The Governance Responsibility Model is a critical component of an effective governance, risk and compliance program. It involves clearly defining and documenting the roles and responsibilities for planning, implementing, operating, assessing, and improving governance initiatives. Without a well-defined responsibility model, accountability can become blurred, leading to gaps in oversight and potential security risks.

Where did this come from?

This control comes from the CSA Cloud Controls Matrix v4.0.10 - 2023-09-26. You can download the full matrix here. The matrix provides a comprehensive set of controls to help organizations assess the security posture of their cloud providers and guide internal security initiatives. For more guidance on establishing effective cloud governance, refer to the AWS Cloud Adoption Framework.

Who should care?

• CISOs and security leadership responsible for overall governance and risk management
• Compliance officers tasked with ensuring adherence to regulatory requirements
• IT managers involved in implementing and operating security controls
• Auditors assessing the effectiveness of governance programs

What is the risk?

Without clearly defined roles and responsibilities for governance:

• Security initiatives may lack clear ownership, leading to gaps in implementation
• Compliance violations may occur due to lack of oversight and accountability
• Incident response may be delayed or ineffective due to confusion over who is responsible for taking action
• Overall security posture may degrade over time without ongoing governance

What's the care factor?

Establishing a clear governance responsibility model should be a top priority for any organization operating in the cloud. The distributed nature of cloud environments and the shared responsibility model make effective governance critical. Regulators and auditors will expect to see well-documented roles and responsibilities. Failure in this area could lead to significant security incidents, data breaches, and reputational damage.

When is it relevant?

A governance responsibility model is relevant for:

• Organizations of all sizes operating in the cloud
• Regulated industries with strict compliance requirements (e.g. finance, healthcare)
• Organizations with complex, multi-cloud environments
• Enterprises with globally distributed teams

It may be less critical for smaller organizations with simple cloud deployments and centralized IT teams. However, as the organization and cloud usage grows, a responsibility model becomes increasingly important.

What are the trade-offs?

Implementing a comprehensive governance responsibility model requires:

• Significant time and effort to define and document roles and responsibilities across the organization
• Ongoing maintenance to keep documentation up-to-date as roles and cloud usage evolve
• Potential friction with DevOps teams who may view governance processes as bureaucratic overhead
• Balancing the need for oversight with the autonomy required for innovation and agility

How to make it happen?

1. Assemble a cross-functional team including security, compliance, IT, and business leadership
2. Review existing security policies, standards, and procedures
3. Define high-level roles and responsibilities for governance (e.g. strategy, implementation, operations, audit)
4. Break down each area into more granular responsibilities
5. Map responsibilities to specific individuals or teams
6. Use a RACI matrix to clarify roles (responsible, accountable, consulted, informed)
7. Validate the model with all stakeholders
8. Communicate roles and responsibilities broadly
9. Incorporate into employee onboarding and training
10. Schedule regular reviews and updates based on organizational changes

What are some gotchas?

• Failing to get buy-in and input from all relevant stakeholders
• Defining roles and responsibilities too broadly without clear ownership
• Not keeping the responsibility model up-to-date as the organization and cloud usage changes
• Failing to communicate and reinforce roles and responsibilities on an ongoing basis
• Not defining clear escalation paths for issues and incidents

Specific AWS permissions that may be required include:

• iam:GetAccountSummary to view users, groups, and roles (docs)
• iam:GetPolicy and iam:GetPolicyVersion to review permissions policies (docs)

What are the alternatives?

While a formal governance responsibility model is best practice, some alternatives for smaller organizations may include:

• Defining high-level responsibilities in job descriptions rather than a separate model
• Communicating roles and responsibilities through regular team meetings and training
• Using a simplified responsibility matrix focused on key areas like incident response

Explore further

• AWS Shared Responsibility Model
• CIS Control 17: Governance
• NIST SP 800-53 PM-3: Information Security Resources

This detailed article provides an overview of the Governance Responsibility Model control from the CSA CCM, including key responsibilities, risks, and implementation guidance. By defining clear roles and responsibilities for cloud governance, organizations can strengthen their security posture and ensure accountability.

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