Cloud Risk Assessments in AWS SaaS Environments
Why You Should Combine ISO 27001 & Cloud Controls Matrix (CCM)
As more organizations build and scale SaaS applications on cloud platforms like AWS, the complexity of managing information security and regulatory compliance increases exponentially.
Many teams start with ISO/IEC 27001, the globally accepted standard for building information security management systems (ISMS). But in cloud-native environments, especially multi-tenant SaaS models on AWS, ISO 27001 alone may not cover the cloud-specific risks, controls, and service-layer responsibilities that are essential to building trust and securing data.
To bridge that gap, organizations are increasingly adopting the Cloud Controls Matrix (CCM) developed by the Cloud Security Alliance (CSA).
This blog post dives deep into how ISO 27001 and CCM complement each other, how to apply both in AWS-based SaaS environments, and how to build a comprehensive, contextual risk assessment approach that maps to both frameworks effectively.
📚 Quick Framework Overview
🔐 ISO/IEC 27001
Focus: Risk-based information security management (ISMS)
Applicability: Organization-wide, including processes, people, and technology
Control Reference: Annex A – 93 controls (2022 edition)
Certification: Yes (auditable)
☁️ Cloud Controls Matrix (CCM v4.0)
Focus: Cloud-specific security controls aligned with standards (ISO, NIST, SOC 2, etc.)
Applicability: CSPs and cloud consumers (shared responsibility)
Control Domains: 17 domains, 197 controls
Certification: No (used for STAR self-assessments and attestations)
⚠️ Why ISO 27001 Alone May Not Be Enough for AWS-Based SaaS
While ISO 27001 provides foundational structure and processes for risk identification, treatment, and monitoring, it lacks the granularity and technical depth required for securing dynamic, distributed, and shared infrastructure environments like AWS.
Examples of ISO 27001 Gaps in AWS SaaS:
🧩 Why Combine ISO 27001 with CCM?
Integrating both frameworks helps organizations:
Meet regulatory expectations (e.g., ISO certification + cloud control validation)
Bridge cloud-specific control gaps
Build an ISMS that reflects real-world cloud risks
Achieve continuous compliance in fast-moving cloud environments
💡 Think of ISO 27001 as the engine, and CCM as the GPS system specifically calibrated for the terrain of the cloud.
🛠️ How to Combine ISO 27001 & CCM in AWS SaaS Environments
Here’s a step-by-step approach tailored for SaaS providers operating in AWS:
✅ 1. Establish Scope of the ISMS (ISO 27001)
Define boundaries to include:
AWS-hosted infrastructure
Cloud-native services (e.g., Lambda, RDS, ECS, API Gateway)
SaaS application layers
Customer and internal admin interfaces
📌 Practical Tip: Include AWS shared responsibility model in your ISMS Statement of Applicability.
✅ 2. Conduct Baseline Risk Assessment (ISO 27001 Approach)
Use ISO 27001 methodology:
Identify threats (e.g., unauthorized access, misconfiguration, DoS)
Assess likelihood and impact
Determine risk treatment options (accept, mitigate, transfer, avoid)
📌 Example:
Risk: Misconfigured S3 bucket leads to data exposure
Likelihood: Medium
Impact: High
Treatment: Enforce encryption, use AWS Config rules, implement CI/CD pipeline checks
✅ 3. Overlay CCM for Cloud-Specific Control Mapping
Map ISO Annex A controls to relevant CCM domains. For example:
✅ 4. Use AWS Tools to Operationalize Controls
Map CCM technical control implementations to AWS native services:
📌 Example Implementation:
CCM Control EKM-03 – Secure Key Storage
AWS KMS key policies enforce access control
Periodic key rotation enabled
CMK usage logs monitored via CloudTrail
✅ 5. Update the Risk Register with Combined Results
Maintain a risk register that tracks both ISO 27001-identified risks and CCM-aligned cloud-specific risks, including:
Risk description
Asset affected (e.g., Lambda, EC2, user data)
Associated CCM & ISO controls
Risk owner
Mitigation plan
Residual risk
✅ 6. Continuous Monitoring and Improvement
Leverage ISO 27001’s PDCA (Plan-Do-Check-Act) cycle to:
Regularly review AWS control effectiveness (e.g., using AWS Security Hub findings)
Update CCM control mappings based on service usage
Track remediation of control gaps from AWS Well-Architected Tool or pen tests
Review compliance posture quarterly (tie into SOC 2 or HIPAA if applicable)
📊 Example Scenario: Multi-Tenant SaaS App on AWS
Use Case: You operate a multi-tenant SaaS app using AWS services like ECS, RDS, and Cognito.
Risk: A single tenant gains unauthorized access to another tenant’s data.
Risk Treatment (Combined Framework Approach):
📈 Final Thoughts: Better Together
When managing a SaaS business in AWS, relying solely on ISO 27001 gives you the structure—but not the specificity—to defend against the unique, fast-evolving threats in cloud environments.
Combining ISO 27001 and CCM delivers:
✅ Strategic alignment with global standards
✅ Tactical coverage of cloud-native services and configurations
✅ Measurable, auditable controls for customers and auditors
✅ End-to-end visibility across your security and compliance posture
If you’re running or building a SaaS product in the cloud, don’t treat ISO 27001 and CCM as either/or—they’re stronger together.
📚 References
Cloud Security Alliance Cloud Controls Matrix (CCM): https://cloudsecurityalliance.org/research/cloud-controls-matrix/
ISO/IEC 27001:2022 Standard: https://www.iso.org/standard/27001
AWS Security Documentation: https://docs.aws.amazon.com/security/
CSA STAR Program: https://cloudsecurityalliance.org/star/
AWS Well-Architected Framework – Security Pillar: https://docs.aws.amazon.com/wellarchitected/latest/security-pillar/
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