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Runbook 01 β€” Cloud Compliance Assessment & Evidence Collection

Item Details
Runbook 01 β€” Cloud Compliance Assessment & Evidence Collection
Module Cloud Compliance & ISO Cloud Standards
Difficulty Advanced
Primary Role Cloud GRC Analyst / Cloud Compliance Analyst
Supporting Roles Cloud Security, IAM, SOC, Platform Engineering, Privacy, Legal, Procurement, Internal Audit
Applicable Environments IaaS, PaaS, SaaS, Multi-Cloud
Primary Standards ISO/IEC 27001, ISO/IEC 27017, ISO/IEC 27018
Primary Output Cloud Compliance Assessment & Evidence Package
Runbook Type Cloud Assurance / Control Testing

This runbook provides a reusable procedure for performing periodic or event-driven cloud compliance assessments.

The process covers:

Assessment Trigger
↓
Scope Definition
↓
Cloud Inventory Validation
↓
Shared Responsibility Review
↓
Provider Assurance Review
↓
Evidence Collection
↓
Evidence Validation
↓
Control Testing
↓
Finding Identification
↓
Risk Impact
↓
Root Cause Analysis
↓
Remediation
↓
Retesting
↓
Management Reporting

The objective is to determine whether cloud controls are:

  • Appropriately designed.

  • Implemented.

  • Operating consistently.

  • Supported by reliable evidence.

  • Aligned with provider/customer responsibility.

  • Connected to enterprise risk.

  • Ready for internal or external assurance.

At the end of the process, the assessment team should be able to answer:

What cloud environments are in scope?
Who owns them?
Which data do they process?
Which controls apply?
Who operates each control?
Which controls are inherited?
What provider evidence supports them?
What customer evidence exists?
Which controls failed?
What risk do those failures create?
Who will remediate them?
Were corrective actions independently validated?

Run this procedure when any of the following occurs:

Scheduled Cloud Compliance Review
ISO Internal Audit
Certification Readiness Review
Major Cloud Migration
New Critical Cloud Provider
Major Cloud Architecture Change
Security Incident
Regulatory / Contractual Change
Material Provider Change
High-Risk Cloud Finding

Create an assessment record.

Include:

Assessment ID
Trigger
Requestor
Date
Lead Assessor
Target Completion

Example:

Assessment ID:
CCA-2026-03
Trigger:
Annual Cloud Compliance Review

Example:

Determine whether in-scope cloud governance, security, privacy, and compliance controls are appropriately implemented and operating across production cloud environments.

Typical participants include:

GRC
Cloud Engineering
Cloud Security
IAM
SOC
Data Owners
Privacy
Legal
Procurement
Internal Audit

The lead coordinates:

  • Scope.

  • Evidence requests.

  • Testing.

  • Findings.

  • Reporting.

  • Remediation tracking.

Document:

AWS
Azure
Google Cloud
Critical SaaS Providers
Private Cloud

where applicable.

Include:

AWS Accounts
Azure Subscriptions
GCP Projects
SaaS Tenants
Cloud Regions
Production Workloads

Examples:

Compute
Object Storage
Managed Database
Identity
Logging
Kubernetes
Serverless
SaaS Applications

Document relevant classifications:

Public
Internal
Confidential
Restricted
PII
Payment Data

Example:

01 January 2026
through
30 June 2026

Point-in-time evidence may not be sufficient for controls expected to operate throughout the period.

Possible criteria include:

ISO/IEC 27001
ISO/IEC 27017
ISO/IEC 27018
Cloud Security Policy
Cloud Configuration Standard
IAM Standard
Logging Standard
Data Residency Requirements
Backup & Recovery Standard
Provider Contracts

Request:

Cloud Account Inventory
SaaS Inventory
Provider Inventory
Application Inventory
Data Inventory

Useful sources include:

Cloud Organizations
SSO Applications
Procurement
Expense Records
CSPM
CASB
DNS / Network Discovery

Use:

Known
Unknown
Duplicate
Inactive
Unowned

For every environment confirm:

Business Owner
Technical Owner
Security Owner

Confirm classifications such as:

Critical
High
Moderate
Low

Check whether system metadata aligns with actual data.

Example:

One active SaaS service processing customer information is absent from the approved Cloud Service Inventory.

Create a finding candidate if material.

Request provider/customer responsibility documentation for critical services.

Use:

Provider
Customer
Shared
Inherited

Step 20 β€” Validate Service-Specific Responsibility

Section titled β€œStep 20 β€” Validate Service-Specific Responsibility”

Do not assume responsibility is the same for every service from the same provider.

Example:

Virtual Machine
β‰ 
Managed Database
β‰ 
SaaS

Example:

Control:
Logging
Provider:
Generates audit-event capability

Example:

Customer:
Enables logging
Centralizes logs
Defines retention
Monitors events

Every customer and shared responsibility should have an internal owner.

Avoid:

Owner:
Cloud Provider + Customer

Instead:

Internal Owner:
SOC Manager

Example:

Provider provides backup capability
Customer assumes backup includes recovery testing
No recovery test exists

Document the gap.

Use provider tiering or service criticality.

Examples:

ISO Certificates
SOC Reports
ISO/IEC 27017 Assurance
ISO/IEC 27018 Assurance
Security Documentation
Resilience Information

Use:

Current
Approaching Expiry
Stale
Unavailable

Verify:

Provider Entity
Service
Region
Period
Control Scope

Inspect:

Audit Exceptions
Qualified Conclusions
Control Failures
Subservice Organizations

For each provider exception ask:

Does it affect our service?
Which inherited control?
Which risk?
Do we need treatment?

Provider reports may state requirements such as:

Enable Logging
Manage Users
Review Access
Protect Credentials
Configure Backups

Map these to customer controls.

Use:

Request Evidence Owner Due Status

Examples:

Cloud Inventory
Responsibility Matrix
Cloud Control Framework
Approved Region Register
Exception Register

Examples:

Privileged User Inventory
MFA Coverage
Access Review Records
Service Account Inventory
Break-Glass Accounts

Examples:

CSPM Reports
Cloud Policy Reports
Resource Inventory
Public Exposure Report
Security Baseline Report

Examples:

Log Source Inventory
SIEM Coverage
Retention Configuration
Detection Rules
Logging Exceptions

Examples:

Encryption Coverage
Key Permissions
Key Rotation
Data Classification
Region Configuration

Examples:

Backup Status
Recovery Tests
DR Tests
Backup Exceptions

Examples:

Admin Users
MFA Status
External Users
Audit Logs
Integrations
Retention
Provider Assurance

Ask:

Does this evidence prove the control?

Check:

Correct accounts?
Correct systems?
Correct user population?

Ask:

Does it cover the assessment period?

Example:

Production Accounts:
50
Evidence:
48
Result:
Incomplete

Prefer evidence from authoritative systems.

Examples:

Cloud API
IAM Platform
SIEM
CSPM
GRC Workflow

A screenshot may support one sample.

It does not normally prove a large population.

Include:

Evidence ID
Source
Date
Scope
Owner
Control

Use:

Control Requirement Responsibility Population Test Result

Examples:

64 Privileged Users
150 Storage Resources
20 Critical Workloads
15 Production Accounts

Ask:

How was the population generated?
Does it cover all in-scope systems?
Can anything bypass it?

Use:

Complete Population
Risk-Based Sampling
Random Sampling
Judgmental Sampling

Cloud APIs often make full-population testing practical.

Procedure:

Identify privileged users
↓
Validate MFA
↓
Identify failures
↓
Review exceptions

Pass condition:

100% privileged identities
meet approved authentication requirement

Identify local accounts bypassing enterprise identity.

Ask:

Approved?
Business need?
Least privilege?
Temporary where required?

Review:

Population
Reviewer
Frequency
Decisions
Removal Actions

Verify:

Restricted Use
Secure Credentials
Monitoring
Periodic Testing

Review:

Service Accounts
Managed Identities
Static Keys
Credential Age
Privilege

Examples:

Administrative Logs
Authentication Logs
Network Logs
Data Access Logs

Example:

Production Accounts:
50
Integrated:
48

Record uncovered environments.

Compare actual retention with standard.

Ask:

Who can delete logs?
Who can change retention?
Are changes logged?

Sample events:

New Administrator
Logging Disabled
Public Storage
Suspicious Login

Trace:

Event
β†’ Alert
β†’ Investigation
β†’ Closure

Evaluate:

Storage
Databases
Administrative Interfaces
Security Groups
SaaS Sharing

A public resource may be legitimate.

Confirm:

Business Need
Approval
Risk
Controls

Look for:

SSH
RDP
Database Management
Administrative APIs

open to unrestricted sources.

Review:

Approved Image
Patching
EDR
Host Firewall
Logging

Determine whether the organization detects changes from approved baseline.

Assess:

Coverage
Rules
Enforcement
Exceptions
Change Management

Examples:

Databases
Object Storage
Disks
Backups

Compare against classification-based requirements.

Identify:

Provider-Managed
Customer-Managed
Externally Managed

Check:

Administrators
Applications
Key Usage
Logging
Access Review

Broad key access can undermine encryption controls.

Use:

Data Inventory
Classification Register

Compare:

Actual Region
vs
Approved Region

Check backup and DR locations.

Include:

Analytics
AI Services
Support Platforms
Integrations

Check:

Approval
Purpose
Current Need
Security Controls

Validate relevant provider/subprocessor locations.

Determine whether support-access locations are relevant to applicable requirements.

For every critical workload verify:

Backup Enabled
Frequency
Retention
Encryption

Check whether failed jobs are detected and remediated.

Remember:

Backup Success
β‰ 
Recoverability

Review actual restore tests.

Example:

Required:
Quarterly
Actual:
No test in 12 months

Potential finding.

Compare actual results against:

RTO
RPO

where defined.

Include systems processing:

PII
Customer Data
Source Code
Identity
Financial Data

Validate:

Admin List
MFA
Ownership
Access Review

Review inactive or unnecessary external accounts.

Check:

Anonymous Links
External Sharing
Public Objects

Inventory:

OAuth Applications
API Tokens
Connected Apps

Confirm ownership and need.

Determine whether audit logs are:

Available
Enabled
Exported
Retained
Reviewed

Apply the same provider-assurance procedure.

Every finding should include:

Requirement
Condition
Evidence
Risk

Avoid:

Cloud security is weak.

Prefer:

Three production cloud accounts were not forwarding required administrative audit logs to the enterprise SIEM during the assessment period.

Use approved methodology.

Possible levels:

Critical
High
Medium
Low

Confirm factual accuracy.

Do not allow valid issues to disappear through wording negotiation.

Example:

MFA Failure
↓
Privileged Account Compromise

If a matching risk exists:

Update it

If not:

Create / Escalate

according to risk methodology.

Control failure may increase residual risk.

Map affected:

ISO Controls
ISO 27017 Guidance
ISO 27018 Controls
Customer Contracts
Internal Standards

Example:

Issue:
Logging missing

Correction:

Enable logging

Root cause may be:

Account provisioning
does not deploy logging baseline

Ask:

Why did it happen?
Why was it not prevented?
Why was it not detected?

Avoid:

Human error
Forgot
Mistake

unless backed by deeper process analysis.

Fix immediate condition.

Address systemic cause.

Use a person/role with authority to remediate.

Base on:

Severity
Risk
Dependencies
Implementation Effort

Examples:

Configuration Export
Updated Workflow
Policy-as-Code Rule
Completed Recovery Test
Current Provider Report

Use:

Finding Action Owner Target Status
Open
Planned
In Progress
Blocked
Ready for Retest
Closed

Escalation should be risk based.

Example:

High Finding
↓
CISO / Risk Owner

Avoid:

Owner says fixed
↓
Closed

Use same or improved test procedure.

Step 113 β€” Validate Full Population Where Appropriate

Section titled β€œStep 113 β€” Validate Full Population Where Appropriate”

Example:

Original:
3 / 50 accounts missing logs
Retest:
50 / 50 integrated

Also test:

New account provisioning
automatically enables logging

Use:

Effective
Partially Effective
Ineffective
Pass
β†’ Close
Fail
β†’ Reopen

Add missing services and owners.

Clarify unclear responsibility.

Where control design changes.

If applicable control status changed.

Reflect changed residual risk.

Add remediation where needed.

Capture accepted deviations.

Include:

Assessment Scope
Overall Control Status
High Findings
Top Cloud Risks
Provider Issues
Remediation Priorities

Useful examples:

Cloud Inventory Coverage
Privileged MFA Coverage
Logging Coverage
Encryption Coverage
Approved Region Coverage
Recovery Test Coverage
Current Provider Assurance

Example:

Logging Coverage:
Q1 88%
Q2 94%
Q3 100%

Trends are often more useful than one-time percentages.

Examples:

Manual Account Provisioning
Fragmented IAM
Weak SaaS Governance
Incomplete Provider Assurance
Manual Recovery Scheduling

Examples:

MFA
Logging
Encryption
Region
Public Exposure
Backup Status

Example:

Public Exposure
β†’ Continuous
MFA
β†’ Daily
Provider Assurance
β†’ Annual

Document stale thresholds.

Where possible use:

Cloud API
↓
Evidence Collector
↓
Evidence Repository

Track:

Collection Failures
Missing Accounts
Stale Evidence
API Errors

Use:

Evidence ID Control Source Period Owner

Do not provide:

Passwords
Private Keys
Sensitive Customer Records

unless strictly required and appropriately controlled.

Example:

IAM-002/
β”œβ”€β”€ MFA-Coverage
β”œβ”€β”€ Exception-Register
└── Retest

Auditor should be able to follow:

Requirement
↓
Control
↓
Evidence
↓
Test
↓
Finding
↓
Remediation
  • Assessment trigger documented.

  • Objective defined.

  • Lead assigned.

  • Stakeholders identified.

  • Providers identified.

  • Accounts/subscriptions/projects identified.

  • SaaS included.

  • Data scoped.

  • Regions scoped.

  • Assessment period defined.

  • Criteria defined.

  • Inventory obtained.

  • Discovery comparison performed.

  • Unknown services identified.

  • Owners validated.

  • Data classifications reviewed.

  • Responsibility matrices reviewed.

  • Provider controls identified.

  • Customer controls identified.

  • Shared controls identified.

  • Inherited controls identified.

  • Internal owners validated.

  • Critical providers identified.

  • Current assurance collected.

  • Scope validated.

  • Exceptions reviewed.

  • Customer responsibilities mapped.

  • Evidence request list issued.

  • Evidence sources validated.

  • Period validated.

  • Scope validated.

  • Completeness validated.

  • Evidence metadata recorded.

  • Privileged population validated.

  • MFA tested.

  • Federation tested.

  • Access reviews tested.

  • Break-glass accounts tested.

  • Workload identities tested.

  • Required sources identified.

  • Coverage tested.

  • Retention validated.

  • Protection reviewed.

  • Detection tested.

  • Public exposure tested.

  • Administrative ports tested.

  • Secure baseline tested.

  • Drift monitoring assessed.

  • Policy-as-code reviewed.

  • Encryption tested.

  • Key model reviewed.

  • Key access reviewed.

  • Restricted datasets identified.

  • Primary locations validated.

  • Backup locations validated.

  • Transfers assessed.

  • Subprocessors considered.

  • Support access considered.

  • Backup coverage tested.

  • Backup failures reviewed.

  • Recovery testing validated.

  • RTO/RPO considered.

  • SaaS admins tested.

  • MFA tested.

  • Guest users reviewed.

  • Sharing reviewed.

  • Integrations reviewed.

  • SaaS logging reviewed.

  • Provider assurance reviewed.

  • Requirement identified.

  • Condition documented.

  • Evidence recorded.

  • Risk defined.

  • Severity assigned.

  • Owner assigned.

  • Correction defined.

  • Root cause identified.

  • Corrective action defined.

  • Target assigned.

  • Closure evidence defined.

  • Retest planned.

  • Retesting completed.

  • Findings closed or reopened.

  • Risk updated.

  • SoA updated where required.

  • Control library updated.

  • Management report issued.

Cloud-Compliance-Assessment/
β”‚
β”œβ”€β”€ 01-Scope/
β”‚ β”œβ”€β”€ Assessment-Plan
β”‚ └── Stakeholders
β”‚
β”œβ”€β”€ 02-Inventory/
β”‚ β”œβ”€β”€ Cloud-Inventory
β”‚ └── SaaS-Inventory
β”‚
β”œβ”€β”€ 03-Responsibility/
β”‚ └── Shared-Responsibility-Matrix
β”‚
β”œβ”€β”€ 04-Provider-Assurance/
β”‚ β”œβ”€β”€ Certifications
β”‚ β”œβ”€β”€ SOC-Reports
β”‚ └── Provider-Reviews
β”‚
β”œβ”€β”€ 05-Evidence/
β”‚ β”œβ”€β”€ IAM
β”‚ β”œβ”€β”€ Logging
β”‚ β”œβ”€β”€ Configuration
β”‚ β”œβ”€β”€ Encryption
β”‚ β”œβ”€β”€ Residency
β”‚ └── Recovery
β”‚
β”œβ”€β”€ 06-Testing/
β”‚ └── Control-Testing-Worksheets
β”‚
β”œβ”€β”€ 07-Findings/
β”‚ └── Findings-Register
β”‚
β”œβ”€β”€ 08-Remediation/
β”‚ └── Remediation-Tracker
β”‚
β”œβ”€β”€ 09-Retest/
β”‚ └── Retest-Evidence
β”‚
└── 10-Reporting/
└── Executive-Summary
Cloud Environment In Scope?
β”‚
β”œβ”€β”€ No β†’ Document Exclusion
β”‚
└── Yes
↓
Inventory Complete?
β”‚
β”œβ”€β”€ No β†’ Raise Governance Gap
β”‚
└── Yes
↓
Responsibility Defined?
β”‚
β”œβ”€β”€ No β†’ Clarify Provider/Customer Responsibility
β”‚
└── Yes
↓
Evidence Available?
β”‚
β”œβ”€β”€ No β†’ Evidence Gap
β”‚
└── Yes
↓
Evidence Complete & Current?
β”‚
β”œβ”€β”€ No β†’ Assurance Gap
β”‚
└── Yes
↓
Control Operating?
β”‚
β”œβ”€β”€ No β†’ Finding
β”‚
└── Yes
↓
Effective?
β”‚
β”œβ”€β”€ No β†’ Control Design Gap
β”‚
└── Yes β†’ Pass

For every evidence item ask:

Right Source?
Right Scope?
Right Period?
Complete Population?
Reliable?
Reproducible?
Current?
Protected?

Use:

[Requirement] requires [expected condition]. The assessment identified [actual condition] based on [evidence]. This may result in [risk/impact].

Example:

The Cloud Logging Standard requires centralized administrative logging for all production cloud accounts. The assessment identified two of fifteen production environments that were not fully forwarding administrative logs to the enterprise SIEM. This reduces CloudNova’s ability to detect and investigate unauthorized administrative activity.

Failure 1 β€” Starting With Evidence Requests Before Scope

Section titled β€œFailure 1 β€” Starting With Evidence Requests Before Scope”

Teams collect unnecessary information.

Unknown cloud services escape assessment.

The wrong party is asked for evidence.

Failure 4 β€” Provider Certificate Accepted Without Scope Review

Section titled β€œFailure 4 β€” Provider Certificate Accepted Without Scope Review”

Inherited controls may not actually be covered.

Failure 5 β€” Current Screenshot Used for Historical Control

Section titled β€œFailure 5 β€” Current Screenshot Used for Historical Control”

Operation throughout the assessment period is not demonstrated.

SaaS risk remains unmanaged.

Failure 7 β€” Configuration Scanning Replaces Control Testing

Section titled β€œFailure 7 β€” Configuration Scanning Replaces Control Testing”

Governance and operating effectiveness are missed.

They become opinions rather than audit observations.

Root cause remains.

Compliance and enterprise risk remain disconnected.

A weak assessment asks:

Is the checkbox green?

A stronger assessment asks:

Does the configuration meet the requirement?

A mature assessment asks:

Is the control well designed, operating across the complete population, supported by reliable evidence, aligned with shared responsibility, reducing the intended risk, and able to remain effective as the cloud environment changes?

That is the mindset required for meaningful cloud compliance assurance.

A completed assessment package should contain:

01 β€” Assessment Plan
02 β€” Validated Cloud Inventory
03 β€” Responsibility Matrix
04 β€” Provider Assurance Review
05 β€” Evidence Request Register
06 β€” Evidence Index
07 β€” IAM Assessment
08 β€” Logging Assessment
09 β€” Configuration Assessment
10 β€” Encryption Assessment
11 β€” Data Residency Assessment
12 β€” Backup & Recovery Assessment
13 β€” SaaS Assessment
14 β€” Control Testing Worksheets
15 β€” Findings Register
16 β€” Risk Impact Analysis
17 β€” Root Cause Records
18 β€” Remediation Tracker
19 β€” Retest Records
20 β€” Executive Summary

The assessment is complete when:

Scope is documented
Cloud inventory is validated
Responsibilities are understood
Provider assurance is current
Evidence is complete
Critical controls are tested
Findings are documented
Risk impact is assessed
Root causes are identified
Corrective actions are assigned
Retesting is completed or scheduled
Management receives the assessment result

You now have a repeatable enterprise workflow for moving from:

Cloud Environment

to:

Validated Inventory
↓
Responsibility Mapping
↓
Evidence
↓
Control Testing
↓
Findings
↓
Risk
↓
Remediation
↓
Retesting
↓
Management Assurance

This procedure can be reused for scheduled assessments, internal audits, ISO certification readiness, major cloud changes, provider reviews, and event-driven cloud compliance investigations.

➑️ Next: Runbook 02 β€” Cloud Compliance Exception, Remediation & Continuous Monitoring

In the next and final runbook for this module, you will operationalize what happens after a cloud control fails or an exception is requested.

You will build the lifecycle:

Control Violation
↓
Determine Immediate Risk
↓
Correct Immediate Exposure
↓
Exception or Remediation?
↓
Risk Assessment
↓
Compensating Controls
↓
Approval
↓
Corrective Action
↓
Continuous Monitoring
↓
Retest
↓
Close / Renew / Escalate

The runbook will connect cloud exceptions, risk acceptance, remediation, policy-as-code, continuous control monitoring, evidence freshness, and management escalation into one repeatable operating process.