Cloud Compliance in Scotland – Why It Matters and How to Get It Right
Why Resilience Matters – Lessons from AWS
On 20 October 2025, a major outage at Amazon Web Services (AWS) disrupted operations for a wide range of organisations, including HMRC, the Financial Times, Netflix, Slack, and leading e-commerce platforms. The incident highlighted how deeply businesses depend on cloud infrastructure and why compliance alone isn’t enough – resilience matters too. Having a clear cyber incident response plan ensures your organisation can act quickly, protect data, and maintain trust if a cloud service disruption or security event occurs.
With Scottish organisations embracing cloud services at pace, compliance with data protection and cyber security standards isn’t optional – it’s critical for trust, resilience, and legal certainty. Cloud compliance refers to meeting legal and industry standards, such as the UK GDPR, the Data Protection Act 2018, and Cyber Essentials, as outlined in the Scottish Government Cloud Framework.(Scottish Government Cloud Framework).
At Lugo, we see this as a partnership – cloud providers secure the infrastructure, but your organisation must manage access, configurations, and sensitive data. We help bridge that gap.
Cloud compliance involves:
- Protecting data at rest and in transit
- Maintaining robust access controls
- Conducting regular assessments and audits
- Managing cloud applications and their configurations
It’s important to remember that compliance is a shared responsibility. Cloud providers secure the infrastructure, but your organisation must manage access, configurations, and sensitive data. Knowing where your data is stored, how it flows, and who can access it is critical – especially given Scotland’s emphasis on data sovereignty and public trust (Scottish Government Data Protection Policy).
Public trust and compliance with Scottish Government frameworks are increasingly scrutinised, especially for regulated sectors like accountancy, housing, and charities.
The Rise of Cloud and Compliance Challenges in Scotland
Cloud solutions offer flexibility, scalability, and cost savings, but they also introduce new compliance challenges. Scottish organisations must navigate UK-wide regulations (GDPR, Data Protection Act 2018) and sector-specific requirements, such as those for public bodies and charities (Cyber Scotland).
Key challenges include:
- Data residency and sovereignty (ensuring data stays within the UK or EEA)
- Managing vulnerabilities and updates in cloud applications
- Ensuring every login to cloud apps is unique to the individual (no shared admin accounts)
- Keeping track of who uses which cloud services and whether they’re still needed
Cyber Essentials: The Scottish Standard for Cloud Compliance
Cyber Essentials is a government-backed scheme promoted by the Scottish Government, NCSC, and IASME. It sets out the minimum recommended steps to protect your organisation from common cyber threats (Cyber and Fraud Centre Scotland).
Why is Cyber Essentials important for Scottish organisations?
- It’s recognised as the baseline standard for cyber security in Scotland
- Certification demonstrates your commitment to protecting data and building trust
- Scottish SMEs can access voucher schemes to help cover certification costs (Law Society of Scotland)
Cloud applications are often the hardest part to manage for Cyber Essentials compliance:
- You must list all cloud apps in your asset register, including who uses them, their purpose, and whether multi-factor authentication (MFA) is enabled
- Every login to a cloud app should be unique to the individual – shared admin accounts or generic logins are non-compliant
- You need to consider how cloud apps are configured, updated, and whether they’re still necessary for your business (IASME Knowledge Hub)
What Is a Cloud Application?
A cloud application is any web-based service your organisation subscribes to and controls access for – examples include Microsoft 365, Google Workspace, Salesforce, Dropbox, and sector-specific portals.
Why is cloud education important?
- Cloud apps are updated by vendors, but you must ensure updates are applied and vulnerabilities are managed
- You need visibility into who uses each app, whether it’s still needed, and how it’s configured
- Cloud apps must be included in your asset register and compliance scope
Asset Management and Cloud Apps
Effective asset management is foundational for compliance. You must maintain an accurate asset register that includes:
- All devices (laptops, mobiles, servers, firewalls)
- All software (including cloud apps and mobile apps)
- Who uses each asset, its purpose, and its update status
- For cloud apps: who has access, whether MFA is enabled, and if the app is still required
Technical Controls for Cloud Compliance
1. Firewalls
- All devices must be protected by correctly configured firewalls
- Change default admin passwords and restrict remote access
- Document all firewall rules and business cases for open ports
2. Secure Configuration
- Remove unnecessary accounts and software
- Change default passwords
- Disable auto-run features and enforce device locking
3. Security Update Management
- Enable automatic updates for all devices and software
- Remove unsupported software
- Apply critical updates within 14 days
4. User Access Control
- Every user must have unique credentials for cloud apps
- MFA is mandatory for all cloud services
- Admin accounts must be separate from standard user accounts
- Document processes for adding/removing users and granting admin rights
5. Malware Protection
- Install and configure anti-malware software on all devices
- Only allow approved, code-signed applications
- Maintain an approved software list for all devices and cloud apps
What Makes Cloud Apps Hard to Manage for Compliance?
- Updates and Vulnerabilities: Cloud apps update frequently, but you must ensure all users are on the latest version and that vulnerabilities are patched promptly
- User Management: Shared logins or admin accounts are non-compliant. Every user must have a unique login, and MFA must be enabled wherever possible (MFA apps would be our recommendation)
- Configuration: Misconfigured cloud apps can expose sensitive data. Regular reviews and audits are essential
- Asset Tracking: It’s easy to lose track of who uses which cloud app and whether it’s still needed. Regular asset reviews help maintain compliance
Best Practices for Maintaining Cloud Compliance
- Regular Audits: Identify and address compliance gaps
- Robust Access Controls: Use least privilege and MFA for all cloud apps
- Data Encryption: Encrypt data at rest and in transit
- Continuous Monitoring: Use audit logs and real-time alerts
- Employee Training: Educate team on safe cloud practices and compliance requirements
- Asset Register: Keep an up-to-date list of all devices, software, and cloud apps
Frequently Asked Questions
What is cloud compliance?
Meeting legal and regulatory standards for data protection when using cloud services.
Who is responsible for cloud compliance?
Both the cloud provider and the customer share responsibility.
How can I ensure my cloud provider is compliant?
Check for certifications (ISO 27001, Cyber Essentials), review data handling policies, and ensure encryption and audit capabilities.
How do I manage cloud app compliance for Cyber Essentials?
List all cloud apps in your asset register, ensure unique logins and MFA, and regularly review usage and configuration.
How Lugo Can Help Scottish Organisations
At Lugo, we specialise in helping Scottish organisations achieve Cyber Essentials certification and strengthen their cloud compliance strategy. Our experts can guide you through the complexities of cloud regulations, asset management, and technical controls. We offer practical advice, hands-on support, and tailored solutions to help you reduce risk and stay compliant.
