Supporting compliance requirements · Topic 1 of 2

Shared Responsibility, Compliance Scope and Control Mapping

Apply the shared responsibility model on Google Cloud, set the compliance scope, find technical needs and map regulations to Google Cloud controls.

  • 5 min
In a nutshell
  • Google secures the infrastructure; you always own identity, access, configuration and data.
  • IaaS leaves the OS to you; PaaS moves the runtime to Google.
  • Use only services in scope for the certification, and sign a BAA for HIPAA.

What it is

Moving to Google Cloud does not move compliance to Google. Google certifies its infrastructure and services, and you remain responsible for how you configure and use them. The engineer's job is to know which part is whose, which systems a regulation covers, and which Google Cloud controls meet each requirement.

RegulationPCI DSS, HIPAA, FedRAMPScopewhich projects and dataShared responsibilityGoogle or youControlsIAM, network, keys, logsEvidenceaudit logs, reports

How it works

The shared responsibility model

LayerIaaS (Compute Engine)PaaS (Cloud Run, App Engine)SaaS (Google Workspace)
Physical data centers, hardware, global networkGoogleGoogleGoogle
Hypervisor and host OSGoogleGoogleGoogle
Guest OS, patching, runtimeYouGoogleGoogle
Application codeYouYouGoogle
Network configuration, firewall rulesYouMostly youGoogle
Identity, access and IAMYouYouYou
Data classification, encryption key choicesYouYouYou

The more managed the service, the more Google handles, but identity, access and data are always yours. Google describes its approach as shared fate: it also provides secure defaults, blueprints and guidance to help you meet your share.

Evidence from Google

ResourceUse
Compliance Reports ManagerDownload Google's third-party audit reports and certificates, such as ISO/IEC 27001, SOC 2 and PCI DSS attestations
Services in scope listsCheck that every service you use is covered by the certification you rely on
Business Associate Agreement (BAA)Required before storing protected health information under HIPAA; use only covered services
Exam tip

A service being available in Google Cloud does not mean it is in scope for a given certification. The exam often hides a non-covered service in an otherwise correct answer.

Determining technical needs

AreaTypical regulatory needsGoogle Cloud features
ComputeHardened, patched systems; sometimes dedicated hardwareGolden images, VM Manager patching, Shielded VM, Confidential VM, sole-tenant nodes
DataClassification, encryption, key control, minimisationSensitive Data Protection, CMEK, Cloud HSM, Cloud EKM, tokenization
NetworkSegmentation, encrypted transmission, restricted internet exposureSeparate VPCs, firewall policies, VPC Service Controls, TLS, HA VPN, MACsec
StorageLocation, retention, immutability, deletionResource locations policy, retention policies, Bucket Lock, lifecycle rules

Determining the environment in scope

The scope is every system that stores, processes or transmits regulated data, plus the systems that can affect their security. Shared services such as identity, CI/CD and logging often fall in scope because they connect to regulated workloads.

Reduce scope deliberately:

  • Put regulated workloads in a dedicated folder, projects and VPC network.
  • Draw a VPC Service Controls perimeter around them.
  • Tokenize data such as card numbers with Sensitive Data Protection so downstream systems never hold the real values.
  • Restrict who can administer the regulated folder.

A smaller scope means fewer systems to audit and fewer controls to prove.

Mapping requirements to controls

Requirement (paraphrased)Google Cloud control
Restrict access to data by business needIAM groups and least-privilege roles, PAM for elevated access, VPC Service Controls
Segment regulated systems from othersSeparate projects and VPCs, hierarchical firewall policies, no peering to untrusted networks
Log and review all access to regulated dataData Access audit logs, aggregated sinks, alerts, Log Analytics
Keep audit logs for a set period and protect themLocked log buckets or Cloud Storage with Bucket Lock, separate logging project
Encrypt stored data and control keysCMEK, Cloud HSM or Cloud EKM, with key rotation
Encrypt data over public networksTLS with SSL policies, HA VPN, MACsec
Keep data in a country or regiongcp.resourceLocations, Assured Workloads
Manage vulnerabilitiesArtifact Analysis, VM Manager, Security Health Analytics
Continuously show complianceSecurity Command Center Premium compliance reports and security posture

PCI DSS, for example, requires audit log history of at least one year, with the last three months immediately available. That maps to a locked log bucket or archive with matching retention.

A worked example

A retailer must meet PCI DSS for online payments. The engineer limits scope by placing the payment service in its own folder, project and VPC, inside a perimeter, and tokenizing card numbers with Sensitive Data Protection so the analytics platform never sees real numbers.

Every control is mapped in a matrix: IAM groups and PAM for access, Data Access logs into a locked bucket for one year, CMEK on storage, and SCC Premium PCI DSS reports for continuous evidence. Google's PCI DSS attestation from Compliance Reports Manager covers the infrastructure layer.

Payment serviceown folder and VPCTokenize cardsSDPAnalyticsout of scopeControl matrixEvidencelogs, SCC reports, Google attestation

How the exam asks about this

  • "Who is responsible for patching the operating system of Compute Engine VMs?" The customer, because Compute Engine is IaaS.
  • "Reduce the number of systems in PCI DSS scope while analysts still analyze purchases." Tokenize card data with Sensitive Data Protection and isolate the payment environment.
  • "An auditor asks for evidence that Google's data centers meet ISO 27001." Download the report from Compliance Reports Manager.

What to remember for the exam

  • Google secures the infrastructure; you always own identity, access, configuration and data.
  • IaaS leaves the OS to you; PaaS moves the runtime to Google.
  • Use only services in scope for the certification, and sign a BAA for HIPAA.
  • Shrink scope with isolation and tokenization before mapping controls.
  • Map each requirement to a specific control and to the evidence that proves it.
Watch out

Google's certifications cover Google's part only. A certified platform with a public bucket or an open firewall still fails your audit.

Common mistakes

Assuming a managed service makes you compliant. Managed services shift infrastructure work, not your duty to set access, keys and logging correctly.

Leaving shared services out of scope. CI/CD, identity and logging systems that touch regulated workloads can change them, so assess them too.

Mapping requirements to products, not evidence. Auditors need proof the control works, such as logs and reports, not just a product name.

Check yourself

  • Under the shared responsibility model, which layer is always the customer's?

    Identity and access management, configuration of services, and the data itself, whatever the service model.

  • How can tokenization reduce PCI DSS scope?

    Downstream systems store tokens instead of card numbers, so they no longer handle cardholder data.

  • Where do you obtain Google's third-party audit reports?

    From Compliance Reports Manager.

Topic 1 of 2 in Supporting compliance requirements

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