This is a guest post from Michael Marrano, MS, CISSP, CISM, CISA, at Riskigy.
There is a widespread misunderstanding regarding cloud services, particularly in relation to Software as a Service (SaaS). Many organizations mistakenly believe that once they migrate to the cloud, the responsibility for all aspects of security and data protection rests solely with the SaaS provider. This misconception creates a false sense of security, which can be detrimental.
What is shared responsibility model?
The Shared Responsibility Model is a framework that explains how security and compliance responsibilities are divided between a cloud service provider (CSP) and its customers. It ensures clarity on who is accountable for which part of the infrastructure and data, reducing gaps in security and compliance.
In this model, the cloud provider is typically responsible for securing the underlying cloud infrastructure, this includes physical data centers, networking, storage, and virtualization layers. On the other hand, the customer is responsible for securing what they put in the cloud, such as applications, data, identity and access management, configurations, and user behavior.
For example, if you use a public cloud like AWS, Azure, or Google Cloud, the provider ensures the servers and networks are secure, but you must configure security groups, encrypt sensitive data, and manage user permissions. This model is important because misconfigured settings or weak controls on the customer side can lead to breaches even if the provider’s infrastructure is secure.
The truth is that the responsibility for maintaining a secure cloud environment is a shared endeavor between the organization and the cloud service provider (CSP). While the CSP does play a significant role in securing the underlying infrastructure and application, organizations must also actively participate in implementing critical security measures.
Read the “Cloud GRC best practices: 8 strategies for secure & compliant operations” article to learn more!
Understanding the shared responsibility model
The Shared Responsibility Model is a critical concept in cloud security and compliance, especially for organizations working in highly regulated industries. It defines the boundary of accountability between a cloud service provider (CSP) and its customers, ensuring both parties understand their specific roles in protecting data and systems. While the CSP maintains and secures the core cloud infrastructure, the customer is responsible for how that infrastructure is used.
This model helps organizations prevent security blind spots, meet compliance obligations, and reduce the risk of misconfigurations that could lead to breaches.
Key elements of the shared responsibility model include:
- Provider-managed infrastructure security
The CSP handles physical security, networking, storage, and virtualization layers. This includes securing data centers, patching hardware, and ensuring network resilience. - Customer-owned data and applications
Users are responsible for protecting the data, applications, and workloads they deploy, including encrypting information and managing access controls. - Configuration and identity management
The CSP provides tools, but customers must configure them correctly. This includes setting permissions, managing roles, and implementing multi-factor authentication. - Compliance alignment
While CSPs meet baseline certifications and regulatory standards, customers must ensure their usage complies with specific industry requirements like HIPAA, ISO 27001, or SOC 2. - Monitoring and incident response
The CSP ensures platform availability and basic monitoring, but customers must actively monitor their own environments, detect unusual activity, and respond to incidents. - Shared risk awareness
Both parties share responsibility for overall risk management. A strong understanding of the model ensures clear ownership and reduces the likelihood of overlooked vulnerabilities.
Failing to recognize this shared responsibility can result in critical security oversights, leaving the organization vulnerable to various risks and potential vulnerabilities. It is imperative for organizations to acknowledge and actively address their role in ensuring the security of their data and applications within the cloud environment.
The cloud SaaS shared responsibility model provides a framework to delineate security responsibilities between the cloud service provider and its customers. Within the SaaS model, administrators have reduced control over the software stack, granting the SaaS vendor the responsibility of securing the application and supporting infrastructure. Conversely, customers bear the obligation of managing their data and overseeing security permissions.
Lack of comprehensive comprehension regarding the allocation of security responsibilities between the CSP and the customer within organizations can lead to security gaps. These gaps emerge when the organization mistakenly assumes that the CSP is responsible for certain security aspects that actually fall under the customer’s purview.
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Learn MoreWhat’s the risk?
The concept of cloud supply chain risk encompasses the potential hazards and vulnerabilities that can jeopardize different elements within a CSP’s supply chain. These risks have the potential to impact the security, availability, and performance of the cloud services provided by the CSP.
Cloud service risks include
- Data breaches
Unauthorized access to customer data stored in the cloud can result in data breaches, causing financial losses, damage to reputation, and potential legal liabilities for both the CSP and customers. - Geopolitical risks
Political instability, trade restrictions, or economic sanctions can impact the availability or cost of resources required by the CSP, thereby influencing the quality or pricing of the cloud services. - Natural disasters and extreme weather events
Natural disasters have the potential to disrupt data centers, network infrastructure, or other crucial components of the CSP’s supply chain, leading to service outages or diminished performance. - Regulatory and compliance risks
Changes in regulations, such as data privacy laws or industry-specific requirements, can affect the CSP’s capability to offer compliant cloud services, potentially impacting customers’ operations. - Cybersecurity risks
Cyberattacks targeting the CSP or its supply chain can result in service disruptions, data breaches, or other security incidents that affect customers. - Software vulnerabilities
Exploiting vulnerabilities in the software used by the CSP can lead to security breaches or service disruptions.
To effectively address cloud supply chain risks, organizations should take the following measures:
- Conduct thorough vendor assessments
Prior to engaging in a contract, carefully evaluate the security and dependability of the CSP and its supply chain partners. - Implement robust access controls
Manage user access to cloud resources by implementing role-based access controls, and regularly review and update permissions. - Monitor and audit
Regularly monitor and audit your cloud environment to promptly identify and address any security issues or policy violations. - Diversify cloud providers
Consider utilizing multiple cloud providers to reduce reliance on a single vendor, thereby minimizing the potential impact of supply chain disruptions. - Develop a comprehensive security strategy
Establish a comprehensive security strategy that encompasses both your organization’s responsibilities and those of the CSP. This strategy should include incident response plans, data protection measures, and compliance requirements. - Maintain compliance
Understand the compliance requirements specific to your industry and ensure that both your organization and the CSP adhere to these standards.
What is cloud shared responsibility?
Cloud shared responsibility is a security and compliance framework that clearly defines which tasks are handled by the cloud service provider (CSP) and which remain the responsibility of the customer. It exists because moving to the cloud changes the traditional IT ownership model. While the CSP builds, manages, and secures the underlying infrastructure, customers are responsible for what they put on that infrastructure and how they use it.
Read the “Building operational resilience: How TrustCloud safeguards business continuity” article to learn more!
Understanding customer responsibilities
For organizations using cloud services, understanding customer responsibilities is a pivotal step towards secure IT operations. Customers need to focus on the following areas:
- Application configuration
Customers are responsible for setting up and managing application configurations, ensuring that every deployment conforms to security best practices such as encrypted data transmissions and secure API calls. - Identity and access management
It is critical to implement strict controls over user access. IT professionals should establish role-based access control (RBAC), enforce multi-factor authentication (MFA), and routinely review user permissions. - Data security
Maintaining data security involves encryption (both at rest and in transit), regular data backups, and efficient management of data privacy policies. Organizations must also be vigilant about data residency and compliance issues. - Application and service patch management
Regularly updating applications to mitigate vulnerabilities is essential. Customers are responsible for ensuring timely application of patches, security updates, and bug fixes. - Network security
Beyond physical and virtual protections provided by cloud vendors, customers should manage firewalls, configure virtual private networks (VPNs), and apply intrusion detection systems (IDS) at the application level.
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Defining provider responsibilities
Defining provider responsibilities in cloud computing is essential to understanding the shared responsibility model. Cloud service providers (CSPs) play a critical role in establishing and maintaining the secure foundation upon which all customer applications and services rely. Their responsibilities extend beyond mere uptime guarantees; they encompass physical, network, and platform-level controls that enable customers to operate confidently in the cloud.
From safeguarding sprawling data centers with redundant power supplies and advanced surveillance systems to securing hypervisors that isolate virtual workloads, CSPs ensure that the infrastructure itself remains resilient against threats. They also manage core services such as databases, storage, and serverless frameworks, embedding advanced security tools and monitoring features to protect against misuse or compromise.
- Physical Infrastructure Management
Cloud providers safeguard the physical backbone of cloud environments, including servers, networking hardware, and cooling systems. They invest in advanced data centers fortified with biometric access controls, CCTV monitoring, and redundant power supplies. This ensures uninterrupted services and secures customer data at the hardware level, preventing physical breaches, equipment failures, and environmental disruptions from impacting business operations. - Network and Hypervisor Security
The provider ensures secure and reliable network connectivity by protecting communication channels with encryption, monitoring for suspicious traffic, and mitigating Distributed Denial-of-Service (DDoS) attacks. Additionally, they manage hypervisors, the virtualization layer that hosts customer workloads, by patching vulnerabilities, enforcing workload isolation, and preventing cross-tenant attacks, thereby safeguarding sensitive information in shared computing environments. - Core Platform Services
CSPs deliver essential cloud offerings such as virtual machines, managed databases, serverless functions, and container orchestration. They continuously update, patch, and monitor these services to prevent exploitation. Providers integrate built-in security features like identity access management, logging, and automated monitoring to reduce risks, giving customers reliable, ready-to-use platforms without the complexity of managing underlying infrastructure. - Compliance Adherence
Top cloud providers undergo rigorous third-party audits and certifications to prove adherence to global regulatory frameworks. Certifications like ISO 27001, SOC 2, and GDPR compliance provide assurance of secure environments. By maintaining compliance, providers not only demonstrate trustworthiness but also reduce regulatory burdens for customers, enabling organizations to meet legal and industry-specific obligations without duplicating efforts. - Backup and Disaster Recovery Infrastructure
Providers implement resilience by distributing workloads and data across multiple geographically separated data centers. They offer built-in backup systems, replication mechanisms, and disaster recovery options to ensure business continuity in case of hardware failures, natural disasters, or cyberattacks. These redundancies provide customers with assurance that critical data and services remain available under all circumstances.
It is critical for IT professionals to understand that while providers handle these core areas, configuring and managing the services that run on top of these platforms remains a customer responsibility. This demarcation of responsibilities ensures that each party can focus on their domain, but it also underscores the need for both collaboration and clear communication.
Read the “How to build a unified control framework for multi-standard compliance” article to learn more!
Implications for compliance and risk management
Compliance has emerged as a top concern for organizations, particularly in sectors such as healthcare, finance, and government services. Understanding the shared responsibility model is key to maintaining compliance with data protection regulations such as GDPR, HIPAA, and PCI-DSS. The division into “of” and “in” the cloud helps organizations delineate accountability when auditing IT processes.
When preparing for audits, IT professionals should ensure that documentation and access logs cover all customer-controlled configurations and that any changes in infrastructure are communicated to and supported by up-to-date policies. This requires not just technical acumen but also a robust governance framework that aligns with internal policies and regulatory requirements.
The risk of misconfigurations or overlooked security policies can be mitigated through coordinated strategies that emphasize accountability. Companies must regularly assess their configurations, carry out penetration testing, and rarely provide employees with unchecked privileges. A well-documented audit trail supports risk management and gives assurance that both provider and customer obligations are met.
Read the “Modern risk management: Strategies to cut costs without compromising security” article to learn more!
How to manage cloud shared responsibility
Effectively managing the Shared Responsibility Model (SRM) necessitates a clear comprehension of the roles and obligations of each party involved, including the cloud service provider (CSP), users, and the organization.
Here are some recommendations to facilitate SRM management:
- Comprehend the division of responsibilities
Gain familiarity with the distinct responsibilities of each party based on the specific cloud service model utilized (IaaS, PaaS, or SaaS). This understanding will enable the identification and resolution of potential security gaps. - Select a reputable CSP
Choose a cloud service provider with a strong reputation for security and compliance. Ensure that the CSP’s security policies and procedures align with the organization’s requirements. - Establish transparent communication channels
Foster open lines of communication among the organization, CSP, and users to ensure awareness of respective responsibilities and any changes in the cloud environment. - Implement robust access controls
Effectively manage user access to cloud resources by implementing role-based access controls and regularly reviewing and updating permissions. - Educate users
Train users on security best practices, such as employing strong passwords, enabling multi-factor authentication, and recognizing and avoiding phishing attacks. Encourage users to promptly report any security concerns or incidents. - Monitor and audit
Conduct regular monitoring and auditing of the cloud environment to identify and address security issues or policy violations. Collaborate with the CSP to ensure access to appropriate tools and support for monitoring and auditing purposes. - Develop a comprehensive security strategy
Formulate a comprehensive security strategy that encompasses the responsibilities of both the organization and the CSP. This strategy should include incident response plans, data protection measures, and compliance requirements. - Maintain compliance
Understand the compliance obligations specific to the industry and ensure adherence to these standards by both the organization and the CSP. Regularly assess and update the organization’s compliance posture as necessary. - Review and update
Periodically review and update SRM policies and procedures to ensure their relevance and effectiveness in the face of evolving threats and evolving business needs. - Leverage CSP expertise
Take advantage of the expertise and resources offered by the CSP, such as documentation, best practices, and support services, to effectively manage the assigned responsibilities.
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Turning the shared responsibility model into a daily operating model
The shared responsibility model only works when it escapes slide decks and becomes part of how teams design, deploy, and monitor systems every day. Treating cloud security as a continuous, co-owned practice, rather than an abstract contract clause, creates fewer blind spots, clearer ownership, and a stronger foundation for trust assurance across your entire GRC program.
- Embed responsibilities into runbooks
Translate “customer vs. cloud provider” responsibilities into concrete steps inside incident response, change management, and deployment runbooks. This ensures that when something breaks, teams know exactly which playbook belongs to your org and which requires escalating to the CSP, avoiding confusion in the middle of an incident. - Tie shared responsibilities to controls
Map each responsibility (for example, identity, data encryption, configuration hardening) to specific technical and procedural controls in your GRC framework. When these controls are automatically tested and evidenced, you get real-time proof that your side of the shared responsibility model is actually being met. - Use SLAs and DPAs as living documents
Ensure SLAs and data processing agreements reflect the shared responsibility split for monitoring, backups, and incident notification. Revisit them when you adopt new cloud services or features, so legal language, operational expectations, and security architecture stay aligned, not frozen at contract signing. - Drive shared-responsibility awareness in onboarding
Include a simple, visually clear explanation of the shared responsibility model in onboarding for engineers, admins, and vendors. When teams understand what the CSP handles and what they own, they make better day-to-day decisions about access, logging, and configuration. - Integrate responsibilities into architecture reviews
Add “Who owns what?” as a mandatory section in design review templates. For every new workload, teams must document which layers (infrastructure, platform, app, data) are handled by the CSP versus internal teams and how those assumptions are validated. - Continuously monitor for responsibility drift
Use monitoring and auditing to detect when responsibility boundaries are changing, for example, when a new managed service shifts patching or logging obligations back to your team. Surfacing this “responsibility drift” early helps you avoid gaps that attackers and auditors will eventually discover.
When the shared responsibility model is woven into processes, templates, and tools, it becomes a practical operating model rather than a theoretical diagram, keeping cloud security resilient as architectures, providers, and regulations evolve.
Read the “Boost resilient security posture: Proven 10 steps for strong controls” article to learn more!
Overcoming challenges in shared responsibility model implementation
Adopting the shared responsibility model can transform cloud security posture, but the path isn’t always smooth. Many organizations underestimate how much work still falls on their side once workloads move to the cloud. Skills, alignment, and visibility gaps can slow progress or introduce new risks. When teams don’t understand their obligations, cloud providers become a default fallback, but not always a safe one.
As multi-cloud deployments grow and regulations tighten, clarity becomes crucial. The right mix of training, tooling, and governance turns shared responsibility into a powerful accelerant for secure cloud operations, rather than a confusing framework to navigate.
1. Limited internal cloud expertise
A lack of cloud-native security knowledge often causes misconfigurations or incomplete control implementation. Investing in certifications, hands-on labs, and role-based training strengthens internal capability and ensures customer-side tasks—like identity management or workload protection—are handled correctly and consistently.
2. Lack of visibility into cloud environments
Without proper observability tools, blind spots emerge across workloads, networks, and storage layers. Improving visibility through unified dashboards, centralized logging, and continuous monitoring helps teams detect threats earlier and respond confidently.
3. Over-reliance on cloud providers
While cloud platforms deliver robust foundational security, they are not responsible for everything. Assuming they cover more than they do leads to compliance gaps. Understanding provider documentation and aligning responsibilities with frameworks prevents false assumptions and strengthens assurance.
4. Complexity across multiple cloud tools
Multi-cloud tooling brings flexibility but often introduces fragmented operations. Integrating platforms through automation, shared policy engines, and single-pane governance ensures consistency across environments and reduces operational confusion.
5. Undefined roles and responsibilities
Ambiguous accountability creates overlapping efforts or missed tasks. Establishing clear RACI assignments, updating governance models, and aligning documentation with real workflows ensures duties are transparent and measurable, especially during audits.
6. Lack of continuous training and updated documentation
Cloud platforms evolve rapidly, and static policies become outdated fast. Regular refreshers, scenario-based learning, and maintained runbooks help teams stay aligned with current best practices and reinforce shared responsibility as an ongoing discipline, not a one-time configuration.
When organizations address these challenges proactively, the shared responsibility model becomes an advantage rather than an obligation. Teams gain confidence in their roles, providers have clearer boundaries, and governance becomes repeatable and scalable. Most importantly, security shifts from assumption to collaboration, creating a stronger foundation for resilient cloud operations.
How can TrustCloud help with implementing a shared responsibility model for your organization?
Organizations adopting cloud platforms often assume full responsibility for security once infrastructure moves off-premises. TrustCloud clears up that confusion. By providing real-time visibility into controls, continuous evidence gathering, and compliance automation, it fills critical gaps in the shared responsibility model.
Whether you’re responsible for data, configurations, or identity, and your cloud provider covers the rest, TrustCloud ensures you’re not left guessing. It streamlines risk monitoring, surfaces control status across IaaS, PaaS, and SaaS layers, and delivers clarity in how obligations are divided and managed.
Summing it up
The shared responsibility model serves as a flexible framework that enables organizations to establish proper data security measures. It delineates the shared responsibilities among the cloud service provider, users, and the organization. Instead of solely relying on the CSP for security, the SRM outlines the specific actions that organizations are accountable for and those that should be managed by other parties. By adhering to these guidelines, organizations can effectively manage the Shared Responsibility Model and create a secure and compliant cloud environment. Proactive management of cloud supply chain risks allows organizations to minimize potential disruptions and uphold the security and performance of their cloud services. By adopting a proactive approach to cloud security and comprehending the shared responsibilities, organizations can avoid falling into a false sense of security and maintain a robust and compliant cloud environment.Guest Blog Spotlight
Thank you to Michael Marrano, MS, CISSP, CISM, CISA, for his valuable contribution to our guest blog. His expertise and insights have greatly enriched our Trust Community, providing our readers with valuable knowledge in cybersecurity. Michael is an information security expert, practitioner, writer, speaker, and the founder of Riskigy. With an extensive list of degrees, certifications and over 25 years in technology and cybersecurity, Michael specializes in technology and cybersecurity strategy development and fractional CISO and CIO leadership engagements to help organizations, investors and service providers enhance cybersecurity compliance. Learn more about Riskigy at www.riskigy.com and connect with Michael on LinkedIn. www.linkedin.com/in/michaelmarranoFAQs
What is the shared responsibility model, and why is it important?
The shared responsibility model is a foundational principle in cloud computing that outlines how security and compliance duties are divided between the Cloud Service Provider (CSP) and the customer. The provider typically secures the infrastructure, data centers, networking, and hypervisors, while you’re responsible for everything you deploy on the platform: your applications, data, configurations, and access controls.
This clarity prevents dangerous overlaps or, worse, security gaps. Understanding this model ensures you know what the provider handles and where accountability begins and ends. It’s indispensable for cloud migration, compliance audits, and maintaining a secure posture in dynamic environments.
What are best practices for managing your end of the shared responsibility model?
To remain secure and compliant as your infrastructure scales, follow these best practices:
- Understand Your Cloud Usage Model: Responsibilities differ depending on whether you’re using IaaS, PaaS, or SaaS. The deeper your reliance on managed services, the less you manage, but that doesn’t eliminate your obligations.
- Secure Configurations Proactively: Set up controls like network segmentation, encryption, and MFA from day one. Tools like Infrastructure-as-Code help enforce consistency.
- Monitor Continuously: Deploy logging, alerts, and dashboards to track changes and suspicious activity in real time. Visibility is your best tool.
- Practice Incident Response: A simulation or tabletop exercise helps validate that your tools, teams, and processes can handle real threats.
- Align with Compliance Requirements: Even if the CSP is compliant, your use of their services must align with standards like HIPAA or ISO 27001. Document this alignment and maintain audit-ready evidence.
How do responsibilities change across different cloud service models (IaaS, PaaS, SaaS)?
Responsibilities under the Shared Responsibility Model shift based on the service model:
- IaaS (Infrastructure as a Service): Customers manage operating systems, applications, data, and network configurations. The provider handles the infrastructure.
- PaaS (Platform as a Service): The provider manages more of the computing platform, so customers focus on their custom code, data processes, and configuration.
- SaaS (Software as a Service): Most of the stack, from infrastructure to application, is managed by the provider. Customers typically configure settings, manage access, and take responsibility for the data and usage policies.
As organizations move from IaaS to SaaS, their burden lightens, but each model still demands clear ownership for secure deployment and GRC alignment.
Why do shared responsibility mistakes remain so common?
Despite the model being clear in principle, real-world misalignment is common:
- Assumption errors: Many users assume CSPs handle everything, including data encryption or user access, even when that’s not the case.
- Tool overload: When different teams use different cloud services, overlapping tools and dashboards create confusion.
- Lack of automation: Manual rollout of resources often bypasses security checks, leading to drift over time.
- Insufficient visibility: Teams may not have a single view across environments, on-prem or multi-cloud, which impedes clear accountability.
A clear operating model and cultural reinforcement are key to closing these gaps.
What are the key challenges organizations face with the shared responsibility model?
Organizations often face challenges due to misunderstandings or assumptions about their security responsibilities under the shared responsibility model. One common issue is the tendency to presume that the cloud provider covers all security aspects, leading to gaps in securing data, applications, and endpoints. Another challenge is the complexity of managing security in multi-cloud or hybrid-cloud environments where responsibilities differ across platforms.
Additionally, the proliferation of cloud-native tools and rapid deployment cycles can create difficulties in enforcing consistent security controls. To mitigate these challenges, organizations must develop clear policies, conduct regular training, and implement monitoring and auditing to ensure all responsibilities are met effectively.
