Why Attestations Are Just One Part of Your Cloud Security Program

Steven Murray

Jul 5, 2017

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1 min read

Why Attestations Are Just One Part of Your Cloud Security Program

Key Takeaways

    • Attestations alone don’t guarantee security. They confirm that certain standards are met, but not that controls are functioning or monitored properly.

    • Operational readiness matters more than certification. A company can pass an audit while its security tools—like IDS/IPS systems—are nonfunctional.

    • Auditors often verify existence, not performance. Many attestations assess whether systems exist, not whether they are configured correctly or actively maintained.

    • A strong cloud security program blends compliance with continuous monitoring. Attestations provide a compliance baseline, but ongoing testing and evaluation ensure true protection.

    • Third-party penetration tests reveal real vulnerabilities. They offer deeper insights than surveys or checklists, validating that security measures work under real-world conditions.

    • Vendor evaluations should consider data access and risk exposure. Partners handling sensitive information deserve stricter scrutiny and regular review.

    • Effective security requires transparency. Mature organizations willingly share policies, incident response frameworks, and vulnerability management procedures.

Q&A Highlights

  • Why aren’t attestations a reliable measure of security maturity?

    Because they only prove that required controls exist, not that they work. True security maturity involves ongoing validation, monitoring, and responsiveness to threats.

  • What’s a common failure in relying solely on compliance checks?

    Organizations may deploy tools just to “check the box.” For example, an IDS may be installed but not actually configured to detect or alert on threats.

  • What should you review beyond attestations when evaluating a vendor?

    Always examine the full findings report (not just the summary), ask about annual penetration testing, and request access to core security documentation.

  • How can third-party testing improve a security program?

    Penetration tests simulate real-world attacks, revealing weaknesses that compliance audits overlook, ensuring that defenses function as intended.

  • What defines a mature cloud security program?

    A balanced approach combining attestations, continuous monitoring, data protection strategies, incident response readiness, and proactive vulnerability management.

  • How should you assess vendors’ security postures?

    Evaluate based on the sensitivity of data they access—vendors handling customer data should meet higher security standards and undergo regular reviews.

People often ask me what makes a good security program. As much as I would like to point to one aspect of my security perimeter to use as an example, there are multiple items to highlight.

Attestations Don’t Always Measure your Defensive Posture

An attestation, by definition, is an indication that makes something evident. In the case of the security, specifically security programs it means to certify in an official capacity.

People often ask me what makes a good security program. As much as I would like to point to one aspect of my security perimeter to use as an example, there are multiple items to highlight. The industry relies on attestations and certifications to measure your security defenses. Engineers and operators will tell you that your actual security perimeter and threat assessment capabilities define your security program. I will tell you it is both compliance attestations as a measurement and the operational capabilities of your security team that define your program. Though attestations alone are not an accurate benchmark to measure a program.

Attestations are an industry necessity to ensure compliance with federal, local and state statutes as well as industry best practices. ISO, NIST or DoD standards form the baseline of most attestations. NIST, for example, publishes a set of standards and technical guides to help organizations build perimeter defenses that are “acceptable” to the government. As I will outline however, just because the standards are set doesn’t mean implementation is always stellar.

Deployment of a Tool Doesn’t Mean it is Providing Value

Controls allow for flexibility in implementation and operational growth and innovation over time. Unfortunately some organizations use the flexibility to check the box, but have no real defenses in place.

A prime example of this problem is intrusion detection/protection systems (IDS or IPS). Like virus scanners, most organizations invest in IDS/IPS as a matter of standard security practices to guard against malicious traffic and data exfiltration. The industry is replete with vendors making various forms of IDS/IPS systems. However, some organizations build systems rather than buy.

I recently left one such organization that “built” their own intrusion detection system from open source tools. Auditors were told the system was a “fantastic tool”, and even given examples of traffic. When I dug deeper into the telemetry the tool was providing, I realized that traffic was not being analyzed at all. Rather, passing through the sensor as it was not configured to capture any traffic or alert at all. Furthermore, the credentials used to administer the tool were set up by a previous employee and were never updated after his departure. So essentially, the tool was sitting idle for months without any human intervention. Not only does this put the company at risk, but it also compromises the perimeter.

A savvy auditor wouldn’t have caught the issue because the attestations don’t look for “operational” information on all systems – the standard is literally one layer of question and answer. In fact, most attestations measure simply if the tool exists, not operational viability. Additionally, most auditors are not technical enough to discern a functional IDS/IPS from a non-functional. The meat of the audit relies on the company to put their best foot forward rather than answer tough questions. Auditors also have to cover a vast array of controls during an audit so time is a large factor in the quality of their analysis.

An attestation alone will tell you that a company has a mature security program with controls. Requiring a potential partner to complete a vendor survey won’t provide you confidence either. Surveys merely outline the same information in a different format. So how do you evaluate a mature security program?

Controls allow for flexibility in implementation and operational growth and innovation over time. Unfortunately some organizations use the flexibility to check the box, but have no real defenses in place.

A prime example of this problem is intrusion detection/protection systems (IDS or IPS). Like virus scanners, most organizations invest in IDS/IPS as a matter of standard security practices to guard against malicious traffic and data exfiltration. The industry is replete with vendors making various forms of IDS/IPS systems. However, some organizations build systems rather than buy.

I recently left one such organization that “built” their own intrusion detection system from open source tools. Auditors were told the system was a “fantastic tool”, and even given examples of traffic. When I dug deeper into the telemetry the tool was providing, I realized that traffic was not being analyzed at all. Rather, passing through the sensor as it was not configured to capture any traffic or alert at all. Furthermore, the credentials used to administer the tool were set up by a previous employee and were never updated after his departure. So essentially, the tool was sitting idle for months without any human intervention. Not only does this put the company at risk, but it also compromises the perimeter.

A savvy auditor wouldn’t have caught the issue because the attestations don’t look for “operational” information on all systems – the standard is literally one layer of question and answer. In fact, most attestations measure simply if the tool exists, not operational viability. Additionally, most auditors are not technical enough to discern a functional IDS/IPS from a non-functional. The meat of the audit relies on the company to put their best foot forward rather than answer tough questions. Auditors also have to cover a vast array of controls during an audit so time is a large factor in the quality of their analysis.

An attestation alone will tell you that a company has a mature security program with controls. Requiring a potential partner to complete a vendor survey won’t provide you confidence either. Surveys merely outline the same information in a different format. So how do you evaluate a mature security program?

Controls allow for flexibility in implementation and operational growth and innovation over time. Unfortunately some organizations use the flexibility to check the box, but have no real defenses in place.

A prime example of this problem is intrusion detection/protection systems (IDS or IPS). Like virus scanners, most organizations invest in IDS/IPS as a matter of standard security practices to guard against malicious traffic and data exfiltration. The industry is replete with vendors making various forms of IDS/IPS systems. However, some organizations build systems rather than buy.

I recently left one such organization that “built” their own intrusion detection system from open source tools. Auditors were told the system was a “fantastic tool”, and even given examples of traffic. When I dug deeper into the telemetry the tool was providing, I realized that traffic was not being analyzed at all. Rather, passing through the sensor as it was not configured to capture any traffic or alert at all. Furthermore, the credentials used to administer the tool were set up by a previous employee and were never updated after his departure. So essentially, the tool was sitting idle for months without any human intervention. Not only does this put the company at risk, but it also compromises the perimeter.

A savvy auditor wouldn’t have caught the issue because the attestations don’t look for “operational” information on all systems – the standard is literally one layer of question and answer. In fact, most attestations measure simply if the tool exists, not operational viability. Additionally, most auditors are not technical enough to discern a functional IDS/IPS from a non-functional. The meat of the audit relies on the company to put their best foot forward rather than answer tough questions. Auditors also have to cover a vast array of controls during an audit so time is a large factor in the quality of their analysis.

An attestation alone will tell you that a company has a mature security program with controls. Requiring a potential partner to complete a vendor survey won’t provide you confidence either. Surveys merely outline the same information in a different format. So how do you evaluate a mature security program?

Evaluate the Entire Cloud Security Program

First, you should review at a minimum the attestations and the findings report, not the executive summary. That will provide you with an overview of the program reviewed by a third party. Additionally, comprehensive security programs should include robust data protection strategies such as database backup and recovery procedures to ensure business continuity and data integrity during security incidents. Second, you should definitely review if the company undergoes a third party penetration test or bug bounty program. Personally I am not a fan of bug bounties, but I am a fan of third party penetration testing on an annual basis. Pentesting provides you with a structured test of your defenses and real feedback on vulnerabilities. Finally, review the security documents (usually table of contents) the company utilizes as a basis for implementation. This includes (but certainly is not limited to) a security policy, incident response and vulnerability management. An experienced security team will offer to share those documents and artifacts as a part of normal business.

I make it a matter of course to evaluate every vendor and partner from the perspective of access to company data. Meaning if the partner or vendor manages company data, they’re subject to more scrutiny than a vendor that does not. Keep in mind the business purpose when evaluating a security program. I review the business purpose and type of information involved, then evaluate from that perspective, rather than handle all partners and vendors the same. When in doubt, always ask for more information.

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