Disclaimer. The
views, assessments, and observations presented in this article are provided
strictly for educational and analytical purposes, based on publicly available
information and professional expertise. Defthon is not affiliated with, funded
by, or acting on behalf of M-TIBA, any of its partners, competitors, government
agencies, or any other stakeholder mentioned or implied.
This analysis is vendor-neutral and non-partisan. It does not
seek to assign blame, validate unverified claims, or reach definitive conclusions
while official investigations are ongoing. All references to entities, systems,
or potential impacts are intended solely to support high-level risk awareness,
resilience building, and the advancement of cybersecurity best practices.
Still referring to the case of M-TIBA, the platform likely
operates on a hybrid infrastructure with services distributed across multiple
environments, including different cloud providers with diverse underlying
technologies, as well as several third-party integrations. This level of
complexity introduces a wide range of risks, and as a result, defining and
managing security responsibilities becomes significantly more challenging.
Shared responsibility in Cloud Computing
In an Infrastructure as a Service (IaaS) model, the cloud provider (CSP) is responsible for securing the core infrastructure, while the customer(CSC) must safeguard everything they deploy on it. For Platform as a Service (PaaS), responsibility is shared; the provider secures the platform itself, and the customer handles how they configure and secure their applications on that platform. In a Software as a Service ( SaaS) model, the provider manages the majority of security controls, and the customer’s primary role is to oversee user access, permissions, and application-level entitlements.
It is crucial to note that the involvement of cloud brokers or other intermediaries can further blur responsibility boundaries. For example, let us assume that M-TIBA uses a service like Cloudflare as an additional security for DDoS protection. While Cloudflare enhances security, it also introduces another stakeholder in the ecosystem.
In such situations, it
becomes essential to clearly define each party’s obligations at a detailed
level. Best practice in Cloud security recommends that:
- The Cloud Customer should develop a detailed
responsibility matrix for every cloud deployment, ensuring it aligns with
relevant compliance requirements.
- Cloud service providers (CSP)
should thoroughly outline the security measures they offer.
Shared Responsibility Example (M-Tiba Case)
Using M-Tiba as our case
study, security responsibilities will spread across different parties as
illustrated below:
A. M-Tiba as a Service
(SaaS):
In this case, M-Tiba
customers/users e.g patients and healthcare centers will be responsible
for protecting their data in the platform, configuring security controls such
as 2FA, managing their profile just to name a few. On the other hand, M-TIBA
will be responsible for securing the application itself, which includes
protecting backend systems, enforcing strong API and data-governance controls,
managing encryption, monitoring for fraud or abuse, and ensuring compliance
with healthcare and financial regulations such as HIPAA and PCI-DSS where
applicable. M-TIBA will also be required to maintain secure integrations with
cloud providers, telcos, and third-party partners, while continually monitoring
configurations, access, and platform-wide risks.
B. Cloud service providers
(E.g AWS /Azure /Safaricom Cloud)
Referring the best
practice recommendation by CSA, the specific responsibilities of the CSP
will depend on the cloud service model M-TIBA subscribes to:
- In an Infrastructure-as-a-Service (IaaS) model,
the CSP will secure the infrastructure while M-TIBA will manage the
operating system, applications, data, and configurations.
- in a Platform-as-a-Service
(PaaS) model, the CSP will also secure the platform environment, while
M-TIBA will focus on securing their applications, data, and API
configurations.
The Risk: Assumed Security
A major cloud-security
failure point arises when parties assume that another stakeholder has
implemented a specific control, when in reality:
- No one has implemented it.
- It exists only partially.
- It exists but is misconfigured.
- Or it exists but no one is
monitoring it.
This leads to gaps such
as:
- Missing encryption
responsibilities (e.g., AWS handles storage encryption, but platform
owners must encrypt in-transit APIs).
- Undefined incident response
roles: who responds first when a breach is detected—cloud provider, telco,
or the platform operator?
- Data residency uncertainty:
cloud providers offer regions, but platform owners must enforce where PHI
and financial data actually sit.
- Undefined responsibilities for
log retention, audit trails, and fraud analytics.
- Weak API security when each
party assumes the other is validating or rate-limiting requests.
Why Shared Responsibility Breakdown is Critical
Organizations like
M-Tiba or any other related Fintech and Healthcare organizations carry
sensitive personally identifiable information (PII) , medical records, financial
information, and insurance data.
In such a sensitive environment:
- A single misconfigured S3
bucket can leak millions of records.
- A poorly secured telco
connection can allow SIM-swap-based fraud.
- An insecure integration layer
can be vulnerable to attacks.
When responsibility lines are not explicit and continually monitored, risks multiply across all integrated systems.
Call to Action for Organization using Similar Deployments
The Cloud Service Provider (CSP) hosting similar deployments can adopt these best practices to ensure a secure and compliant environment:
- Clear
responsibility matrices between M-TIBA (CSC), the CSP, and third-party
integrations.
- Compliance
with legal and regulatory frameworks such as ODPC, DPA 2019, GDPR, HIPAA, and PCI-DSS,
depending on jurisdiction and sector.
- Contractual
SLAs defining
incident response, data handling, and escalation procedures.
- Regular
joint security testing across
all integrations, including penetration testing and configuration reviews.
- End-to-end
visibility across
all connected platforms and systems.
- Risk
management to
identify, assess, and mitigate potential security threats proactively.
- Identity
and Access Management (IAM), including role-based access controls, least-privilege
enforcement, and periodic review of permissions.
- Data
encryption and key management, ensuring data is encrypted both in transit and at
rest, with secure management of encryption keys.
- Monitoring,
logging, and incident detection, with centralized audit trails for compliance and
forensic purposes.
- Backup
and disaster recovery testing, including automated backups and periodic recovery
drills.
- Security
awareness and training for
M-TIBA users, healthcare staff, and administrators to reduce human error
and phishing risks.
- API
security and integration controls, including authentication, validation, and
rate-limiting for all internal and third-party API calls.
- Patch
and vulnerability management, ensuring timely updates and regular vulnerability
scans for both infrastructure and applications.
- Third-party
risk management,
assessing the security posture of partners such as telcos, hospitals, and
payment providers.
- Compliance
reporting and auditing,
with tools to generate reports for internal governance and regulatory
audits.
Joke of the Day: After a life of cybercrime, how did the hacker get to heaven?
The password hadn’t been changed in 2000 years.
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