Hey there! Let's chat about something called "Internal Compliance Testing". I know, I know, it sounds about as exciting as watching paint dry. But trust me, it's actually pretty important stuff. Basically, it means that organizations need to regularly check that they are following their own rules and that those rules are actually working.

Where did this come from?

This little gem comes straight from the "CSA Cloud Controls Matrix v4.0.10 - 2023-09-26". You can download the full matrix here if you're really keen. The matrix was put together by some smart folks at the Cloud Security Alliance to help organizations secure their cloud environments.

Who should care?

If you're a compliance officer, risk manager, or anyone else responsible for making sure your organization is following the rules, this one's for you. It's especially important if you're working with third-party suppliers or have service level agreements (SLAs) in place.

What is the risk?

Without regular internal compliance testing, organizations risk drifting away from their own standards. This can lead to security gaps, breaches of SLAs, and non-compliance with legal and regulatory requirements. In the worst case, it could result in data breaches, financial losses, and reputational damage.

What's the care factor?

On a scale of "meh" to "oh sh*t", this one's probably a solid "pay attention". While it may not be the most glamorous task, internal compliance testing is a key part of good governance and risk management. It's especially important in highly regulated industries or for organizations dealing with sensitive data.

When is it relevant?

Internal compliance testing should be done regularly, at least annually. It's particularly relevant when:

• You have third-party suppliers handling your data
• You have SLAs with customers that promise certain levels of security or performance
• You operate in a highly regulated industry
• You've recently made significant changes to your systems or processes

What are the trade offs?

Like most things in security, internal compliance testing takes time and resources. You'll need to assign people to conduct the tests, which takes them away from other work. The tests themselves can also be disruptive, especially if they involve things like penetration testing. However, the costs of not doing testing can be much higher.

How to make it happen?

1. Define the scope of your testing. What standards, policies, and SLAs do you need to assess?
2. Identify the systems, processes, and third-parties that are in-scope for testing.
3. Develop a testing plan. What types of tests will you conduct (e.g. interviews, sample testing, penetration testing)?
4. Assign responsibilities. Who will conduct the tests? Do they have the necessary skills and authority?
5. Execute the testing plan. Document all results, including any non-conformities.
6. Report the results to relevant stakeholders. Include recommendations for addressing any issues.
7. Follow up to ensure that corrective actions are implemented.

What are some gotchas?

• Make sure your testers have the necessary permissions to access systems and data. They may need specific IAM permissions like ec2:StartInstances for AWS. See the AWS documentation for details.
• Be careful not to disrupt production systems during testing. Use staging environments where possible.
• Don't forget to test your third-party suppliers. Their compliance is your compliance.

What are the alternatives?

Honestly, there aren't really any alternatives to internal compliance testing. You could rely solely on external audits, but that's riskier and usually more expensive. Automated compliance tools can help streamline the process, but they don't replace the need for human oversight.

Explore further

• Check out control A&A-02 in the CSA CCM for more on compliance assessments
• The CIS Controls (especially Control 3) have some good guidance on continuous vulnerability management
• NIST SP 800-53 is the bible of security controls if you want to go deep

So there you have it - internal compliance testing in a nutshell. It may not be the most thrilling topic, but it's a vital part of keeping your organization secure and compliant. Now if you'll excuse me, I have some paint drying that needs my attention...

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