Understanding Sensitive Data Management in SaaS Solutions

By Phil Varghese, Partner Solutions Architect – AWS

In today’s digital landscape, many Software-as-a-Service (SaaS) solutions manage sensitive data, particularly during the AWS Foundational Technical Review (FTR). This review is essential as it helps AWS Partners identify and mitigate risks, especially when handling Personally Identifiable Information (PII) and Protected Health Information (PHI).

The Nature of Sensitive Data

Sensitive data is not a one-size-fits-all concept; definitions of PII and PHI can greatly vary with local laws and regulations. At the core, PII includes information that can pinpoint an individual’s identity, such as names, social security numbers, and even biometric data. On the other hand, PHI refers to health-related information that can be tied to a specific individual.

When SaaS solutions undergo an FTR, it’s crucial to understand how PII is integrated into the software. This can often relate to user credentials or personal details collected through the service. Furthermore, if any health-related data is stored, even if the solution is not in the healthcare domain, PHI regulations—including HIPAA in the U.S.—will apply.

For instance, when AWS partners implement software authentication and utilize services like Amazon RDS or Amazon S3 for storing PII, they must adhere to strict data protection measures to ensure compliance and security.

Importance of Data Classification

One of the first steps in addressing sensitive data risks is implementing a robust data classification system. This system serves as a guide for identifying and documenting sensitive data within applications. For example, a specific Amazon RDS table containing user credentials may be classified as "Sensitive," while an S3 bucket with generic images could be labeled as "Public."

This classification not only helps in understanding what data requires stringent protection but also serves as a roadmap for implementing data security protocols. Utilizing labels such as "Sensitive," "Confidential," and "Public," as recommended by the Center for Internet Security, can enhance data management strategies.

AWS Partners can utilize tools like Amazon Macie and AWS Glue to automate the discovery and remediation of sensitive data. Amazon Macie, for instance, employs machine learning to identify and protect sensitive data stored in S3, while AWS Glue can detect PII during data processing, ensuring compliance and security.

Strategies for Protecting Data at Rest

Having identified sensitive data, the next step is to ensure its safety, particularly data at rest. A key requirement under the FTR is encrypting all sensitive data. This significantly mitigates risks associated with data breaches. AWS services such as Amazon EBS, Amazon S3, and various databases offer built-in encryption solutions facilitated by AWS Key Management Service (KMS).

For instance, Amazon S3 utilizes server-side encryption (SSE) to encrypt objects stored at rest, thus securing critical information. Similarly, whether utilizing AWS KMS-managed keys or creating custom encryption keys, it is vital to incorporate regular key rotation to enhance security further.

Using Amazon Cognito for user authentication can also simplify security protocols, as it automatically encrypts user credentials, thereby minimizing the likelihood of data exposure.

Safeguarding Data in Transit

In addition to protecting data at rest, ensuring the security of data in transit is equally important. The FTR mandates the use of encrypted communication protocols when transmitting sensitive data outside a Virtual Private Cloud (VPC). This typically involves implementing HTTPS or SSL/TLS encryption.

AWS provides various services that support secure data transmission, including Elastic Load Balancers, Amazon CloudFront, and API Gateway. Tools like AWS Certificate Manager simplify the process of managing digital certificates necessary for secure communication, ensuring that sensitive data travels securely across networks.

Navigating PHI Regulations and HIPAA Compliance

For partners dealing with PHI, such as those offering services to U.S. customers, it is imperative to have a Business Associate Addendum (BAA) established with AWS for any accounts handling PHI. Additionally, leveraging HIPAA-eligible AWS services is crucial for compliance when storing and processing PHI, ensuring that your operational practices meet federal regulations.

AWS provides detailed guidelines on maintaining HIPAA compliance, enabling partners to navigate PHI management effectively during their FTR evaluations.

Best Practices for Logging and Monitoring

While not a formal requirement for the FTR, implementing comprehensive logging across your architecture can reinforce security. Establishing a dedicated logging solution helps trace activities related to PII and PHI, enhancing your ability to respond to any potential data breaches or incidents effectively.

This examination highlights the critical aspects of managing sensitive data within SaaS solutions. By implementing strong data classification, protection protocols for both data at rest and in transit, and ensuring compliance with applicable regulations, AWS Partners can significantly bolster their security posture and foster greater trust with their clientele. For more specific instructions on enabling encryption and data protection features, partners can refer to the corresponding product documentation provided by AWS.