be
proactively cataloged and assessed.
Choosing the right security risk analysis methodology when there are so many choices
afforded caused Vorster and Labuschagne (2005) to create a framework comparing risk
assessments. Their framework was designed to assist the practitioner in choosing a risk
analysis methodology based on a common set of criteria: single or groups of assets, where
and who does the risk analysis, what formula are used and whether the scale is absolute or
relative. They also suggested that many organizations that want to perform risk analysis
treated the process over-simplistically due to the mostly subjective
nature of qualitative surveys that are popular (e.g. ISO 27002).
Other approaches that used the confidentiality, integrity, and availability (CIA) model ignore
the domains of people, process, and technology and their interaction (Hamdi & Boudriga,
2003). Hermann (2007) elaborated with the comment that limiting the scope of systems to
hardware, software, and telecommunications in turn limits the completeness of privacy and
security metrics. They must also include people, process, and supporting infrastructure
(2007).
Contemporary security risk management assessment methodologies often come from
standards organizations such as the United States Government - National Institute of

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Standards and Technology (NIST) (e.g., NIST SP800 series), academic research institutions -
Carnegie Mellon University’s (CMU) Software Engineering Institute (SEI) (e.g., OCTAVE -
Operationally Critical Threat, Asset, and Vulnerability Evaluation), and ISO (International
Organization for Standardization) (e.g., Common Criteria Standard ISO/IEC 15408) (NIST,
2011; OCTAVE, 2009; ISO/IEC, 2009). Defense Healthcare Information Assurance Program
(DHIAP, 2003) evaluated these security risk management standards and showed that privacy
risk assessments are a small subset of these frameworks and few include quantitative metrics.
Hermann (2007) listed 972 security and privacy metrics of which less than 10% are privacy
metrics localized to the United States. Hermann emphasized security knowledge management
and did not offer guidance on privacy knowledge management.
As another example, OCTAVE (2009) only mentioned privacy in the introduction since it
was designed to address the compliance requirements for securing the personal health
information as required by the Health Insurance and Portability and Accountability Act
(HIPAA). OCTAVE was not designed specifically to evaluate privacy risk exposures, and
OCTAVE did not include a quantitative method (Vorster & Labuschagne, 2005). As the need
for security levels increases due to the design of a web-based system, privacy requirements
are often left out of the design (Yu, Doddapaneni, & Murthy, 2006).
OCTAVE has inspired researchers such as Gutierrez, Fernandez-Medina, & Piattini (2006) in
web services (WS) requirements elicitation with regard to security.
Gutierrez, Fernandez-Medina, & Piattini (2006) specifically looked at consumer vs. provider
service protections, attacker profiles, and Quality of Service (QoS) measurements using
Unified Modeling Language (UML) profiles and an attack impact assessment. Their
specification of a process for web services security was designed to improve the ease with
which a developer could coordinate security mechanisms in web services design. Privacy was
not specifically called out in the design leaving the specification of privacy controls up to the
developer. Research combining user preferences and security requirement analysis has
generated prioritized lists usable in assessments. However, the lists lack specific privacy
measurement and recommendations (Romero-Mariona, Ziv, & Richardson, 2008).

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Bennett and Raab (2006) stated that privacy impact assessments present a way to evaluate
risk of new systems before they are implemented and are a way to understand the price tag of
a policy. Both Bennett and Raab (2006) and Clarke (2009) state that Privacy Impact
Assessments (PIA) are rooted in the methods used in industrial practices where impact on the
environment is a key part of a new manufacturing process. Bennett and Raab (2006) also
suggested that PIA evaluation could be implicit or explicit for evaluative measurement of
invasion and its inverse – protection. Clarke (2009) declared that PIAs are anticipatory in
nature (e.g., pre-assessment), are broad in scope with regard to the measurement of privacy,
and emphasize the assessment process. Clarke (2009) also stated that part of the assessment
process in an organization includes benefits for the organization from the execution process.
One of the benefits are the results of the assessment which often include increased
organizational knowledge through exchanges of information related to privacy data and
process as they apply to the applications being assessed.
To summarize this section of the literature review, elements of privacy assessment were
found within security assessments such as ISO 27002 and in pre-assessments as part of PIAs;
what appears to be lacking in prior research is a comprehensive and specific privacy risk
assessment methodology and related research.

Cloud Computing

Tanenbaum and Steen (2007) identify the distributed computing models used today which
include Client/Server (CS), Grid computing, and Peer-to-Peer (P2P). Distributed computing’s
most recent instantiation is called Cloud computing (Foster, Zhao, Raicu, and Lu, 2008),
which is the logical progression from Grids which are silooriented to service-oriented
architectures (SOA) that are composed of dynamic virtual environments with automated and
shared services (Gentzsch, 2009). Foster, Zhao, Raicu, and Lu (2008) stated that scientific
and commercial enterprises view cloud computing as a new paradigm in Internet-based
distributed computing. Companies providing services on the Internet are being driven to a
shared infrastructure model as opposed to owning and operating their own infrastructures

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(Candan, Li, Phan, & Zhou, 2009). According to Ross and Westerman (2004), this new
distributed computing platform is one that holds promise to make the enterprise more agile,
competitive, and reduce costs while
optimizing resource utilization.
Pym and Sadler (2010) suggested that Cloud computing is made up of information
ecosystems of service providers whose purpose is to allow more automated and formalized
federations while reducing costs and improving service delivery. As indicated by Davis and
Sedsman (2010) businesses are interested in cloud computing services due to the promise of
reduced IT expenses. Davis and Sedsman (2010) go on to state that the centralized
provisioning of services by a CSP reduces the need for IT to maintain internal servers,
software licenses, support staff, and facilities. CSPs in turn can leverage scale to provide
lower costs, improved service levels such as continuous global access, software update and
maintenance, and security services (Davis and Sedsman, 2010).
NIST (2009) defines cloud computing as having key characteristics, specific delivery models,
and deployment models. Pearson (2009) listed the key characteristics defined by NIST as
including the sharing of resources, and resource pooling technology such as multi-tenancy
and virtualization. NIST’s (2009) elaboration of the key characteristics also mentions
ubiquitous network access, dynamic scalability providing elastic resource provisioning,
measured or metered services, on-demand and self-service, and using a pay-as-you-go or
subscription model. NIST also specified several deployment models: private cloud,
community cloud, public cloud, and hybrid cloud, which are unique to the cloud architecture.

Cloud Benefits

This new distributed computing platform is one that holds promise to make the enterprise
more agile, competitive, and reduce costs while optimizing resource utilization (Ross &
Westerman, 2004). The benefits of emerging technologies such as Cloud for the enterprise
can maximize performance and synergies (Rouse & Acevedo, 2004).

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Cloud Privacy Challenges

With every new distributed computing model arise common concerns regarding security and
privacy. According to Foster, Zhao, Raicu, and Lu (2008) new exposures exist due to the key
characteristics and deployment models of cloud computing. They specified seven security
risks of cloud computing which all pertain to the privacy of data: privileged user access,
regulatory compliance, data location, data segregation, recovery, investigative support, and
long term viability. Privileged user access risk is exacerbated by storing a company’s
information on a CSP’s infrastructure where a privileged user may have access to all tenants
on the shared infrastructure. Regulatory compliance can be assured by the CSP via external
audits and certifications. Many CSPs now tout SAS70 Type II compliance to instill a level of
trust (Pauley, in press).
Hayes (2008) stated that in the cloud computing model the concerns of privacy protections
are further exacerbated due to the requirement for an enterprise to allow third parties to own
and manage the infrastructure and to be custodians of the enterprise’s information. Data
location is often regulated by the each individual country’s privacy laws or specific domain
regulations. A key characteristic of cloud is location independence, putting this privacy
requirement in conflict with privacy laws requiring authorization before the information can
be transferred to another jurisdiction (Foster, Zhao, Raicu, & Lu, 2008). One example of a
jurisdictional requirement for systems deployment is financial information systems which
have to undergo a Privacy Impact Assessment due to the Financial Services Modernization
Act of 1999 (Clarke, 2009).
Shared infrastructures that are multi-tenant also need to ensure that data segregation is
maintained to guarantee privacy of one customer’s data from another even though
infrastructure resources are shared (Foster, Zhao, Raicu, & Lu, 2008).
They stated that recovery via replication or backup assurances are necessary if a disaster
occurs. The copies of the information pose privacy risks inherent in storing copies; providing
access to the copies, erasure techniques, and depending on the use of technology such as
magnetic tape may create additional exposures (Nahra and Rein, 2008). Foster, Zhao, Raicu,

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and Lu (2008) cited that investigative support (e.g. forensics), which is a requirement in
PIAs, is difficult with CSPs. The final issue cited was long term viability.
They raised the issue of the possibility of the CSP being acquired which suggests that
concerns regarding the viability and transitivity of privacy policies and guarantees between
the original CSP and the acquirer.
Chow, et al. (2009) stated that cloud computing is a new IT procurement model and due to
the lack of control in the cloud, companies are only putting less sensitive data in the cloud.
They went on to suggest that there are new problems in the cloud related to the abundance of
data and cheap data mining resources, massive centralized targets for breach, indirect data-
mining performed by the CSP by analyzing transactional and relationship information, mash-
up authorization exposures, and the lack of cooperative terms between CSPs and
subcontractors that enable intransitive protection.
Hu and Klein (2009) identified several new privacy risks in cloud computing including a
diminished concept of ownership and, hence, liability due to the pay-as-yougo financial
model. Additionally, they suggested that multi-tenancy, shared resource models and dynamic
instantiation can introduce uncertainty in data location. They also defined rules for encrypting
specific data types as a business requirement to prevent privacy exposures. These data types
were defined as reference data and transactional data. They identified user reference data
types such as personal/company information, identification and authorization data, and
customized or personalized data. The transactional data included business events such as
order and invoices which are information assets that are often shared between a company, its
partners, and customers.
Mowbray and Pearson (2009) stated that cloud computing services are provided on hardware
that is not owned or operated by the customer. They went on to suggest that cloud computing
is more cost-efficient than owning and operating the infrastructure due to the shift from a
capital expense model to an operational expense model based on actual usage. They stated
that there are also new challenges to data privacy due to the reliance on a third party to
adequately protect the company’s data. The data is not generally encrypted in these
situations. They pointed out that the threats include unauthorized use of the data by the

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service providers and the potential of theft of the data. They cited a case where
Salesforce.com was breached resulting in customer email and physical addresses were stolen
using a phishing attack. Mowbray and Pearson (2009) also highlighted that different country
regulations may restrict processing and placement of personal or sensitive information on
systems that do not adhere to the regulatory requirements.
Huebscher and McCann (2008) described a higher level of automation based on autonomics
that are goal-directed instead of event-based, suggesting that systems be able to take initiative
versus purely acting in response to environmental events. Nepal and Zic (2008) stated that
event-based designs contain deficiencies inherited due to the static nature of current risk
management and mitigation methodologies. They went on to suggest that dynamic
collaborations must contain an eContract that captures the service contributions and service-
level agreements. Clarke (2009) listed a set of characteristics in privacy assessment requiring
an emphasis on the process, which consists of information exchange, organizational learning,
and executive engagement thereby inferring an analog iterative process. Such an analog
process poses a problem for the highly automated environments that clouds are designed to
be (Foster, Zhao, Raicu, & Lu, 2008).

Cloud Exacerbates Privacy Exposures

Existing technologies that have prominence in the data center and in grid computing are now
being adapted to the cloud (Foster, Zhao, Raicu, & Lu, 2008). These technologies include
virtualization, autonomic capabilities, on-demand provisioning, resource pooling, and service
isolation which are all traits of grid computing that can be incorporated (or inherited) into the
cloud (McKee, 2005; Foster, Zhao, Raicu, & Lu, 2008). Erdogmus (2007) reviewed the
benefits of on-demand services such as the ease of management, scalability, and freedom
from managing upgrades of software and hardware; however, the risks of security are also
designed into the platform. Erdogmus (2007) also suggested that executives consider the
issue of privacy more prominently in their decision-making process.

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The enterprise has traditionally protected itself using firewalls to form a ‘Chinese Wall’ with
regard to security and privacy at the edge of the data center. Kapadia, Naldurg, and Campbell
(2007) suggested that this type of protection does not extend to the cloud due to its
inefficiency in distributed environments semantically requiring a priori knowledge of any
user’s history. One tenet of cloud computing is location transparency which Foster, Zhao,
Raicu, and Lu (2008) stated poses a challenge when cloud-based systems span jurisdictional
and administrative boundaries. McLaughlin (2008) pointed out that trans-border dataflow is
common for mature applications run by global companies and as they shift to newer
technologies, or young companies implement their services on the Internet, the problem will
continue to grow. McLaughlin (2008) also observed that each country has its own law and
regulations, many of which have different requirements and constraints which, in turn, forces
nation states to devise new regulations to protect their citizens’ information.
The data that is protected by HIPAA is subject to privacy rules regarding the storage and
sharing of information (Baker, 2006). If the cloud provides data and access transparency;
how are jurisdictional and access protections ensured? By design, cloud systems make the
location of the data transparent to the user and, possibly also the owner of the data (e.g.
enterprise) (Foster, Zhao, Raicu, and Lu, 2008). Cloud software infrastructure can make
autonomic decisions to relocate data based on policies such as data protection (e.g. cloning or
replication) (Huebscher and McCann, 2008; Leavitt, 2009) that enterprise architects have to
consider in their use of the cloud. There are also process related issues that are a portion of
the jurisdictional problem. Cloud systems are designed to be extremely resilient. To satisfy
the availability requirement, the information can be autonomically migrated (Kephart and
Chess, 2003) thereby maintaining the
Quality of Service (QoS) requirement while possibly voiding jurisdictional regulations.
Multi-tenancy in the cloud is the sharing of resources and potentially sharing common
applications. Garfinkel (2007) evaluated Amazon’s cloud computing services as a potential
model for moving a scientific application to the cloud. The evaluation included ease-of-use,
service-level agreement using Amazon Web Services (AWS): Elastic Compute Cloud (EC2),
Simple Storage Service (S3), and Simple Queue Service (SQS). During the evaluation

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Garfinkel (2007) found that Amazon does not guarantee privacy for its shared (multi-tenant)
storage service. Amazon stated in its security white paper (Amazon Security, 2008) that
storage blocks given back after use are available to any other tenant. The privacy protection
mechanism is only that the blocks will only accept writes when it is allocated by a new
tenant.
The Internet is the connection to cloud resources. In 2004 Leonard Kleinrock (Kleinrock,
2004) reviewed the tenets of the Internet 35 years after his famous experiment that
culminated in logging into a remote host across the state of California on the ARPA network.
Kleinrock (2004) revealed the five initial tenets of which he felt four have been met, and
described the dark side of the Internet that includes an invasion of privacy that is not
adequately protected today by the Internet (technology) or regulation. This exposure is
further exacerbated by weak ISP (Internet Service Provider) regulations and the Patriot Act
(Kleinrock, 2004) allowing all data traversing and at rest on the Internet to be reviewed.
Pan-jurisdictional data protections for specific data types (e.g. healthcare) are reasonably well
defined by regulations. Pfähler and Weber-Jahnke (2008) evaluated the security of a specific
healthcare system that was originally designed to run inside a service provider’s data center
as a net-centric implementation. During their assessment of a specific system they found that
there were numerous vulnerabilities that were “new” when running the application on the
Internet. One specific concern raised by was the location of the data stored on the Internet
and another was the new exposure of having data downloaded across jurisdictional
boundaries.
Virtual Machine image migration across domains or shared images pose a new privacy
exposure (Keahy, Foster, Freeman, Zhang, & Galron, 2005). Many enterprises rely on
virtualization technologies as well as cloud providers such as Amazon and Salesforce.com.
Spiekermann and Cranor (2008) suggested that the development community consider the
growing complexity of distributed systems and that privacy engineering needs to be designed
in, and executed, as a holistic endeavor – this would include preand- post implementation
privacy assessments. Yee (2006) defined a scoring system for privacy protection levels so
that there can be an implied improvement in the quality of privacy protection with service

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providers. Yee went on to suggest that privacy audits and privacy impact assessments are
methods for finding vulnerabilities and help identify new classes of privacy vulnerabilities.
Yee also stated that privacy assessments could provide more comprehensive understanding of
the exposures and stated that more research is needed to prove this out. Clarke (2009)
enumerated the benefits of privacy impact assessments as anticipatory and proactive risk
management as opposed to post implementation methods. He went on to state that
organizations can use PIAs to demand more information and consultation on how information
systems are designed to protect privacy and how private information will be put to use.
Summary
This chapter presented a comprehensive review of the related literature. It began by
addressing the definitions of privacy and how the risk of privacy exposure has grown in terms
of importance to the enterprise. The next section related the depth and breadth of security
assessments and their role in identifying risks and assisting in the development of
requirements. The chapter reviewed security assessments and showed the lack of privacy
assessment methods. The next section of the chapter defined cloud computing and its inherent
benefits to the enterprise and suggested that cloud computing also exacerbates existing
privacy exposures and creates new exposures. Additionally, as the latest type of distributed
computing platform, several of the new characteristics of such as multi-tenancy, location
independence, and new pay-as-you-go economic models have never been evaluated for their
privacy risks nor have privacy assessments been tested in this context.

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CHAPTER 3

RESEARCH METHODOLOGY

Introduction

The purpose of this chapter is to detail the design of the study including the hypothesis that
was tested in this study, a description of the proposed population of this study, details of the
instruments used to collect data relevant to this study, and descriptions of the procedures that
were used to collect data. The goal of the study was to determine if existing privacy
instruments adequately assess privacy risks in cloud computing environments. The
methodology used was an empirical field experiment using an exploratory design (Sekaran,
2003). The study attempted to determine if there are weaknesses in existing privacy risk
assessment methods when utilized in the cloud context. Applications running on the cloud
differ widely and resources in cloud computing are shared making it more likely that
customers would have diverse preferences regarding their privacy risk standards tolerance.

This study was executed in a three-stage process which is explained at a high level here as
part of the introduction and is explained later in more detail. Since different privacy
assessment methods are designed to expose different privacy risks (e.g., healthcare verses
financial services) Stage 1 included taking the selected privacy assessments (PA) and
rationalizing them along a common set of dimensions (Notice, Access, Consent, Permissions,
Regulations and Data Flows, and Management and Organization). Stage 1 also included
creating one instrument survey that has sections specific to each instrument with columns for
supporting data collection and scoring. In Stage 1 a Reference Application Architecture
(RAA) was defined to test the privacy assessments within the cloud computing context. The
RAA is a pre-defined architecture that has specific privacy requirements to test against the
key characteristics of the cloud.

The final part of Stage 1 was choosing appropriate cloud providers based on their ability to
provide services via a self-service portal that supports the requirements of the Reference
Application Architecture.
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Stage 2 included acquiring agreements from the cloud providers to execute the study, and
then executing the actual study with the providers. The testing was executed in four iterations
with the first two iterations being executed completely in self-service mode. Self-service is a
key cloud characteristic as defined by NIST (2010) and is a method where a consumer can
use services provided by the service provider’s web portal which are open to the public to
provision services in a fully automated manner without any assistance from the service
provider. Service providers share some information regarding their services including
security policies, privacy notices and service levels.

Other information must be acquired by being an actual customer. The third iteration was
executed using the self-service portal that the CSP provides for customers to interact with
their online customer service. The fourth iteration was executed by interacting with
whomever the customer service department escalates to if they couldn't answer the
instrument’s questions within the customer service function. In the fourth iteration the
contacts were business development or the CSO/Security organization within the cloud
provider via any means possible (e.g. phone, email, Twitter, via another contact at the
company, etc.).

Stage 3 entailed data analysis and summarization, and reporting the findings which are
detailed later in this document in design section under the heading “Stage 3 - Data Analysis
and Report on Findings”. Experimental methods are often executed in a contrived lab
environment and then as a natural field experiment (Sekaran, 2003). Due to the lack of
resources for a contrived environment this research selected and tested three privacy
assessments against three real CSPs. The privacy assessments were selected by choosing
exemplars from the standards and best practices that have been ratified by standards or
industry organizations in the US. The privacy assessments were tested in an iterative fashion
with each iteration designed to complete more of the assessment. For example, if all the
privacy assessment questions could be answered in the first iteration against that cloud
provider then that assessment is complete, which was the case with two of the cloud
providers. If all the answers could not be answered in a self-service mode then the study of

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that assessment on that cloud provider continued to the next iteration as a customer still in
self-service mode. If the answers were not all answerable then the study continued to the next
iteration that included contacting customer service. If all answers were not acquired in the
third stage then the fourth iteration was executed by contacting someone in the business or
security office. If all the answers still could not be acquired then the questions that could not
be answered were logged and that assessment against that cloud provider was completed with
unanswered questions. Testing the assessments in the cloud environments provided patterns
of phenomena and data collected to support the hypothesis. The observations expected are
derivatives of the methodology. Such as; if all the same questions can't be answered by a
particular assessment for all the cloud providers, that suggests a different result than if the all
questions can be answered by one provider and not answered at a different provider.

This study employed nonparametric statistical analysis to assist in determining what the key
observations are for the risk scoring across the Privacy Dimensions (PD).

The PDs are (Notice, Access, Consent, Permissions, Regulations and Data Flows, and
Management and Organization) and were correlated to the five Cloud Tenets (CT)
(ondemand/ self-service, broad network access, measured services, shared resources, and
elasticity) explained in detail in the design section of this chapter.

Due to the nature of the assessment and ensuing analysis all companies included in the study
have been anonymized. The hypothesis of this study is to determine if existing instruments
adequately assess privacy risks in cloud computing environments.

This study determined if the hypothesis is true or false by empirically comparing three
privacy assessment instruments against three cloud provider environments.

Design of the Study

The approach in this study was to empirically compare three existing privacy assessment
instruments in cloud environments and determine their adequacy in cloud environments. The
assessments chosen included exemplars from a standards organization, a government

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organization, and a financial services organization. A diagram is provided below in Figure 1


depicting the study design.

Figure 1, Methodology for each cloud provider in the study

The process for determining each privacy instruments adequacy began with finding suitable
cloud environments. Once suitable cloud providers were found an application of each privacy
instrument was tested against the cloud providers in selfservice mode. Self-service mode is
defined as the ability for a customer to provision and use resources in the cloud without
having to interact with the CSP (NIST, 2011). This determined if the privacy assessment
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could be executed in self-service mode which is one of the tenets of cloud computing (NIST,
2011).

Pre-assessments are commonly called privacy impact assessments (PIA) (Clarke, 2009). PIAs
are designed to determine if the environments are prepared and designed to protect the
information that is intended to be stored or accessed in the system being assessed before it is
actually deployed or implemented. Assessment is the first step in most risk management
methods (Peltier, 2004). To facilitate the comparison, a Reference Application Architecture
(RAA), which is a hypothetical application, was used to provide a consistent benchmark to
test the privacy protections of an application. In this study the CSPs selected were selected
based on their ability to support the requirements of the RAA. The RAA is simply a
hypothetical application that would include the storing, processing, and sharing of data that
requires the enterprise to ensure privacy protections.

The RAA also utilized capabilities that are unique to the cloud. For the study this RAA
application included a web server, a database, and an application that could be accessed by
users from outside the cloud via the Internet.

The methodology used was an empirical field experiment using an exploratory design
(Sekaran, 2003) to establish the weakness in existing privacy risk assessment methods when
utilized in the cloud context. Clarke (2009) claimed that privacy assessments are designed to
evaluate systems design, privacy data, and management of privacy processes. He went on to
state that outcomes from privacy assessments include organizational learning, design
adaptation, and information exchange problems and solutions.

Sekaran (2003) observed that the steps for executing a valid experimental methods are
executing them first in a lab environment and then following that with a field experiment.
However, due to the lack of a priori research and a small population of public cloud providers
in the US, this study selected a small population of cloud providers. The cloud providers were
selected based on ability to meet basic requirements criteria of the five key cloud tenets (on-
demand/self-service, broad network access, measured services, shared resources, and

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elasticity), and providing services in one of the three cloud delivery models (IaaS, PaaS, or
SaaS) (NIST, 2011). The research questions explored include:

• RQ 1:Do existing privacy assessment methods adequately assess privacy risk


exposures of cloud computing for the enterprise as measured by the privacy
assessment comparison methodology described below in the methodology section?
• RQ2: By using the scoring system outlined in the methodology section are the five
tenets in cloud computing (on-demand/self-service, broad network access, measured
services, shared resources, and elasticity) adequately evaluated or accommodated in
existing privacy assessment methods?

Hypothesis Tested

The hypothesis evaluated in the study is:

HA1: The average answerability rate for each privacy assessment (DHS/DOJ Privacy
Impact Assessment, ISO/IEC 22307:2008 Privacy Assessment, and Shared
Assessments Privacy Assessment) at each CSP (CSP1, CSP2, and CSP3) is ≤ 95%.

and the following null hypothesis:

H01: The average answerability rate for each privacy assessment (DHS/DOJ Privacy
Impact Assessment, ISO/IEC 22307:2008 Privacy Assessment, and Shared
Assessments Privacy Assessment) at each CSP (CSP1, CSP2, and CSP3) is > 95%
Simply stated, if less than 95% of the questions could be answered with a "Yes"

or “No” then the result > 95% making the null hypothesis (H01) the result. 95% was chosen
as a high confidence interval (Corder and Foreman, 2009) providing a reasonable measure of
answerability rate with the PA requirements. If the findings were consistent with HA1 then it
can be inferred that privacy specifications were inadequate and the opposite would hold true
for the null hypothesis H01.

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Procedures:

This research study was performed in three stages and each phase has multiple steps
in it.

Stage 1 – The Preparation Stage

Stage 1 (S1) included three steps. The first step was to develop a process for creating
specific privacy dimensions to categorize the different survey questions in the privacy
instruments. Table 1 highlights the differences in the various instruments in use today to
evaluate privacy.

Table 1, Privacy Assessment Types

Assessment Name Authority Pre or Post Assessment


ISO/IEC 22307:2008 Standard Pre
DHS/DOJ PIA Best Practice Post
Shared Assessments Best Practice Post

As illustrated in Table 2, the instruments included in the study are: ISO/IEC


22307:2008 (ISO/IEC 22307:2008, 2008), DHS/DOJ PIA (Clarke, 2009), and Shared
Assessments Privacy Assessment (Shared Assessments, 2010). The need for categories along
a common set of dimensions is to insure there can be a common method for measuring their
effectiveness. ISO/IEC 22307:2008 is a standard ratified by a standards review process.
DHS/DOJ PIA and Shared Assessments Privacy Assessment are best practices recommended
by their respective organizations. Factoring the different instruments into a common
framework allows for statistical comparison by creating a consistent set of dimensions for
assessing and scoring privacy risks.

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Bornman and Labuschagne (2006) created a framework for comparing information security
risk management methods against technology governance. This study took the same approach
by creating a framework of dimension as shown in Table 2.

Table 2, Privacy Dimensions for Privacy Assessments

Privacy notices and protections are broken into dimensions to provide clarity and
specific protections within the guidelines such as the OECD guidelines on privacy protections
(OECD, 1980).

This study used the major dimensions that were applied by Smith, Milberg, and Burke
(1996) in their research, which were defined by the Fair Information Privacy Act (1974)
(FIPS) and then were reinforced by the Federal Trade Commission (2000) (FTC). The study
also used the extensions added by the Shared Assessments (Shared Assessments, 2010)
organization which were taken from ISO/IEC 27002:2005. The core FIPS dimensions
include: notice/awareness, choice/consent, access/participation, and integrity/security.
Integrity and security are security related dimensions and therefore are not included in the
privacy dimensions. Shared Assessments (2010) also included dimensions from ISO/IEC
27002:2005 that were needed to evaluate service provider organizations: permissions,
management and organizational, regulations and data flows. Due to the overlap in the
dimensions of permissions and choice, choice was consolidated in the permissions dimension
in this study.

This dissertation was US centric to manage scope of the study, therefore privacy
guidance is provided by the Federal Trade Commission (FTC, 2000) report on privacy.
Common among nation states are the dimensions, which drive privacy specification and

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control, including: notice, access, consent, permissions. This dissertation extended those
dimensions to include permissions, regulations and data flows, and management and
organization as they are additional dimension found in the Shared Assessments privacy
assessment and in the ISO/IEC 22307:2008 and provide finer grain assessment and validation
to the study.

This study is designed to evaluate privacy assessments as opposed to security


assessments based on security controls. Research by Bornman and Labuschagne (2006) and
Vorster and Labuschagne (2005) was designed to compare security assessments methods to
each other while this study was designed to see if the most common standards and best
practices based privacy assessments can adequately assess cloud environments.

The comparison framework is to evaluate each privacy assessment with common


criteria for scoring by each dimension (e.g. Notice). The dimensions defined provided a
method for comparing the common criteria in each of the assessments which were organized
into a comparative framework. The privacy assessment methods included in this study were:
ISO/IEC 22307:2008, DHS/DOJ PIA, and the Shared Assessments Privacy Assessment. The
assessment instruments were transformed into a set of survey instruments by putting them
into the tabular form (spreadsheet) shown in Table A1 in the Appendix so they could be used
efficiently to assess the cloud providers via the iterative process described above.

Smith, Milberg and Burke (1996) defined the primary privacy dimensions as
collection, errors and internal/external secondary use. An example of this type of
categorization was presented by Gupta, Banerjee, Agrawal, and Rao (2008) where they
created a classification rating system as an evaluation matrix to derive risk factors for security
assessment. Farahmand, Navathe, Sharp, and Enslow (2003) also created factoring scoring
matrices for evaluating the cost of loss due to both tangible and intangible losses.

The framework included a scoring system, also shown in Table A1 in the Appendix,
for comparing the scoring results from each assessment instrument applied to a cloud
infrastructure. The scores were applied to each of the five CTs of cloud computing against

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each of the questions that were asked within each dimension. For example in Table A1 the
first question under Notice asks the assessor if the notices on privacy are prominently
displayed. The assessor would score column five first (labeled as 'Answer') by posting an
answer was with a 'yes', 'no', 'unknown', or 'not applicable'. A 'yes' answer meant that the
service provider supported the privacy assessment requirement. The 'no' answer meant that
the provider did not support the requirements.

The answers of ‘yes’ and ‘no’ provides insight into whether the privacy assessment
instrument questions can be answered which in turn provide heuristic results regarding the
value of the instruments as they exist today in cloud environments. An 'unknown' response
meant that it could not be answered in any of the phases. An 'NA' response meant that the
question was not applicable for service providers. Columns 8-11 of Table A1 in the Appendix
were for scoring the five CTs. The purpose of the score is to provide a non-parametric
mechanism for showing what impact the cloud characteristic has on the assessment question.
The scores were then used to show which characteristic(s) had the largest scores, to compare
one assessment to another by evaluating the relative scores of one assessment to another,
correlating the data based on which cloud characteristics have an impact on the privacy
assessment question and are not answered by the provider.

The other component of the assessment evaluation included the qualitative data
collection that is the outcome of the process of running the assessments and having the
questions answered via the iterative method described previously. The qualitative data will be
able to capture specific assessment answers or that lack of answers through each iteration.
The completed assessment of the qualitative data was analyzed and evaluated in several steps.
One step included looking at what iteration has provided answers (data) by assessment, by
cloud provider. Another evaluation was to review what dimensions (e.g. notice) the questions
were not answered in across all three assessments per cloud provider and across all the cloud
providers.

The privacy assessments were transformed into a set of Microsoft Excel instruments
by putting them into the tabular form (spreadsheet) shown in Table A1 in the Appendix so
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they could be used to assess the cloud providers and log the answers and scores via the
iterative process described above. Each privacy instrument was broken down into separate
sections by instrument name and by dimensions and has a weighted scoring scheme designed
to provide comparison between instruments and providers using the dimensions
aforementioned.

The second part of Stage 1 was to define the Reference Application Architecture
(RAA) used as an exemplar of an application that an enterprise would migrate or build in the
cloud. The RAA was used as a test case for qualifying the service provider. If the service
provider could support the RAA on its systems or had an equivalent of the RAA offered as a
service then the service provider met the requirements for being included in the study. The
RAA included data that requires special privacy handling including healthcare, financial, and
personally identifiable information.

The RAA included the requirements which included application code/executable, a


web-server, and a database that stores employee personally identifiable information,
employee healthcare data, and corporate financial data. These RAA requirements force
regulatory and technical controls required by HIPAA, SOX, and PCI. The RAA requirements
would provide an example of a cross section of data that currently falls under regulatory
protection acts for the enterprise. These in turn would allow the privacy assessments to
evaluate the controls by the providers for these types of data. It would be a better
infrastructure requirement manageable enough to keep it within the scope of this research
project. Figure 2 depicts an abstract of a the architecture and configuration of multiple tenants
running within one cloud provider’s infrastructure services.

This type of architecture is representative of a large class of applications currently


seen in the cloud today.

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Figure 2, Proposed Reference Application Architecture

The final part of Stage 1 was to create a list of candidate cloud providers to be
investigated and enlisted for this study. This study required evaluating several cloud service
providers to attest the hypothesis that existing privacy assessment methods do not sufficiently
assess the privacy exposures in cloud computing environments. Cloud providers chosen had
to support the following NIST (2009) criteria: on-demand selfservice, broad network access,
resource pooling, rapid elasticity, and measured service. This list of potential candidate cloud
providers was developed by analyzing companies that currently advertise the necessary cloud
services and validating that they can support the requirements of the study’s RAA and they
had agree to participate in the study. The prospects that fit these characteristics include
Microsoft’s Azure cloud and Office365, Amazon Web Services, Terramark vCloud Express,

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Savvis Cloud Compute, Rackspace Cloud, Sungard Cloud Services, Hosting.com and IBM
Cloud Smart Business.

The final list of providers that agreed to the study was Amazon Web Services, Microsoft
Office365, and Hosting.com.

Stage 2 – Research Site Engagement and Data Collection

Stage 2 (S2) also had three parts. The first part was to acquire agreement by the cloud
providers to participate. The second part was to execute a self-service experiment using the
privacy instruments (DHS/DOJ PIA, ISO/IEC 22307:2005, and Shared Assessments Privacy
Assessment) against the cloud providers and register the scores on the scorecard. This was
executed in four iterations. The first iteration was as a noncustomer running the assessment
against what the provider releases to the public via their public website. The second iteration
was executed as a customer though still in selfservice mode where the investigation did not
include any interaction with the provider. The provider may share more information with a
paying customer than the public at large. The third iteration included sending unanswered
questions to the cloud provider’s customer service function. Any unanswered questions at
this point were directed to the privacy staff (e.g. business development, privacy office,
privacy officer, or security office) of the cloud providers when the self-service mode does not
answer a given question in the instruments. The addition of addressing the staff directly
added data by observing what additional privacy information could or could not be acquired.
Part two and three of S2 used the model shown in Figure 3.

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Privacy Assessment Cloud Experiment Model

Figure 3, Privacy Assessment Cloud Experiment Model

Stage 3 – Data Analysis and Report on Findings

Once the data collection in S2 was completed, the final phase, Stage 3 (S3), included
summarizing and analyzing the data and writing this final report. The data collected in the
score-card contains data that shows: weakness or strength of each assessment instrument
along the dimensions defined and overall patterns of commonality and variance amongst the
cloud providers. As represented earlier in the research questions section above this study
analyzed the data for patterns using frequency statistics aided by visual tools such as
frequency distributions and general demographics. The independent variable in this study is a
manipulated or experimental variable (Sekaran, 2003) which are the cloud characteristics (on-
demand/self-service, broad network access, measured services, shared resources, and
elasticity) which will be evaluated to see if each these variables have an impact on the
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privacy assessment questions. The variables were evaluated as an aggregated score using
frequency analysis shown in the results section. Standard descriptive statistical analysis was
not applicable except for the use of some general frequency analysis and ratios.

Instead inferential statistics were employed to compare frequency distributions against the
answerability rate with respect to the PA instruments and the CSPs. This included the Chi-
Square (X2) goodness of fit test (Corder and Foreman, 2009) and the Kruskal-Wallis X2
(2009) statistic to determine the median. Finally, Spearman's (2009) non-parametric
correlation coefficient (rS) was used to determine if there was a rank correlation between the
three CSPs with respect to their answerability rate to each of the five cloud tenets as defined
by NIST (2009). This allowed the study to include the additional null and alternative
hypothesis:

HA2: The frequency distributions of answerability rate with regard to cloud tenets and
privacy dimensions across the three PA instruments (DHS/DOJ, ISO/EC and
SharedAssessments) will not be substantially similar within each CSP.

H02: The frequency distributions of answerability rate with regard to cloud tenets and
privacy dimensions across the three PA instruments (DHS/DOJ, ISO/EC and
SharedAssessments) will be substantially similar within each CSP.

HA3: The frequency distribution of answerability rates for the different tenet / privacy
dimension combinations is significantly impacted by the choice of CSP.

H03: The frequency distribution of answerability rates for the different tenet / privacy
dimension combinations is not significantly impacted by the choice of CSP.

HA4: The answerability rate relevant to a given cloud tenet is significantly impacted
by the choice of the CSP.

H04: The answerability rate relevant to a given cloud tenet is not significantly
impacted by the choice of the CSP.

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The decision rule was to reject the null hypothesis and accept the alternative hypothesis if the
probability (p) associated with the test statistic was < .05. If p < .05 then it was inferred that
the probability was less than 5% that the results were due to random chance. If p ≤ .05 for the
X2 tatistic, then the alternative hypothesis was not accepted because the probability was 5%
or more that the results were only caused by chance.

Resources Required

Resources needed for this study included the privacy assessments listed in Table 2, the cloud
provider’s infrastructures (Microsoft Office365, Amazon Web Services, and Hosting.com)
and an Internet network connectable laptop with current word processing, spreadsheet, and
statistical analysis software.

Selection of the Population

As noted above, the sample population selection was based on information gathered from the
industry sources. Then an analysis of potential cloud providers was completed which looked
for common traits that match with the NIST cloud definition (2009). NIST defined both
delivery {Software as a Service, Platform as a Service, and Infrastructure as a Service} and
deployment model {private cloud, community cloud, public cloud, and hybrid cloud}. For
this study we used an RAA so the cloud provider had to provide Cloud Services and must be
able to support the requirements as specified in the RAA.

Instrumentation Used

The instruments used include each privacy assessment instrument listed in Table 1. This
study also had the added dimensions listed in Table 2 so that the testing generated a risk score
for the privacy dimensions outlined in the Stage 1 section of this document as tested against
the cloud providers.

Summary

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This study was descriptive and exploratory. The methodology included creating seven
dimensions for categorizing the privacy assessment questions and applying a scoring system
to the questions based on the cloud tenets so that the results could provide insight in terms of
patterns via non-parametric correlated statistical analysis. Three manual privacy assessment
instruments were used in the study and each was executed against three cloud service
providers. Though the sample size was small the number of questions total was over 200 and
they were run against each CSP providing more than 600 data points. Also, each instrument
was executed in four phases providing insight into the difficulty in gathering the data
manually when one of the cloud tenets is self-service.

Pre-analysis of data screening was done to eliminate bad data. Data analysis included
demographics in terms of frequency analysis. Four null hypotheses were tested using Chi-
square test

2), Kruskal-Wallis test to determine median answerability rate, and non-parametric


correlation analysis using Spearman's correlation coefficient (rS) to determine if there was a
rank correlation between the CSPs’ compliance with the five cloud tenets.

A personal computer with Microsoft Word was used to write the report. Microsoft

Excel was used to convert the Adobe PDF survey instruments into data collection tools.

Microsoft Excel, IBM SPSS, and Tableau Software were used for data preparation, data
analysis, and data validation.

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CHAPTER 4
RESULT
Overview

The study was comprised of three privacy risk assessment instruments empirically executed
against three cloud service providers. Each Privacy Assessment (PA) instrument was broken
into the seven dimensions outlined in the methodology section.

The study was run in three stages with the following tasks:

Stage 1:

Task 1:

Rationalizing three privacy assessments {DHS/DOJ PIA, ISO/IEC 22307:2008,


and Shared Assessments Privacy Assessment) across seven dimensions. The dimensions were
selected using dimensions included in the assessments themselves and using the OECD
(1980) and FIPS (1974) standards. The PA questions were put into specific dimensions based
on the intent of the question or the dimension that the assessment was provided in the
assessment. Tables 3-5 show the results of matching the questions for each PA to the
dimensions.

Table 3 shows the seven privacy dimensions {Access, Consent, Management &
Organization Notice, Permissions, Regulations and Data Flows, Retention} in a matrix that
has each CSP tested against in columns grouped under each Privacy Assessment.

Table 3, Total Number of Questions for Each Dimension by Privacy Assessment.

Assessment Name

Dimension DHS/DOJ Privacy ISO/IEC 22307:2008 SharedAssessments


Impact Assessment Privacy Assessment Privacy Assessment
Access 18 0 6
Consent 0 31 5

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Management and 3 12 43
Organization
Notice 4 43 26
Permissions 4 16 13
Regulations and Data 7 0 34
Flows
Retention 4 0 0
Grand Total 40 102 127

Each PA had a different number of questions in total, and different subtotals by


dimension. The DHS/DOJ PA did not include any consent-related questions and had a
combined total of 40 questions. The ISO/IEC 22307:2008 PA did not include questions in
three of the dimensions which were access, regulation and data flows, and retention with a
total of 102 questions. The SharedAssessments PA did not have any questions in the retention
dimension with a total of 127 questions. All three assessments had just three dimensions in
common: (Management and Organization, Notice, and Permissions).

Task 2:

Creating one survey instrument required putting all three assessments into one
large Microsoft Excel spreadsheet to improve the efficiency of data collection.

Task3:

Since the data was collected using the single survey instrument with all three
assessment methods and against all three CSPs the data was already consolidated and
prepared for analysis.

Stage 2:

Task 1:

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The first task was to acquire agreements from at least three service providers
that met the requirements for the study. Email messages were sent to personal contacts or via
contact pages (forms) found on the CSPs’ websites. For example this one at Amazon Web
Services {http://aws.amazon.com/contact-us/aws-sales/} was used to contact Amazon Web
Services. Five service providers were contacted with only three providers Amazon Web
Services, Microsoft Office365, and Hosting.com agreeing to allow use of their services for
research purposes. Due to the need for direct interaction with the Hosting.com staff an IRB
release form was required which is included in Appendix B. Interactions with Amazon Web
Services and MSOffice365 were anonymous and did not require an IRB release. Once
agreements were in place the data collection process was executed in four distinct phases.

1. As a non-customer running the PAs against the provider’s public website.

2. Next the PAs were executed as a customer through self-service activities by


investigating what was published in their online dashboards and websites and did not
include any direct interaction with the provider.

3.The third phase included sending PA questions that weren’t answered without
assistance to the cloud provider’s customer service function.

4. The final phase was to escalate all unanswered PA questions to the privacy staff
(e.g. business development, privacy office, privacy officer, or security office).

Table 4 displays the answer score (count) by PA by CSP with answerability rate (yes and no
answers) and summed by all CSPs and by all PAs.

Table 4, Answerability Score by Privacy Assessment Type.

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A "yes" answer meant that the CSP supported the privacy requirement of the PA, a "no"
answer meant the CSP did not support the privacy requirement. For this research “yes” and
“no” answers both constituted the question being counted as a question that could be
answered. The answer of not applicable was applied based on questions not fitting the
provider’s service offering. The answer of unknown meant the question was a valid question
however the answer could not be ascertained by querying the CSP.

Tables A9 and A11 in the Appendix contain all the raw data collected for the DHS/DOJ and
Shared Assessments PAs. Table A10 in the Appendix was redacted due to licensing
restrictions from the ISO/IEC.

The PAs data gathering process were executed in the four phases which were outlined in the
methodology section and included {Phase 1: Non-customer, Self-service, Phase 2: Customer,
Self-service, Phase 3: Customer, Customer Service Inquiry, Phase 4: Customer, Escalated
Inquiry}.

Table 5 shows what the answer count was per answer type per phase by PA and by CSP. As
shown in Table 5 CSP1 and CSP2 had to have questions answered by querying their
customer service departments in a third phase for the DHS/DOJ PIA. Also shown is that
CSP2 and CSP3 had to have their customer service departments queried in a third phase for
the SharedAssessments PA.

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Table 5, Answer Frequency by Phase and Privacy Assessment Type.

A customer service inquiry meant that the customer (in this case the researcher) had to send
an email to customer service for support. An escalation meant that customer service could not
answer the question and requiring further escalation to business development or the other
product ownership members within the CSP.

Visually inspecting Table 5 for frequency data indicates several trends. The ISO/IEC PA had
more questions that were not applicable; 33 out of 102 representing 32% of the questions.
Also by comparing the phase of responses, CSP2 required interaction beyond the self-service
phases for the SharedAssessments PA.

Another important part of the research process of data collection was also to collect data by
marking the five Cloud Tenets with a "yes" or "no" based on the question from the PA. Each
CSP selected for this study had to support five cloud tenets. The objective of this portion of
the data collection was to evaluate the questions within each PA against the tenets. Each
question was evaluated to determine if the question would be impacted by the tenet and this
was called the relevance score. The relevance score provided a subset of total question count.
Next the answers were filtered by the relevance score providing an answerability score. The
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answerability rate was then able to be determined by dividing the answerability score by the
relevance score or AR = AS/RS.

The results are shown in Table 9 and in Table A5-7 in the appendix.

The questions from each PA were evaluated based on whether the question would be
impacted by each tenet. For example question 17 from the DHS/DOJ PA in Table A2 asks
“How is information transmitted or disclosed?” For the broad network access tenet this
question would be impacted by this tenet as it refers to data transmission. Using this same
question as an example for resource pooling the question would be potentially have to be
modified by the tenet as resource pooling creates new factors impacting the risks due to
resource pooling creating new disclosure considerations.

• On-demand / self-service – The data collected for this tenet was computed twice. The
first time the data was collected by using the phased approach outlined in the
methodology section in chapter 3.If the privacy question response was yes or no and
answered in phase 1 or 2 than the outcome for self-service was a yes answer. If the
privacy question response was unknown or NA then the answer was no.
• On-demand / self-service – The second treatment for this tenet was to apply a
relevance methodology to the question and score the question with a yes if the
question would be impacted by the tenet creating data that was used to measure
relevance rate.
• Broad Network Access – For this tenet each question was evaluated based on two
criteria. First whether or not the CSP provided broad network access services. If they
supported broad network access then whether the questions result was impacted by
the cloud tenet broad network access creating data that was used to measure relevance
rate.
• Resource Pooling - Each question was evaluated based on two criteria. First whether
or not the CSP provided resource pooling services and then whether the questions
result was impacted by resource pooling creating data that was used to measure
relevance rate.
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• Rapid Elasticity - Each question was evaluated based on two criteria, first whether or
not the CSP provided rapid elasticity services and then whether the questions result
was impacted by rapid elasticity creating data that was used to measure relevance rate.
• Measured Service - Each question was evaluated based on two criteria. First whether
or not the CSP provided measured services and then whether the questions result was
impacted by measured services creating data that was used to measure relevance rate.
Table 6 shows the respective scores for yes and no answers broken down by tenet,
CSP, and PA.

Table 6, Tenet Relevance Scores by Cloud Tenet, CSP, and PA .

Answer On-Demend Broad Resourc Rapid Measur Tenet 'Yes' Tenet 'No'
DHS/DOJ Privacy Impact Assessment
CSP1 34 38 32 40 40 40 190 10
CSP2 33 38 32 40 40 40 190 10
CSP3 31 38 32 40 40 40 190 10
Mean 32.67 38 32 40 40 40 190 10
Mediun 33 38 32 40 40 40 190 10
Std. Dev. 1.53 0 0 0 0 0 0 0
ISO/IEC 22307 : 2008 Privecy Assessment
CSP1 69 95 87 93 94 94 463 47
CSP2 69 95 87 94 94 94 464 46
CSP3 68 95 87 94 94 94 464 46
Mean 68.67 95 87 93.67 94 94 463.67 46.33
Mediun 69 95 87 94 94 94 464 46
Std. Dev. 0.58 0 0 0.58 0 0 0.58 0.58
Shared Assessment Privecy Assessment
CSP1 103 127 116 126 126 126 621 14
CSP2 118 127 116 126 126 126 621 14
CSP3 118 127 116 126 126 126 621 14
Mean 113 127 116 126 126 126 621 14
Mediun 118 127 116 126 126 126 621 14
Std. Dev. 8.66 0 0 0 0 0 0 0

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Stage 3: Descriptive Statistics Results

A limitation of the categorical (i.e., "Yes" or "No") responses collected using


the PA instruments was that parametric statistics can only be used for normally distributed
continuous quantitative measurements or counts with bell-shaped frequency distributions,
Since this was not the case with the data from this study the use of parametric statistics were
not justified. Only non-parametric statistics are appropriate to analyze non-normally
distributed categorical variables (based on frequencies, proportions, and medians) could be
applied. The following Tables 7-9 provide some additional insights regarding the various
frequencies of responses. Table 7 shows the total number of valid responses to the
questionnaires by CSP and by Assessment type validating that all the questions had a
response and no questions were missed.

Inferential Statistics Results

All CSPs

The answerability rate was greater than or equal to 95% for none of the three Pas as shown in
Table 4, which also includes the PAs with the greatest to lowest answerability rate on average
89.7% for SharedAssessments, 81.7% for DHS/DOJ, and the ISO/IEC at 67.3% respectively.

The answerability rates by cloud tenet in the PA dimensions for all three privacy assessments
individually and aggregated are presented in Table 9. The raw data that was used to
determine the answerability rate for each PA broken down by each CSP is included in the
appendix in Table A5. The answerability rate was greater than or equal to 95% in 7 of 30
(23%) of the applicable cloud tenet / privacy dimension measurements using the DHS/DOJ
privacy assessment, greater than or equal to 95% in only 2 out of 20 (7%) of the
measurements using the ISO/IEC privacy assessment, and greater than or equal to 95% in 15
out of 30 (50%) of the measurements using the SharedAssessments privacy assessment. To
begin the answerability rate analysis a Chi-Square goodness of fit test was run to see if the
observed values met or exceeded the 95% test. The expected values for DHS/DOJ PIA,
ISO/IEC 22307:2008, and SharedAssessments PA were 38 of 40, 97 of 102, and 121 of 127
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respectively. The null hypothesis was rejected as indicated by the result of the Chi-Square
goodness of fit test show in Table 10. The critical X2 value was 5.99 and the actual value was
10.059 with an expected p <.05 (95%) for the X2 statistic .

CSP1

The distributions of Answerability Rate to the cloud tenets in the PA


Dimensions for CSP1 are presented in Table A5-A7 in the Appendix. Answerability Rate was
calculated for each cell in the matrix of the dimensions and the five tenets generating 30 data
points for the DHS/DOJ PA, 20 data points for the ISO/IEC PA and 30 for the
SharedAssessments PA. A general rule was applied to filtering the data that the
Answerability Rate had to be > 95% to be included in the calculation. The results were ≥ 95%
in 7 out of 30 (23.0%) of the data points using DHS/DOJ, greater than 95% in 0 out of 20
(0.0%) of the cloud tenets using ISO/IEC, and greater than 95% in 15 out of 30 (50.0%) of
the cloud tenets using SharedAssessments. The null hypothesis was rejected as indicated in
Table 10 for the Chi-Square goodness of fit test, indicated by p < .001 for theX2 statistic. The
frequencies of answerability rate above and below the 95% threshold were not equal with one
another. The null hypothesis of the Kruskal-Wallis test shown in Table 11 was also rejected,
indicated by p < .05 for the X2 statistic. The median Answerability Rate was not equal with
respect to the three PA instruments.

The results are consistent with HA1. Less than 95% of the responses to the questions
complied with the privacy specifications in the PA instruments. The findings are also
consistent with HA2 . The frequency distributions of Answerability Rate were not equal
across the DHS/DOJ, ISO/EC and SharedAssessments.

CSP2

The distributions of Answerability Rate are presented in Table A5-A7 in the


Appendix. Answerability Rate was greater than 95% in 7 out of 30 (22.5%) of the cloud
tenets using the DHS/DOJ, greater than 95% in 0 out of 20 (0.0%) of the cloud tenets using
ISO/EC and greater than 95% in 2 out of 30 (66.6%) of the cloud tenets using
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SharedAssessments instrument. The null hypothesis of the Chi-Square goodness of fit test
shown in Table 10 was rejected, indicated by p < .05 for the X2 statistic. The frequencies of
answerability rate above and below the 95% threshold were not equal. The null hypothesis of
the Kruskal-Wallis test shown in Table 11 was also rejected, indicated by p < .05 for the X2
statistic. The median Answerability Rate was not equal with respect to the three PA
instruments.

The results are consistent with HA1 (i.e., less than 95% of the responses to the questions
complied with the privacy specifications in the PA instruments) and with H A2 (i.e., the
frequency distributions of Answerability Rate were not equal across the DHS/DOJ, ISO/EC
and SharedAssessments).

CSP3

The distributions of Answerability Rate at CSP3 are presented in Tables A5-A7 in the
Appendix. Answerability Rate was greater than 95% in 7 out of 30 (23.3%) of the cloud
tenets using DHS/DOJ, greater than 95% in 0 of 20 (25.0%) of the cloud tenets using
ISO/IEC and greater than 95% in 20 out of 30 (66.6%) of the cloud tenets using
SharedAssessments. The null hypothesis of the Chi-Square goodness of fit test shown in
Table 10 was rejected, indicated by p < .001 for the X2 statistic. The frequencies of
Answerability Rate above and below the 95% threshold were not equal. The null hypothesis
of the Kruskal-Wallis test was also rejected, indicated by p < .05 for the X2 statistic shown in
Table 11. The median Answerability Rate was not equal with respect to the three PA
instruments.

The results are consistent with HA1 (i.e., less than 95% of the responses to the questions
complied with the privacy specifications in the PA instruments) and with H A2 (i.e., the
frequency distributions of Answerability Rate were not equal across the DHS/DOJ, ISO/EC
and SharedAssessments).

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CHAPTER 5
CONCLUSION

This study focused on topics relevant to assessing privacy risks in cloud computing
environments. The following questions were addressed in this study:

Q1. Do existing privacy assessment methods adequately assess privacy risk exposures of
cloud computing for the enterprise as measured by the privacy assessment comparison
methodology described in the Methodology section?

Q2.By using the scoring system outlined in the methodology section are the new
characteristics in cloud computing such as on-demand/self-service, broad network access,
measured services, shared resources, and elasticity adequately evaluated or accommodated in
existing privacy assessment methods?

These two questions resulted in the formation of the following hypothesis and null
hypothesis:

H01: The average answerability rate for each privacy assessment (DHS/DOJ Privacy Impact
Assessment, ISO/IEC 22307:2008 Privacy Assessment, and Shared Assessments Privacy
Assessment) at each CSP (CSP1, CSP2, and CSP3) is 95%.

HA1: The average answerability rate for each privacy assessment (DHS/DOJ Privacy Impact
Assessment, ISO/IEC 22307:2008 Privacy Assessment, and Shared Assessments Privacy
Assessment) at each CSP (CSP1, CSP2, and CSP3) is > 95%.

H02: The frequency distributions of answerability rate across the three PA instruments
(DHS/DOJ, ISO/EC and SharedAssessments) will be the same within each CSP.

HA2: The frequency distributions of answerability rate across the three PA instruments
(DHS/DOJ, ISO/EC and SharedAssessments) will not be the same within each CSP.

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H03: The frequency distributions of answerability rate will be the same across the three CSPs
(CSP1, CSP2, and CSP3)

HA3: The frequency of answerability rate will not be the same across the three CSPs (CSP1,
CSP2, and CSP3)

H04: The answerability rate for each of the cloud tenets (On-demand self-service.

Broad network access, Resource pooling, Rapid elasticity, and Measured service) at CSP1,
CSP2, and CSP3 will not be correlated with each other.

HA4: The answerability rate for each of the cloud tenets (On-demand self-service.

Broad network access, Resource pooling, Rapid elasticity, and Measured service) at CSP1,
CSP2, and CSP3 will be correlated with each other.

The hypothesis was empirically tested using data collected via the PAs tested against the
three cloud service providers in the United States (Amazon Web Services,
MicrosoftOffice365, and Hosting.com). In total, 807 usable responses were collected over a
five month time period.

HA1 Conclusion

HA1 could not be rejected because the results showed that less than 95% of the responses
generally complied with the items within privacy dimensions in the three privacy
assessments.

HA2 Conclusion

HA2 could not be rejected because the Answerability Rate across the three privacy
assessments were not equal based on the frequency distribution analysis. This verifies that
there are significant inconsistencies in the approaches used by privacy assessments and the
dimensions they evaluate. As examples the DHS/DOJ Privacy Impact Assessment did not
have questions regarding Consent, the ISO/IEC 22307:2008 assessment was missing

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questions for Access, Regulation & Data Flows, and Retention, and the ShareAssessments
Privacy Assessment did not have questions regarding retention.

HA3 Conclusion

HA3 was rejected as the Answerability Rate was met for all of the cloud tenets (On-demand
Self-service, Broad Network Access, Resource Pooling, Rapid Elasticity, and Measured
Service) for all three of the CSPs. This outcome supports the consistency of the methodology
outcomes against the population. A larger population would allow this hypothesis to be tested
to provide greater accuracy in the results.

HA4 Conclusion

HA4 was rejected as the Answerability Rate was met for all of the cloud tenets (On-demand
Self-service, Broad Network Access, Resource Pooling, Rapid Elasticity, and Measured
Service) for all three of the CSPs were correlated across the CSPs. This outcome also
supports the consistency of the methodology outcomes against the population. A larger
population would allow this hypothesis to be tested to provide greater accuracy.

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CHAPTER 6
FUTURE ENHANCEMENT
Future Enhancement

1. The current study was limited to low rise structures up to G+7 storey only. The same work
can be extended to cover space frames up to 12 stories.

2. The irregularity of the structural frame work can be taken up to study the effect of seismic
forces on the same.

3. The other column shapes like plus shape and rectangular columns oriented in random
directions can be considered to carry out the analysis under lateral loads and to compare their
seismic performance.

4. The effect of shear walls in the frames can be considered for analysis as structures beyond
four storey are bound to have a RCC lift shaft.

5. Seismic analysis can be carried out by considering a high performing material like ECC in
the beam column joint of the frames.

6. RC frames having soft storey can be studied under push over analysis and a general
solution for improving their seismic performance can be worked out based on the findings.

7. A large number of RC framed structures are existing in our countries which are designed
for gravity loads only. Thus, a study can be taken up which designs a typical RC framed
structure for gravity loads only and then subject it to push over analysis. A parameter may be
identified which is causing the highest damage under seismic forces. Some general solution
can be worked out as a retrofitting measure to enhance the seismic performance of such
deficient frames.

8. Seismic performance may be compared for RC frames with various cross sectional shapes
like T, L, +, etc. apart from the rectangular and square shapes for low rise RC frames. The
best shape may be selected for better seismic performance using the well known optimization
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technique such as Genetic Algorithm. However, it may require proper fusion of hard and soft
computing tools and a tremendous of computational effort.

9. Economics is one of the major driving force in deciding the method and material of
construction, especially in case of low rise apartment type housing units. Working out of the
cost difference in designing a 'building to a desired performance level of life safety and
immediate occupancy using push over analysis will be certainly an beneficial extension of the
present study.

10. Investigations can be carried out for RC frames having walls with light weight concrete
blocks (Autoclaved Airated Concrete) instead of the conventional bricks. Study of seismic
performance from the point of view of reduction in seismic weight and increase in the
strength of equivalent strut used for infill may prove fruitful.

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REFRENCES

[1]. Applied Technology Council, "Seismic Evaluation and Retrofit of Concrete Buildings",
ATC-40, Volume 1 and 2, Report No. SSC 96- 01, Seismic Safety Commission, Redwood
City, CA, 1996.

[2]. FEMA-273/274, Federal Emergency Management Agency, NEHRP Guidelines and


Commentary on the Guidelines for the Seismic Rehabilitation of Buildings, Washington D C,
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[3]. Moghadam A. S. and Tso W. K., "Damage Assessment of Eccentric Multistory Building
using 3-D Pushover Analysis", Proceedings of the 11th World Conference on Earthquake
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[4]. Kiiar V. and Fajfar P., "Simplified Pushover Analysis of Building Structures",
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[5]. Faella G. and Kiiar V., "Asymmetric Multistory R/C Frame Structures: Pushover versus
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[6]. Habibullah A., and Pyle S., "Practical Three Dimensional Nonlinear Static Pushover
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[7]. De-La-Colina J., "Effects on Torsion Factors on Simple Non Linear Systems using Fully-
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[8]. Chopra A. K. and Goel R. K., "Capacity-Demand Diagram Methods for Estimating
Seismic Deformation of Inelastic Structures: SDF Systems", Pacific Earthquake Research
Center, PEER Report" - 1999/02, 1999.

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[9]. Moghadam A. S. and Tso W. K., "Pushover Analysis for Asymmetric and Set-back
Multistory Buildings", Proceedings of 12th World 380

[10]. Peckley D. C., Tanzo W. T. and Pacheco B. M., "Pushover Analysis of a Thirty Five
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[11]. Fajfar P. and Dolsek M., "The N2 Method for Seismic Performance Assessment - Basic
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[12]. Basu D. and Jain S. K., "Seismic Analysis of Asymmetric Buildings with Flexible Floor
Diaphragms", Journal of Structural Engineering, ASCE, Aug. 2004.

[13]. Das D. and Murty C. V. R., "Brick Masonary Infills in Seismic Design of RC Frame
Buildings: Part 1 - Cost Implications", The Indian Concrete Journal, Vol. 78, pp. 39-44, 2004.

[14]. Das D. and Murty C. V. R., "Brick Masonary Infills in Seismic Design of RC Frame
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[15]. IS:1893 (Part 1) : 2002, Indian Standard Criteria for Earthquake Resistant Design of
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[16]. Eurocode 8, Part 1-3, Design Provisions for Earthquake Resistance of Structures,
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[17]. NBC201:1994, Nepal National Building Code Mandatory Rules of Thumb - Reinforced
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[18]. IS 13920:1993, Indian Standard Code of Practice for Ductile Detailing of Reinforced
Structures subjected to Seismic Forces, Bureau of Indian Standards, New Delhi, 1993. 382
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ANALYSIS OF DATA SECURITY & MANAGEMENT IN HYBRID CLOUD COMPUTING ENVIRONMENT

[19]. IS 456:2000, Indian Standard Code of Practice for Plain and Reinforced Concrete,
Bureau of Indian Standards, New Delhi, 2000. 29. Kaushik H. B., Rai D. C. and Jain S. K. ,
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[20]. Zaregarizi S., "Comparative Investigation on using Shear Wall and Infill to Improve
Seismic Performance of Existing Buildings", Proceedings of 14th World Conference on
Earthquake Engineering, Paper 05-01-0318, Beijing, China, Oct. 2008.

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APPENDIX – B

LIST OF PUBLICATION

[1] “A Study of Siesmic Stengthening of Multi Storey Building”, International


Research Journal of Engineering & Technology, Volume: 6, Issue 2, pp 55-57, June 2016.

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