Tag Archives: Security Assurance

Embracing our broad responsibility for securing digital infrastructure in the European Union

Post Syndicated from Frank Adelmann original https://aws.amazon.com/blogs/security/embracing-our-broad-responsibility-for-securing-digital-infrastructure-in-the-european-union/

Over the past few decades, digital technologies have brought tremendous benefits to our societies, governments, businesses, and everyday lives. However, the more we depend on them for critical applications, the more we must do so securely. The increasing reliance on these systems comes with a broad responsibility for society, companies, and governments.

At Amazon Web Services (AWS), every employee, regardless of their role, works to verify that security is an integral component of every facet of the business (see Security at AWS). This goes hand-in-hand with new cybersecurity-related regulations, such as the Directive on Measures for a High Common Level of Cybersecurity Across the Union (NIS 2), formally adopted by the European Parliament and the Counsel of the European Union (EU) in December 2022. NIS 2 will be transposed into the national laws of the EU Member States by October 2024, and aims to strengthen cybersecurity across the EU.

AWS is excited to help customers become more resilient, and we look forward to even closer cooperation with national cybersecurity authorities to raise the bar on cybersecurity across Europe. Building society’s trust in the online environment is key to harnessing the power of innovation for social and economic development. It’s also one of our core Leadership Principles: Success and scale bring broad responsibility.

Compliance with NIS 2

NIS 2 seeks to ensure that entities mitigate the risks posed by cyber threats, minimize the impact of incidents, and protect the continuity of essential and important services in the EU.

Besides increased cooperation between authorities and support for enhanced information sharing amongst covered entities, NIS 2 includes minimum requirements for cybersecurity risk management measures and reporting obligations, which are applicable to a broad range of AWS customers based on their sector. Examples of sectors that must comply with NIS 2 requirements are energy, transport, health, public administration, and digital infrastructures. For the full list of covered sectors, see Annexes I and II of NIS 2. Generally, the NIS 2 Directive applies to a wider pool of entities than those currently covered by the NIS Directive, including medium-sized enterprises, as defined in Article 2 of the Annex to Recommendation 2003/361/EC (over 50 employees or an annual turnover over €10 million).

In several countries, aspects of the AWS service offerings are already part of the national critical infrastructure. For example, in Germany, Amazon Elastic Compute Cloud (Amazon EC2) and Amazon CloudFront are in scope for the KRITIS regulation. For several years, AWS has fulfilled its obligations to secure these services, run audits related to national critical infrastructure, and have established channels for exchanging security information with the German Federal Office for Information Security (BSI) KRITIS office. AWS is also part of the UP KRITIS initiative, a cooperative effort between industry and the German Government to set industry standards.

AWS will continue to support customers in implementing resilient solutions, in accordance with the shared responsibility model. Compliance efforts within AWS will include implementing the requirements of the act and setting out technical and methodological requirements for cloud computing service providers, to be published by the European Commission, as foreseen in Article 21 of NIS 2.

AWS cybersecurity risk management – Current status

Even before the introduction of NIS 2, AWS has been helping customers improve their resilience and incident response capacities. Our core infrastructure is designed to satisfy the security requirements of the military, global banks, and other highly sensitive organizations.

AWS provides information and communication technology services and building blocks that businesses, public authorities, universities, and individuals use to become more secure, innovative, and responsive to their own needs and the needs of their customers. Security and compliance remain a shared responsibility between AWS and the customer. We make sure that the AWS cloud infrastructure complies with applicable regulatory requirements and good practices for cloud providers, and customers remain responsible for building compliant workloads in the cloud.

In total, AWS supports or has obtained over 143 security standards compliance certifications and attestations around the globe, such as ISO 27001, ISO 22301, ISO 20000, ISO 27017, and System and Organization Controls (SOC) 2. The following are some examples of European certifications and attestations that we’ve achieved:

  • C5 — provides a wide-ranging control framework for establishing and evidencing the security of cloud operations in Germany.
  • ENS High — comprises principles for adequate protection applicable to government agencies and public organizations in Spain.
  • HDS — demonstrates an adequate framework for technical and governance measures to secure and protect personal health data, governed by French law.
  • Pinakes — provides a rating framework intended to manage and monitor the cybersecurity controls of service providers upon which Spanish financial entities depend.

These and other AWS Compliance Programs help customers understand the robust controls in place at AWS to help ensure the security and compliance of the cloud. Through dedicated teams, we’re prepared to provide assurance about the approach that AWS has taken to operational resilience and to help customers achieve assurance about the security and resiliency of their workloads. AWS Artifact provides on-demand access to these security and compliance reports and many more.

For security in the cloud, it’s crucial for our customers to make security by design and security by default central tenets of product development. To begin with, customers can use the AWS Well-Architected tool to help build secure, high-performing, resilient, and efficient infrastructure for a variety of applications and workloads. Customers that use the AWS Cloud Adoption Framework (AWS CAF) can improve cloud readiness by identifying and prioritizing transformation opportunities. These foundational resources help customers secure regulated workloads. AWS Security Hub provides customers with a comprehensive view of their security state on AWS and helps them check their environments against industry standards and good practices.

With regards to the cybersecurity risk management measures and reporting obligations that NIS 2 mandates, existing AWS service offerings can help customers fulfill their part of the shared responsibility model and comply with future national implementations of NIS 2. For example, customers can use Amazon GuardDuty to detect a set of specific threats to AWS accounts and watch out for malicious activity. Amazon CloudWatch helps customers monitor the state of their AWS resources. With AWS Config, customers can continually assess, audit, and evaluate the configurations and relationships of selected resources on AWS, on premises, and on other clouds. Furthermore, AWS Whitepapers, such as the AWS Security Incident Response Guide, help customers understand, implement, and manage fundamental security concepts in their cloud architecture.

NIS 2 foresees the development and implementation of comprehensive cybersecurity awareness training programs for management bodies and employees. At AWS, we provide various training programs at no cost to the public to increase awareness on cybersecurity, such as the Amazon cybersecurity awareness training, AWS Cloud Security Learning, AWS re/Start, and AWS Ramp-Up Guides.

AWS cooperation with authorities

At Amazon, we strive to be the world’s most customer-centric company. For AWS Security Assurance, that means having teams that continuously engage with authorities to understand and exceed regulatory and customer obligations on behalf of customers. This is just one way that we raise the security bar in Europe. At the same time, we recommend that national regulators carefully assess potentially conflicting, overlapping, or contradictory measures.

We also cooperate with cybersecurity agencies around the globe because we recognize the importance of their role in keeping the world safe. To that end, we have built the Global Cybersecurity Program (GCSP) to provide agencies with a direct and consistent line of communication to the AWS Security team. Two examples of GCSP members are the Dutch National Cyber Security Centrum (NCSC-NL), with whom we signed a cooperation in May 2023, and the Italian National Cybersecurity Agency (ACN). Together, we will work on cybersecurity initiatives and strengthen the cybersecurity posture across the EU. With the war in Ukraine, we have experienced how important such a collaboration can be. AWS has played an important role in helping Ukraine’s government maintain continuity and provide critical services to citizens since the onset of the war.

The way forward

At AWS, we will continue to provide key stakeholders with greater insights into how we help customers tackle their most challenging cybersecurity issues and provide opportunities to deep dive into what we’re building. We very much look forward to continuing our work with authorities, agencies and, most importantly, our customers to provide for the best solutions and raise the bar on cybersecurity and resilience across the EU and globally.

If you have feedback about this post, submit comments in the Comments section below. If you have questions about this post, contact AWS Support.

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Frank Adelmann

Frank Adelmann

Frank is the Regulated Industry and Security Engagement Lead for Regulated Commercial Sectors in Europe. He joined AWS in 2022 after working as a regulator in the European financial sector, technical advisor on cybersecurity matters in the International Monetary Fund, and Head of Information Security in the European Commodity Clearing AG. Today, Frank is passionately engaging with European regulators to understand and exceed regulatory and customer expectations.

161 AWS services achieve HITRUST certification

Post Syndicated from Mark Weech original https://aws.amazon.com/blogs/security/161-aws-services-achieve-hitrust-certification/

The Amazon Web Services (AWS) HITRUST Compliance Team is excited to announce that 161 AWS services have been certified for the HITRUST CSF version 11.0.1 for the 2023 cycle. The full list of AWS services, which were audited by a third-party assessor and certified under the HITRUST CSF, is now available on our Services in Scope by Compliance Program page. You can view and download our HITRUST CSF certification at any time on demand through AWS Artifact.

The HITRUST CSF has been widely adopted by leading organizations in a variety of industries in their approach to security and privacy. Visit the HITRUST website for more information. HITRUST certification allows you, as an AWS customer, to tailor your security control baselines specific to your architecture and assessment scope, and inherit certification for those controls so they don’t have to be tested as a component of your HITRUST assessment. Because cloud-based controls don’t have to be retested, AWS customers enjoy savings in both time and cost for their own HITRUST assessment certification needs.

AWS HITRUST CSF certification is available for customer inheritance with an updated Shared Responsibility Matrix version 1.4.1

As an added benefit to our customers, organizations no longer have to assess inherited controls for their HITRUST validated assessment, because AWS already has! Our customers can deploy business solutions into the AWS cloud environment and inherit our HITRUST CSF certification for those controls applicable to their cloud architecture for services that are in-scope of the AWS HITRUST assessment. A detailed listing of controls and corresponding inheritance values can be found on the HITRUST website.

The AWS HITRUST Inheritance Program supports the latest version of HITRUST controls (v11.1), and is excited to announce the availability of the latest Shared Responsibility Matrix (SRM) version 1.4.1. As an added benefit, the AWS HITRUST Inheritance Program also supports the control inheritance of AWS cloud-based workloads for new HITRUST e1 and i1 assessment types, as well as the validated r2-type assessments offered through HITRUST. The SRM is also backward-compatible to earlier versions of the HITRUST CSF from v9.1 through v11.

Additionally, through the AWS HITRUST Inheritance Program, AWS is a member of the Health 3rd Party Trust Initiative (Health3PT), a consortium of the largest US-based healthcare systems that is proactively committed to reducing third-party information security risk with more reliable and efficient assurances. You can find additional information at https://health3pt.org.

As always, we value your feedback and questions and are committed to helping you achieve and maintain the highest standard of security and compliance. Feel free to contact the team through AWS Compliance Contact Us.

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Mark Weech

Mark Weech

Mark is the AWS HITRUST Compliance Program Manager and has over 30 years of experience in compliance and cybersecurity roles pertaining to the healthcare, finance, and national defense industries. Mark holds several cybersecurity certifications and is a member of InfraGard’s Cyber Health Working Group—a partnership between the Federal Bureau of Investigation (FBI) and members of the private sector for the protection of US critical infrastructure (healthcare section).

How to use tokenization to improve data security and reduce audit scope

Post Syndicated from Tim Winston original https://aws.amazon.com/blogs/security/how-to-use-tokenization-to-improve-data-security-and-reduce-audit-scope/

Tokenization of sensitive data elements is a hot topic, but you may not know what to tokenize, or even how to determine if tokenization is right for your organization’s business needs. Industries subject to financial, data security, regulatory, or privacy compliance standards are increasingly looking for tokenization solutions to minimize distribution of sensitive data, reduce risk of exposure, improve security posture, and alleviate compliance obligations. This post provides guidance to determine your requirements for tokenization, with an emphasis on the compliance lens given our experience as PCI Qualified Security Assessors (PCI QSA).

What is tokenization?

Tokenization is the process of replacing actual sensitive data elements with non-sensitive data elements that have no exploitable value for data security purposes. Security-sensitive applications use tokenization to replace sensitive data, such as personally identifiable information (PII) or protected health information (PHI), with tokens to reduce security risks.

De-tokenization returns the original data element for a provided token. Applications may require access to the original data, or an element of the original data, for decisions, analysis, or personalized messaging. To minimize the need to de-tokenize data and to reduce security exposure, tokens can retain attributes of the original data to enable processing and analysis using token values instead of the original data. Common characteristics tokens may retain from the original data are:

Format attributes

Length for compatibility with storage and reports of applications written for the original data
Character set for compatibility with display and data validation of existing applications
Preserved character positions such as first 6 and last 4 for credit card PAN

Analytics attributes

Mapping consistency where the same data always results in the same token
Sort order

Retaining functional attributes in tokens must be implemented in ways that do not defeat the security of the tokenization process. Using attribute preservation functions can possibly reduce the security of a specific tokenization implementation. Limiting the scope and access to tokens addresses limitations introduced when using attribute retention.

Why tokenize? Common use cases

I need to reduce my compliance scope

Tokens are generally not subject to compliance requirements if there is sufficient separation of the tokenization implementation and the applications using the tokens. Encrypted sensitive data may not reduce compliance obligations or scope. Such industry regulatory standards as PCI DSS 3.2.1 still consider systems that store, process, or transmit encrypted cardholder data as in-scope for assessment; whereas tokenized data may remove those systems from assessment scope. A common use case for PCI DSS compliance is replacing PAN with tokens in data sent to a service provider, which keeps the service provider from being subject to PCI DSS.

I need to restrict sensitive data to only those with a “need-to-know”

Tokenization can be used to add a layer of explicit access controls to de-tokenization of individual data items, which can be used to implement and demonstrate least-privileged access to sensitive data. For instances where data may be co-mingled in a common repository such as a data lake, tokenization can help ensure that only those with the appropriate access can perform the de-tokenization process and reveal sensitive data.

I need to avoid sharing sensitive data with my service providers

Replacing sensitive data with tokens before providing it to service providers who have no access to de-tokenize data can eliminate the risk of having sensitive data within service providers’ control, and avoid having compliance requirements apply to their environments. This is common for customers involved in the payment process, which provides tokenization services to merchants that tokenize the card holder data, and return back to their customers a token they can use to complete card purchase transactions.

I need to simplify data lake security and compliance

A data lake centralized repository allows you to store all your structured and unstructured data at any scale, to be used later for not-yet-determined analysis. Having multiple sources and data stored in multiple structured and unstructured formats creates complications for demonstrating data protection controls for regulatory compliance. Ideally, sensitive data should not be ingested at all; however, that is not always feasible. Where ingestion of such data is necessary, tokenization at each data source can keep compliance-subject data out of data lakes, and help avoid compliance implications. Using tokens that retain data attributes, such as data-to-token consistency (idempotence) can support many of the analytical capabilities that make it useful to store data in the data lake.

I want to allow sensitive data to be used for other purposes, such as analytics

Your organization may want to perform analytics on the sensitive data for other business purposes, such as marketing metrics, and reporting. By tokenizing the data, you can minimize the locations where sensitive data is allowed, and provide tokens to users and applications needing to conduct data analysis. This allows numerous applications and processes to access the token data and maintain security of the original sensitive data.

I want to use tokenization for threat mitigation

Using tokenization can help you mitigate threats identified in your workload threat model, depending on where and how tokenization is implemented. At the point where the sensitive data is tokenized, the sensitive data element is replaced with a non-sensitive equivalent throughout the data lifecycle, and across the data flow. Some important questions to ask are:

  • What are the in-scope compliance, regulatory, privacy, or security requirements for the data that will be tokenized?
  • When does the sensitive data need to be tokenized in order to meet security and scope reduction objectives?
  • What attack vector is being addressed for the sensitive data by tokenizing it?
  • Where is the tokenized data being hosted? Is it in a trusted environment or an untrusted environment?

For additional information on threat modeling, see the AWS security blog post How to approach threat modeling.

Tokenization or encryption consideration

Tokens can provide the ability to retain processing value of the data while still managing the data exposure risk and compliance scope. Encryption is the foundational mechanism for providing data confidentiality.

Encryption rarely results in cipher text with a similar format to the original data, and may prevent data analysis, or require consuming applications to adapt.

Your decision to use tokenization instead of encryption should be based on the following:

Reduction of compliance scope As discussed above, by properly utilizing tokenization to obfuscate sensitive data you may be able to reduce the scope of certain framework assessments such as PCI DSS 3.2.1.
Format attributes Used for compatibility with existing software and processes.
Analytics attributes Used to support planned data analysis and reporting.
Elimination of encryption key management A tokenization solution has one essential API—create token—and one optional API—retrieve value from token. Managing access controls can be simpler than some non-AWS native general purpose cryptographic key use policies. In addition, the compromise of the encryption key compromises all data encrypted by that key, both past and future. The compromise of the token database compromises only existing tokens.

Where encryption may make more sense

Although scope reduction, data analytics, threat mitigation, and data masking for the protection of sensitive data make very powerful arguments for tokenization, we acknowledge there may be instances where encryption is the more appropriate solution. Ask yourself these questions to gain better clarity on which solution is right for your company’s use case.

Scalability If you require a solution that scales to large data volumes, and have the availability to leverage encryption solutions that require minimal key management overhead, such as AWS Key Management Services (AWS KMS), then encryption may be right for you.
Data format If you need to secure data that is unstructured, then encryption may be the better option given the flexibility of encryption at various layers and formats.
Data sharing with 3rd parties If you need to share sensitive data in its original format and value with a 3rd party, then encryption may be the appropriate solution to minimize external access to your token vault for de-tokenization processes.

What type of tokenization solution is right for your business?

When trying to decide which tokenization solution to use, your organization should first define your business requirements and use cases.

  1. What are your own specific use cases for tokenized data, and what is your business goal? Identifying which use cases apply to your business and what the end state should be is important when determining the correct solution for your needs.
  2. What type of data does your organization want to tokenize? Understanding what data elements you want to tokenize, and what that tokenized data will be used for may impact your decision about which type of solution to use.
  3. Do the tokens need to be deterministic, the same data always producing the same token? Knowing how the data will be ingested or used by other applications and processes may rule out certain tokenization solutions.
  4. Will tokens be used internally only, or will the tokens be shared across other business units and applications? Identifying a need for shared tokens may increase the risk of token exposure and, therefore, impact your decisions about which tokenization solution to use.
  5. How long does a token need to be valid? You will need to identify a solution that can meet your use cases, internal security policies, and regulatory framework requirements.

Choosing between self-managed tokenization or tokenization as a service

Do you want to manage the tokenization within your organization, or use Tokenization as a Service (TaaS) offered by a third-party service provider? Some advantages to managing the tokenization solution with your company employees and resources are the ability to direct and prioritize the work needed to implement and maintain the solution, customizing the solution to the application’s exact needs, and building the subject matter expertise to remove a dependency on a third party. The primary advantages of a TaaS solution are that it is already complete, and the security of both tokenization and access controls are well tested. Additionally, TaaS inherently demonstrates separation of duties, because privileged access to the tokenization environment is owned by the tokenization provider.

Choosing a reversible tokenization solution

Do you have a business need to retrieve the original data from the token value? Reversible tokens can be valuable to avoid sharing sensitive data with internal or third-party service providers in payments and other financial services. Because the service providers are passed only tokens, they can avoid accepting additional security risk and compliance scope. If your company implements or allows de-tokenization, you will need to be able to demonstrate strict controls on the management and use of de-tokenization privilege. Eliminating the implementation of de-tokenization is the clearest way to demonstrate that downstream applications cannot have sensitive data. Given the security and compliance risks of converting tokenized data back into its original data format, this process should be highly monitored, and you should have appropriate alerting in place to detect each time this activity is performed.

Operational considerations when deciding on a tokenization solution

While operational considerations are outside the scope of this post, they are important factors for choosing a solution. Throughput, latency, deployment architecture, resiliency, batch capability, and multi-regional support can impact the tokenization solution of choice. Integration mechanisms with identity and access control and logging architectures, for example, are important for compliance controls and evidence creation.

No matter which deployment model you choose, the tokenization solution needs to meet security standards, similar to encryption standards, and must prevent determining what the original data is from the token values.


Using tokenization solutions to replace sensitive data offers many security and compliance benefits. These benefits include lowered security risk and smaller audit scope, resulting in lower compliance costs and a reduction in regulatory data handling requirements.

Your company may want to use sensitive data in new and innovative ways, such as developing personalized offerings that use predictive analysis and consumer usage trends and patterns, fraud monitoring and minimizing financial risk based on suspicious activity analysis, or developing business intelligence to improve strategic planning and business performance. If you implement a tokenization solution, your organization can alleviate some of the regulatory burden of protecting sensitive data while implementing solutions that use obfuscated data for analytics.

On the other hand, tokenization may also add complexity to your systems and applications, as well as adding additional costs to maintain those systems and applications. If you use a third-party tokenization solution, there is a possibility of being locked into that service provider due to the specific token schema they may use, and switching between providers may be costly. It can also be challenging to integrate tokenization into all applications that use the subject data.

In this post, we have described some considerations to help you determine if tokenization is right for you, what to consider when deciding which type of tokenization solution to use, and the benefits. disadvantages, and comparison of tokenization and encryption. When choosing a tokenization solution, it’s important for you to identify and understand all of your organizational requirements. This post is intended to generate questions your organization should answer to make the right decisions concerning tokenization.

You have many options available to tokenize your AWS workloads. After your organization has determined the type of tokenization solution to implement based on your own business requirements, explore the tokenization solution options available in AWS Marketplace. You can also build your own solution using AWS guides and blog posts. For further reading, see this blog post: Building a serverless tokenization solution to mask sensitive data.

If you have feedback about this post, submit comments in the Comments section below. If you have questions about this post, start a new thread on the Amazon Security Assurance Services or contact AWS Support.

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Tim Winston

Tim is a Senior Assurance Consultant with AWS Security Assurance Services. He leverages more than 20 years’ experience as a security consultant and assessor to provide AWS customers with guidance on payment security and compliance. He is a co-author of the “Payment Card Industry Data Security Standard (PCI DSS) 3.2.1 on AWS”.


Kristine Harper

Kristine is a Senior Assurance Consultant and PCI DSS Qualified Security Assessor (QSA) with AWS Security Assurance Services. Her professional background includes security and compliance consulting with large fintech enterprises and government entities. In her free time, Kristine enjoys traveling, outdoor activities, spending time with family, and spoiling her pets.


Michael Guzman

Michael is an Assurance Consultant with AWS Security Assurance Services. Michael is a PCI QSA and HITRUST CCSFP, along with holding several AWS certifications. His background is in Financial Services IT Operations and Administrations, with over 20 years experience within that industry. In his spare time Michael enjoy’s spending time with his family, continuing to improve his golf skills and perfecting his Tri-Tip recipe.