Azure UK Governments - 14 Compliance Controls
Azure UK Governments - 14 Compliance Controls
Azure UK Governments - 14 Compliance Controls
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2016 Microsoft. All rights reserved.
Acknowledgements
Authors
Stuart Aston
Frank Simorjay
Introduction ................................................................................................................................. 4
Conclusion ................................................................................................................................. 24
Introduction
Microsoft Azure provides services that can help address the security and compliance needs of
Microsoft customers. In addition, Microsoft works with customers to understand their assurance
concerns, and to help define their responsibilities as well as its own with regard to protecting
customer data and environmental infrastructure after services are provisioned. Such infrastructure
includes applications, data content, virtual machines, access credentials, and compliance
requirements.
In addition, in the wake of the recent landmark vote in the UK calling for the invocation of Article 50
of the Lisbon Treaty, customers should consider their implementation strategies for both on-premises
and cloud-based services to ensure they meet their compliance obligations.
This paper provides insight into how Azure services align with the fourteen cloud security principles
set forth in the CESG/NCSC 1publication Implementing the Cloud Security Principles, thereby
enabling organisations to fast-track their ability to meet their compliance obligations using cloud-
based services globally and in the UK.
Microsoft Azure is a growing collection of integrated cloud servicesanalytics, computing, database,
mobile, networking, storage, and webthat allow customers to move faster, achieve more, and save
money. Azure serves as a development, service hosting, and service management environment,
providing customers with on-demand compute, storage, networking, and content delivery capabilities
to host, scale, and manage applications on the Internet.
To get the most out of the Microsoft cloud platform, readers should be familiar with basic Azure and
cloud computing concepts, as well as security and compliance fundamentalsthey will not be
discussed here. Links to additional materials can be found on the Get started with Azure webpage as
well as through the Azure Trust Center and the Azure Security Information portal.
1
In October 2016 the CESG has announced its merge with the National Cyber Security Center (NCSC), which will
include the Information Security arm of GCHQ the Centre for the Protection of National Infrastructure, CERT-
UK and the Centre for Cyber Assessment.
Microsoft cloud principles of trust
Protecting the security, privacy, and integrity of sensitive customer data is one of Microsofts highest
priorities.
The Microsoft Trust Center (www.microsoft.com/TrustCenter) lists a number of underlying principles
that guide the way Microsoft cloud services are built and operated, including:
Security. Customers must be able to count on the security of their data. Security is built into Microsoft
cloud services from the ground up, starting with the Security Development Lifecycle, a mandatory
development process that embeds security requirements into every phase of the development process.
Microsoft engineers help ensure that Microsoft cloud services are protected at the physical, network, host,
application, and data layers so that all services are resilient to attack. Continuous proactive monitoring,
penetration testing, and the application of rigorous security guidelines and operational processes further
increase the level of detection and protection throughout Microsoft cloud services.
Privacy. Customers must be able to trust that the privacy of their data will be protected and that it
will be used only in ways that are consistent with their expectations. The Microsoft Online Services
Privacy Statement describes the specific privacy policy and practices that pertain to customer data
in Microsoft enterprise cloud services. Microsoft was also the first major cloud provider to adopt
the first international code of practice for cloud privacy, ISO/IEC 27018.
Transparency. Customers should know as much as possible about how their data is handled and
to whom it is disclosed. Microsoft provides a wide range of evidence, including third-party audit
reports and certifications for their respective services listed in the FAQ located on the Microsoft
trust center. To verify that Microsoft meets the standards it sets for itself. The Microsoft
Transparency Hub provides extensive information and statistics about how Microsoft has
responded to law enforcement requests, US national security orders, and content removal
requests.
Compliance. Microsoft is committed to respecting and accommodating regional regulatory
standards. To help organisations comply with national, regional, and industry-specific
requirements that govern the collection and use of individuals data, Microsoft offers the most
comprehensive set of certifications and attestations of any cloud service provider.
Shared responsibilities
In Figure 1, the left-most column shows seven responsibilities (defined in the sections that follow) that
organisations should consider, all of which contribute to the security and privacy of a computing
environment.
Figure 1. Shared responsibilities for security and privacy
After an information security management system (ISMS) foundation is set and best practices are
adopted, there are additional areas to evaluate and understand to determine an organisations risk
posture and keys for mitigating its risks. To do this, organisations need to understand which areas are
the cloud providers responsibility and which are the organisations responsibility. Figure 1 makes it
clear that responsibilities are driven by the cloud service model (on-premises, IaaS, PaaS, SaaS).
With the exception of Data classification & accountability, customers and cloud service providers
(CSPs) share responsibilities. Some responsibilities require CSPs and customers to manage and
administer the responsibility together, including auditing of their domains. For example, consider
Identity & access management when using Azure Active Directory Services. The configuration of
services such as multi-factor authentication is up to the customer, but ensuring effective functionality
is the responsibility of Microsoft Azure.
Government Cloud (G-Cloud) is a UK government initiative to ease procurement of cloud services by
government departments and promote government-wide adoption of cloud computing. G-Cloud
comprises a series of framework agreements with cloud services providers, such as Microsoft, and a
listing of their services in an online storethe Digital Marketplace. This initiative enables public-sector
organisations to compare and procure those services without having to carry out their own full review
process. Inclusion in the Digital Marketplace requires a self-attestation of compliance, followed by a
verification performed by the Government Digital Service (GDS) branch.
Instead of the central assessment of cloud services previously provided, the new process requires
cloud service providers to self-certify and supply evidence in support of the 14 Cloud Security
Principles of G-Cloud (currently at version 6). This process has not changed either the evidence
Microsoft produces or the standards that the company adheres to.
The Crown Commercial Service (an agency that works to improve commercial and procurement
activity by the government) renewed the classification of Microsoft in-scope enterprise cloud services
at G-Cloud v6, covering all of its offerings at the OFFICIAL level:
Software as a service (SaaS). Using the cloud to deliver applications.
Platform as a service (PaaS). Using the cloud to host, develop, and test applications.
Infrastructure as a service (IaaS). Using the cloud in place of servers and other hardware.
Cloud consulting services. Helping customers get the most from the cloud.
The inclusion of Microsoft services in the Digital Marketplace means that UK government agencies
and partners can use in-scope services to store and process UK OFFICIAL government data, the
majority of government data. In addition, there are now more than 450 Microsoft partners included in
G-Cloud who are resellers of Microsoft cloud services. They can directly assert the compliance of in-
scope services with the 14 cloud security principles in their own applications. Customers and partners,
however, will need to achieve their own compliance for any components that are not included in the
attestation and determination of compliance for Microsoft cloud services.
Addressing cloud security principles with Azure
In its publication Cloud Security Guidance: Summary of Cloud Security Principles, CESG/NCSC , the
information security arm of the Government Communications Headquarters (GCHQ) in the UK, laid
out 14 security principles that organisations should use when evaluating cloud services, and which
cloud service providers should consider when offering those services to government customers
(referred to as consumers in the principles). The 14 principles are aligned with ISO 27001, an
auditable, international, information security management standard published by the International
Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC). ISO
27001 formally defines requirements for a complete ISMS to help protect and secure an organisations
data. The principles defined by CESG/NCSC are:
1. Data in transit protection. Consumer data transiting networks should be adequately protected
against tampering and eavesdropping via a combination of network protection and encryption.
2. Asset protection and resilience. Consumer data, and the assets that store or process it, should be
protected against physical tampering, loss, damage, and seizure.
3. Separation between consumers. Separation should exist between different consumers of the
service to prevent one malicious or compromised consumer from affecting the service or data of
another.
4. Governance framework. The service provider should have a security governance framework that
coordinates and directs their overall approach to the management of the service and information
within it.
5. Operational security. The service provider should have processes and procedures in place to
ensure the operational security of the service.
6. Personnel security. Service provider staff should be subject to personnel security screening and
security education appropriate for their role.
7. Secure development. Services should be designed and developed to identify and mitigate threats
to their security.
8. Supply chain security. The service provider should ensure that its supply chain satisfactorily
supports all of the security principles that the service claims to implement.
9. Secure consumer management. Consumers should be provided with the tools required to help
them securely manage their service.
10. Identity and authentication. Access to all service interfaces (for consumers and providers) should
be limited to authenticated and authorised individuals.
11. External interface protection. All external or less trusted interfaces of the service should be
identified and have appropriate protections to defend against attacks through them.
12. Secure service administration. The methods used by the service providers administrators to
manage the operational service should be designed to mitigate any risk of exploitation that could
undermine the security of the service.
13. Audit information provision to consumers. Consumers should be provided with the audit records
they need to monitor access to their service and the data held within it.
14. Secure use of the service by the consumer. Consumers have certain responsibilities when using a
cloud service in order for this use to remain secure, and for their data to be adequately protected.
This paper describes how Azure addresses each of these cloud security principles, and provides
information and advice that will help customers take full advantage of the security features offered by
Azure. Microsoft is committed to providing organisations located inside and outside of the UK that
their data will be kept secure and their privacy protected at the same levels that existed prior to the
invocation of Article 50 of the Lisbon Treaty.
The UK Governments 14 Cloud Security principles
1. Data in transit protection
Consumer data transiting networks should be adequately protected against tampering and
eavesdropping (confidentiality). If this principle is not implemented, the integrity or confidentiality
of the data may be compromised whilst in transit.
Azure uses the industry-standard Transport Layer Security (TLS) 1.2 protocol with 2048-bit
RSA/SHA256 encryption keys, as recommended by CESG/NCSC , to encrypt communications both
between the customer and the cloud, and also internally between Azure systems and data centers.
For example, when administrators use the Microsoft Azure Portal to manage the service for their
organisation, the data transmitted between the portal and the administrators device is sent over an
encrypted TLS channel. When an email user connects to Outlook.com using a standard web browser,
the HTTPS connection provides a secure channel for receiving and sending email.
Azure offers its customers a range of options for securing their own data and traffic. The certificate
management features built into Azure give administrators flexibility for configuring certificates and
encryption keys for management systems, individual services, secure shell (SSH) sessions, virtual
private network (VPN) connections, remote desktop (RDP) connections, and other functions.
Developers can use the cryptographic service providers (CSPs) built into the Microsoft .NET
Framework to access Advanced Encryption Standard (AES) algorithms, along with Secure Hash
Algorithm (SHA-2) functionality to handle such tasks as validating digital signatures. Azure Key Vault
helps customers safeguard cryptographic keys and secrets by storing them in hardware security
modules (HSMs).
Resources:
Client-Side Encryption and Azure Key Vault for Microsoft Azure Storage.
Data access and protection considerations for all devices, including BYOD (bring your own
device).
Service Management REST API Reference for Azure.
.NET Framework Cryptography Model. Azure is built on the .NET framework and provides
customers with access to the same strong cryptographic protocols and straightforward key
management methods incorporated into the .NET security model.
Validated VPN devices for implementing site-to-site VPN connections to Azure. Also see
ExpressRoute, a streamlined solution for establishing a secure private connection between
customer infrastructure and Azure datacenters.
Configuring SSL for an application in Azure.
Another type of resiliency is applications resiliency, which helps ensure that during either a planned or
unplanned maintenance event, at least one virtual machine will be available and meet the 99.95%
Azure SLA. See Manage the availability of virtual machines for more information.
Resource:
The CSA published the Cloud Control Matrix to support customers in the evaluation of cloud
providers and to identify questions that should be answered before moving to cloud services. In
response, Microsoft Azure answered the CSA Consensus Assessment Initiative Questionnaire CSA
CAIQ to describe how Microsoft addresses the suggested principles.
3. Separation between consumers
Separation should exist between different consumers of the service to prevent one malicious or
compromised consumer from affecting the service or data of another. If this principle is not
implemented, service providers cannot prevent a consumer of the service affecting the
confidentiality or integrity of another consumers data or service.
Because all customer cloud servers are virtual, the physical separation paradigm no longer applies.
Microsoft Azure was designed to help identify and counter risks inherent in a multitenant
environment. Data storage and processing is logically segregated among consumers of Azure using
Active Directory and functionality specifically developed for multitenant services, which aims to ensure
that consumer data stored in shared Azure data centers is not accessible by another organisation.
Fundamental to any shared cloud architecture is the isolation provided for each consumer to prevent
one malicious or compromised consumer from affecting the service or data of another. In Azure, one
customers subscription can include multiple deployments, and each deployment can contain multiple
VMs. Azure provides network isolation at several points:
Deployment. Each deployment is isolated from other deployments. Multiple VMs within a
deployment are allowed to communicate with each other through private IP addresses.
Virtual network. Multiple deployments (inside the same subscription) can be assigned to the same
virtual network, and then allowed to communicate with each other through private IP addresses.
Each virtual network is isolated from other virtual networks.
Traffic between VMs always traverses through trusted packet filters.
Protocols such as Address Resolution Protocol (ARP), Dynamic Host Configuration Protocol
(DHCP), and other OSI Layer-2 traffic from a VM are controlled using rate-limiting and anti-
spoofing protection.
VMs cannot capture any traffic on the network that is not destined for them.
Customer VMs cannot send traffic to Azure private interfaces, or other customers VMs, or Azure
infrastructure services themselves. Customer VMs can only communicate with other VMs owned
or controlled by the same customer and with Azure infrastructure service endpoints meant for
public communications.
To verify isolation on the platform:
Microsoft conducts ongoing penetration tests of the environment in accordance with the dynamic
nature of the cloud to help ensure that a consumers data remains private to them.
Residual risks are published in the Microsoft Risk Management and Accreditation Document Set
(RMADS) and Residual Risk statement, which are available under nondisclosure agreement (NDA)
from Microsoft.
4. Governance framework
The service provider should have a security governance framework that coordinates and directs
their overall approach to the management of the service and information within it. If this principle
is not implemented, any procedural, personnel, physical, and technical controls in place will not
remain effective when responding to changes in the service and to threat and technology
developments. Cloud service providers should have a security governance framework that
coordinates and directs their overall approach to the management of the service and information
within it.
The Microsoft compliance framework includes a standard methodology for defining compliance
domains, determining which objectives apply to a given team or asset, and capturing how domain
control objectives are addressed in sufficient detail as they apply to a given set of industry standards,
regulations, or business requirements. The framework maps controls to multiple regulatory standards,
which enables Microsoft to design and build services using a common set of controls, thereby
streamlining compliance across a range of regulations today and as they evolve in the future.
Microsoft compliance processes also make it easier for customers to achieve compliance across
multiple services and meet their changing needs efficiently. Together, security-enhancing technology
and effective compliance processes enable Microsoft to maintain and expand a rich set of third-party
certifications. These certifications help customers demonstrate compliance readiness to their
customers, auditors, and regulators.
The Microsoft compliance framework includes the following activities:
Identify and integrate requirements. Scope and applicable controls are defined. Standard
operating procedures (SOP) and process documents are gathered and reviewed. In the standard
plandocheckact management methodology that is well known in process development, this
activity aligns with the Plan phase.
Assess and remediate gaps. Gaps in process or technology controls are identified and
remediated, including the implementation of new administrative and technical controls. Aligns
with the Do phase.
Test effectiveness and assess risk. Effectiveness of controls is measured and reported. On a
consistent and regular basis, independent internal audit groups and external assessors review
internal controls. Compliance with internal security standards and requirements, such as
verification that product groups adhere to the Microsoft Security Development Lifecycle (SDL),
occurs in this phase. Aligns with the Check phase.
Attain certification and attestations. Engagement with third-party certification authorities and
auditors occurs. Aligns with the Act phase.
Improve and optimize. If issues or non-conformities are found, the reason is documented and
assessed further. Such findings are tracked until fully remediated. This phase also involves
continuing to optimize controls across security domains to generate efficiencies in passing future
audit and certification reviews. Aligns with the Act phase.
Azure complies with a broad set of international as well as regional and industry-specific compliance
standards, such as ISO 27001, FedRAMP, SOC 1, and SOC 2. Compliance with the strict security
controls contained in these standards is verified by rigorous third-party audits that demonstrate Azure
services work with and meet world-class industry standards, certifications, attestations, and
authorizations.
Azure is designed with a compliance strategy that helps customers address business objectives as well
as industry standards and regulations. The security compliance framework includes test and audit
phases, security analytics, risk management best practices, and security benchmark analysis to achieve
certificates and attestations.
Microsoft Azure offers the following certifications for all in-scope services:
CDSA. The Content Delivery and Security Association (CDSA) provides a Content Protection and
Security (CPS) standard for compliance with anti-piracy procedures governing digital media.
Azure passed the CDSA audit, enabling secure workflows for content development and
distribution.
CSA CCM. The Cloud Security Alliance (CSA) is a non-profit, member-driven organisation with a
mission to promote the use of best practices for providing security assurance within the cloud.
The CSA Cloud Controls Matrix (CCM) provides detailed information about how Azure fulfills the
security, privacy, compliance, and risk management requirements defined in the CCM version
3.0.1., and is published in the CSAs Security Trust and Assurance Registry (STAR).
EU Model Clauses. Microsoft offers customers EU Standard Contractual Clauses that provide
contractual guarantees around transfers of personal data outside of the European Union.
Microsoft is the first company to receive joint approval from the EUs Article 29 Working Party that
the contractual privacy protections Azure delivers to its enterprise cloud customers meet current
EU standards for international transfers of data. This approval ensures that Azure customers can
use Microsoft services to move data freely through the Microsoft cloud from Europe to the rest of
the world.
ISO/IEC 27018. Microsoft is the first cloud provider to have adopted the ISO/IEC 27018 code of
practice, which deals with the processing of personal information by cloud service providers.
ISO/IEC 27001/27002:2013. Azure complies with this standard, which defines the security controls
required of an information security management system.
PCI DSS. Azure is Level 1 compliant with Payment Card Industry (PCI) Data Security Standards
(DSS) version 3.0, the global certification standard for organisations that accept most payments
cards, as well store, process, or transmit cardholder data.
SOC 1 and SOC 2. Azure has been audited against the Service Organization Control (SOC)
reporting framework for both SOC 1 Type 2 and SOC 2 Type 2. Both reports are available to
customers to meet a wide range of US and international auditing requirements. The SOC 1 Type 2
audit report attests to the design and operating effectiveness of Azure controls. The SOC 2 Type
2 audit included a further examination of Azure controls related to security, availability, and
confidentiality. Azure is audited annually to ensure that security controls are maintained.
Resource:
13 Effective Security Controls for ISO 27001 Compliance when using Microsoft Azure. This paper
provides insight into how organisations can use thirteen security principles helps address critical
security and compliance controls, and how these controls can fast track an organisations ability to
meet its compliance obligations using cloud-based services.
5. Operational security
The service provider should have processes and procedures in place to ensure the operational
security of the service. If this principle is not implemented, the service cant be operated and
managed securely in order to impede, detect, or prevent attacks against it.
CESG/NCSC defines the following aspects to consider when implementing or assessing this principle:
Configuration and change management. Good configuration management processes should
ensure that knowledge of the assets which make up the service, along with their configuration
and dependencies, are known and accurate. Good change management processes should
ensure any changes to the service (which could have an effect on its security) are identified and
managed. They should also lead to detection of unauthorized changes.
Vulnerability management. Occasionally, vulnerabilities will be discovered which, if left
unmitigated, will pose an unacceptable risk to the service. Robust vulnerability management
processes are required to identify, triage, and mitigate vulnerabilities.
Protective monitoring. Effective protective monitoring allows a service provider to detect and
respond to attempted and successful attacks, misuse, and malfunction. A service which does
not effectively monitor for attacks and misuse will be unlikely to detect attacks (both successful
and unsuccessful) and will be unable to quickly respond to potential compromises of consumer
environments and data.
Operational Security Assurance (OSA) is a framework that incorporates the knowledge gained
through a variety of resources that are unique to Microsoft, such as the Microsoft Security Response
Center (MSRC), and incorporates deep awareness of the cybersecurity threat landscape. OSA
combines this knowledge with the experience of running hundreds of thousands of servers in data
centers around the world that deliver more than 200 online services to more than 1 billion customers
and 20 million businesses in 88 countries.
Microsoft uses OSA to minimize risk by helping to ensure that ongoing operational activities follow
rigorous security guidelines and by validating that guidelines are actually being followed effectively.
When issues arise, a feedback loop helps ensure that future revisions of OSA contain mitigations to
address them.
OSA helps make Microsoft cloud-based services infrastructure more resilient to attack by decreasing
the amount of time needed to prevent, detect, contain, and respond to real and potential Internet-
based security threats, thereby increasing the security of those services for customers.
Vulnerability management
Security update management helps protect systems from known vulnerabilities. Azure uses integrated
deployment systems to manage the distribution and installation of security updates for Microsoft
software. Azure is also able to draw on the resources of the Microsoft Security Response Center
(MSRC), which identifies, monitors, responds to, and resolves security incidents and cloud
vulnerabilities around the clock, each day of the year.
Protective monitoring
Microsoft has a global, 24x7 incident response service that works to mitigate the effects of attacks and
malicious activity. The incident response team follows established procedures for incident
management, communication, and recovery, and uses discoverable and predictable interfaces with
internal and external partners alike. See Principle 11 for more details about how Microsoft responds to
attempted attacks on Azure systems.
Resources:
Operational Security for Online Services Overview. This white paper provides insight into how
Microsoft applies its resources to online services in ways that extend beyond traditional standards
and methodology to deliver industry-leading capabilities.
Data classification for cloud readiness. This paper presents guidance for categorizing stored data
by sensitivity and business impact in order to determine the risks associated with the data.
Standard Response to Request for Information: Microsoft Azure Security, Privacy, and
Compliance. Details how Azure complies with the Cloud Security Alliance Cloud Controls Matrix
(CSA CCM) operational security requirements.
6. Personnel security
Service provider staff should be subject to personnel security screening and security education for
their role. If this principle is not implemented, the likelihood of accidental or malicious compromise
of consumer data by service provider personnel is increased.
Microsoft Azure Operations and Customer Support personnel and data center staff, who operate
Azure services and provide customer support (or Microsoft subcontractors who assist with platform
operations, troubleshooting, and technical support) undergo a Microsoft standard background (or
equivalent) check to evaluate employee education, employment, and criminal history. The
background checks that are carried out are broadly in line with the requirements of the UK
Governments BPSS / BS7858. They do not specifically include a formal identity check.
Microsoft includes nondisclosure provisions in its employee and subcontractor contracts. All
appropriate Microsoft employees and subcontractors take part in a Microsoft Azure sponsored
security-training program that informs staff of their responsibilities for information security.
Microsoft Azure services staff suspected of committing breaches of security and/or violating the
Information Security Policy (equivalent to a Microsoft Code of Conduct violation) are subject to an
investigation process and appropriate disciplinary action up to and including termination. Contracting
staff suspected of committing breaches of security and/or violations of the Information Security Policy
are subject to formal investigation and action appropriate to the associated contract, which may
include termination of such contracts. If the circumstances warrant it, Microsoft may refer the matter
for prosecution by a law enforcement agency.
To supplement this system of background checks and security education, Microsoft deploys
combinations of preventive, defensive, and reactive controls to help protect against unauthorized
developer and/or administrative activity, including the following mechanisms:
Tight access controls on sensitive data, including a requirement for two-factor smartcard-based
authentication to perform sensitive operations.
Combinations of controls that enhance independent detection of malicious activity.
Multiple levels of monitoring, logging, and reporting.
7. Secure development
Services should be designed and developed to identify and mitigate threats to their security. If this
principle is not implemented, services may be vulnerable to security issues which could
compromise consumer data, cause loss of service, or enable other malicious activity.
Cloud service providers need to use good development practices to ensure the secure delivery of
services to its customers. The Microsoft Security Development Lifecycle (SDL) provides an effective
threat-modeling process to identify threats and vulnerabilities in software and services. Threat
modeling is a team exercise, encompassing the operations manager, program/project managers,
developers, and testers, and represents a key security analysis task performed for solution design. This
approach should also be considered by customers developing their own applications to be hosted in
cloud services, either using IaaS or PaaS. Team members use the SDL Threat Modeling Tool to model
all services and projects, both when they are built and when they are updated with new features and
functionality. Threat models cover all code exposed on the attack surface and all code written by or
licensed from a third party, and consider all trust boundaries. The STRIDE system (Spoofing,
Tampering, Repudiation, Information disclosure, Denial of service, and Elevation of privilege) is used
to help identify and resolve security threats early in the design process, before they can affect
customers.
Conclusion
Cloud computing offers tremendous opportunities to enable increased quality and greater access at
lower cost of services. These advantages must be balanced against the complexity of managing
security and privacy in multi-tenanted cloud services and how an organisation shows the appropriate
compliance to applicable standards. Internal frameworks such as OSA and SDL, deep experience with
cloud computing, and compliance with such international standards as ISO 27001 provide Microsoft
with the ability to help organisations evaluate their overall privacy, security, and regulatory compliance
posture for the specific UK government requirements Implementing the Cloud Security Principles.
The information in this document is provided as a way to approach that migration, including:
compliance requirements, shared responsibilities, and rationalized mapping to address necessary
controls.