However, recent studies have shown that organizations frequently get enamored by the hot technology of the day (such as VOIP or SOA) and begin to deploy virtualization before the complexities and impact to security and compliance are well understood.
Significant challenges to IT compliance are introduced when you consider the mappings of policy, guidance and the resulting controls that now have to be considered through the layers of virtualization.
Here are five challenging aspects of IT compliance when dealing with virtualization:
- Discovery and inventory: You can't measure what you can't see (or for that matter, don't even know exists). Determining which virtual machines (VMs) are active, which are abandoned or dormant and what data they are accessing is a fundamental part of defining your scope of compliance and applying the appropriate IT controls. Perhaps of a greater concern is how organizations cope with unapproved or rogue VMs.
- Chain of custody: Can you provide an audit trail for critical VMs as they move from development to testing to production? Are only approved changes occurring and are they made by the appropriate personnel? Due to the dynamic and mobile nature of virtualization, keeping track of where the VMs are, who touched them and what changed is key for audit documentation and a true lifesaver in incident response scenarios.
- Separation of critical assets (especially in a hosted environment): How do you know that customer A VMs are properly segregated from customer B VMs? Are low risk, non-critical VMs being hosted on the same box as high risk, mission critical VMs? Add features like VMotion and DRS in plus some modern storage solutions and there is good chance that things are not so cleanly separated. Having the ability to make VMs aware of their risk profile and location is going to be critical as more organizations adopt virtualization.
- Software license violations: Push-button provisioning has become a huge contributor to virtual sprawl and major corporate licensing violations. This one seems simple but take the case of a software development shop. The vendor tools make it quick and easy to build a server for coding or testing purposes but then you can clone it, copy it and move it and before long there are numerous copies of the OS, applications and development tools floating around. Software inventory and metering will have to learn some new tricks in the context of products like VMware's Lab Manager.
- Subject Matter Expertise (SME): Virtualization is being rolled out faster than IT audit staff is being trained. IT compliance and audit professionals have just not had the training and time they need to appropriately understand the role virtualization plays in regulatory compliance. This is an area that can be solved but it will take effort from the vendor community working alongside organizations like ISACA, ISSA, IIA and SANS.