What is The Shared Responsibility Model?
Most major public cloud providers including, Amazon Web Services (AWS), Google Cloud Platform (GCP) and Microsoft Azure follow a “Shared Responsibility Model” for security and compliance. This means that security and compliance are a shared responsibility between the cloud platform and the cloud customer. This applies not only for regulatory compliance such as HIPAA, PCI DSS, and FedRAMP, but also for cybersecurity frameworks such as SOC 2, NIST 800-53 and ISO 27001. Cloud providers implement a certain set of security protections and safeguards, but customers are responsible for building secure solutions with these cloud services.
The AWS Shared Responsibility Model
The AWS Shared Responsibility Model defines security responsibilities for the cloud provider and AWS customers. This model applies to a majority of AWS security and compliance programs including HIPAA, and is defined and included inside AWS Business Associates Agreement (BAA).
The AWS shared responsibility model looks as follows:
Under the Shared Responsibility Model, AWS is responsible for “Security OF the Cloud”. AWS will fulfill a number of HIPAA physical safeguards as well administrative reporting related to cloud services. Physical safeguards managed by AWS include:
- Signing a business associates agreement (BAA)
- Breach notification
- Physical server security
- Facility locks and access
- Employee access to systems
- Availability of encryption standards
AWS cloud services have built with many security features built-in. Many AWS services can be setup and configured with backup, encryption, and access control settings. These protections are provided by AWS, but ultimately become the responsibility of the cloud customer.
Cloud Customer Responsibilities
AWS cloud customers are responsible for the “Security IN the Cloud”. This means that cloud service settings, operating systems, and applications fall under the responsibility of the cloud customer. AWS customers must implement administrative safeguards and technical safeguards in order to maintain HIPAA compliance under the AWS Shared Responsibility Model. Policies should be customized to fit your organization’s technologies, and staff structure.
HIPAA Administrative Policies must include:
- A Policy for defining a Security and Privacy Officer
- Procedures for system access
- A set process for backup and disaster recovery
- Processes for incident investigation and response
- Processes for intrusion detection
- Processes for audit logging
HIPAA Technical Safeguards must include:
- Audit logging
- Anti-virus and anti-malware
- Backup and disaster recovery (DR)
- Firewall and network access
- Intrusion detection systems (IDS)
- Vulnerability scanning
Technical safeguards can be implemented using AWS services and configuration or other 3rd party tools and configuration. It is possible to use many AWS services to address these technical safeguards, but it is important to note that organizations must handle all configuration and management of these AWS services and controls.
Executing on the Shared Responsibility Model
For HIPAA Compliance, organizations should take the following steps for fulfilling their role in the Shared Responsibility Model:
- Sign the Amazon Web Services BAA
- Create Administrative Policies and Procedures
- Build on AWS HIPAA Eligible Services
- Implement Technical Controls
- Monitor, Access, and Improve Organization’s Security Plan