Cloud service continuity and recovery

The cloud service continuity and recovery requirement expects you to prove your cloud-delivered services can be restored within defined time and data loss limits, even during major outages. To operationalize it fast, set measurable recovery objectives, map dependencies, implement backup and failover controls, and run documented recovery tests with evidence that restoration works 1.

Key takeaways:

  • Define and approve service-specific recovery objectives (RTO/RPO) and align them to business impact and contractual commitments.
  • Engineer recoverability into your cloud architecture (backups, replication, runbooks, access) and validate it through realistic tests.
  • Keep audit-ready evidence: test plans/results, restoration logs, dependency maps, and third-party attestations.

“Cloud service continuity and recovery” is a requirement you pass or fail on evidence. Auditors and customers do not want a promise that “the cloud is resilient.” They want proof that your specific workloads can survive provider incidents, misconfigurations, ransomware, accidental deletion, and region failures, and that you can restore service and data within your stated objectives.

ISO/IEC 27017 is guidance for information security controls in cloud services 1. The implementation intent captured for this requirement is simple: maintain continuity capabilities for cloud-delivered services 1. In practice, that means you must (1) set recovery targets, (2) build technical and operational recovery capability across people/process/technology, and (3) test it and retain evidence.

This page is written for a Compliance Officer, CCO, or GRC lead who needs to turn the cloud service continuity and recovery requirement into an actionable control set quickly. It focuses on what to do, what to save, what auditors ask, and what commonly breaks during incidents.

Regulatory text

Provided excerpt (summary record): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” The requirement summary is: “Maintain continuity capabilities for cloud-delivered services.” 1

Operator interpretation: You must be able to continue or restore cloud services after disruption, and you must be able to demonstrate that capability with documented design and test evidence 1. “Continuity” includes both technology (backups, replication, infrastructure capacity) and operations (runbooks, access, roles, communications).

Plain-English interpretation (what the auditor is really testing)

Auditors typically look for three things:

  1. Clarity: You defined what “recovered” means for each important service (availability restored, data restored, integrity validated).
  2. Capability: Your cloud architecture and operations can achieve those outcomes under plausible failure scenarios.
  3. Proof: You tested recovery and can show results, gaps, and remediation.

Who it applies to

ISO/IEC 27017 continuity expectations apply across cloud ecosystems, so scope it by role 1:

Cloud customer (you consume cloud services)

Applies when your organization runs workloads in IaaS/PaaS/SaaS and must assure continuity for:

  • Customer-facing applications (e-commerce, mobile, APIs)
  • Core business systems (ERP, finance, HR)
  • Security-critical platforms (identity, SIEM, key management)
  • Regulated or contractual workloads (customer data processing)

Operational context: You may not control the cloud provider’s underlying infrastructure, but you still own continuity of your service to your customers. Your controls focus on workload design, configuration, backup strategy, and third-party obligations (SLAs, support, notification, data export).

Cloud provider (you deliver cloud services)

Applies when you provide cloud services to customers and must assure continuity of:

  • The service platform and management plane (where applicable)
  • Customer data protection and recoverability features
  • Service operations (support, incident response, change control)

Operational context: Customers will ask for evidence of recovery testing, separation of duties, and resilience measures that match your commitments.

What you actually need to do (step-by-step)

Use this sequence to stand up an audit-ready program fast.

1) Set scope and tier services by criticality

  • Build a service inventory of cloud-delivered services (including shared services like DNS, IAM, CI/CD, logging).
  • Assign service tiers (e.g., Critical / High / Moderate / Low) based on business impact.
  • Record service owners (technical) and risk owners (business).

Output: Service continuity scope register.

2) Define recovery objectives (RTO/RPO) and minimum service levels

  • For each Critical/High service, define:
    • RTO (maximum acceptable downtime)
    • RPO (maximum acceptable data loss window)
    • Minimum service mode (degraded operations that are acceptable during recovery)
  • Obtain written approval from business owners. If the business refuses to set objectives, document the decision and the risk acceptance.

Common hangup: Teams claim “the provider handles DR.” For IaaS/PaaS, provider availability does not equal application recoverability. You still need workload-level RTO/RPO.

3) Map dependencies and failure modes

Create a dependency map that includes:

  • Cloud regions/zones used per service
  • Data stores, queues, object storage, secrets, and KMS dependencies
  • Identity dependencies (SSO, MFA, break-glass paths)
  • Third parties (CDN, email/SMS, payment processors)
  • Build/deploy pipeline dependencies

Then define failure scenarios you will test against, such as:

  • Region impairment
  • Accidental deletion or corruption
  • Ransomware-style encryption of data stores
  • Misconfiguration causing outage
  • Loss of privileged access credentials

Output: Dependency map + scenario list tied to each service tier.

4) Implement continuity architecture and operational controls

Choose patterns that match the service tier and objectives:

  • Backups: Automated backups for databases and critical configuration; immutable or logically protected where feasible.
  • Replication: Cross-zone or cross-region replication for critical data stores where required.
  • Infrastructure as Code (IaC): Rebuild capability from source-controlled templates.
  • Golden images and configuration baselines: Reduce restore variance.
  • Runbooks: Step-by-step restore procedures with decision points (failover vs restore vs rebuild).
  • Access: Break-glass accounts, tested MFA, and secure credential storage for recovery operations.
  • Monitoring: Signals that show recovery progress (restore completion, error rates, integrity checks).

Control design note: The evidence burden drops dramatically if your recovery steps are automated and logged. Manual DR can pass audits, but it is harder to prove and easier to fail under stress.

5) Contract and third-party alignment (customers and providers)

Continuity breaks at the boundary between you and your cloud provider or critical third parties. For in-scope services:

  • Capture provider commitments (availability, support response, incident notification, data export, termination assistance).
  • Ensure your internal RTO/RPO assumptions do not exceed what the provider can support.
  • Document shared responsibility assumptions for each service model (IaaS/PaaS/SaaS).

Practical move: Maintain a one-page “continuity responsibility matrix” per critical service: what the provider covers, what you cover, and what is jointly coordinated.

6) Test recovery scenarios and retain restoration evidence

This is the recommended control in your record: test cloud recovery scenarios and retain evidence of restoration readiness 1.

A test program that passes audits usually includes:

  • Test plan: scope, objectives, roles, prerequisites, rollback steps.
  • Execution evidence: tickets, logs, screenshots, change records, and timing notes.
  • Results: whether objectives were met, gaps found, corrective actions assigned, and retest evidence.

Keep tests realistic. If you only test restoring a small dev database, you have not proven recovery of production-scale services.

7) Close gaps and track remediation to completion

  • Log findings as issues with owners and target dates.
  • Prioritize gaps that prevent recovery (missing backups, untested runbooks, broken access paths).
  • Retest after remediation and attach evidence.

Required evidence and artifacts to retain

Keep these in a system of record (GRC tool, ticketing system, or controlled repository):

Governance

  • Continuity/DR policy and standard operating procedures
  • Service inventory and tiering methodology
  • Approved RTO/RPO per service (business sign-off)

Design and build

  • Architecture diagrams showing resilience patterns (zones/regions, replication)
  • Backup configurations and schedules (exported settings where possible)
  • IaC repositories or release artifacts supporting rebuild
  • Runbooks/playbooks for failover and restore

Operational proof

  • Recovery test plans and completed test reports
  • Restoration logs and screenshots (where appropriate)
  • Incident postmortems that include recovery lessons
  • Change records showing fixes applied after test failures

Third-party documentation

  • Cloud provider continuity-related commitments and support terms
  • Relevant attestations you receive from providers (as applicable to your program)

Common exam/audit questions and hangups

Expect these questions and prepare mapped evidence:

  1. “Show me your RTO/RPO for this service, and who approved it.”
    Hangup: objectives exist informally in engineering notes, not formally approved.

  2. “Prove you can restore production data and application functionality.”
    Hangup: backup exists, but no restoration test, or test excluded key dependencies.

  3. “What happens if your primary cloud region is unavailable?”
    Hangup: multi-region is assumed, but DNS, certificates, secrets, or IAM were not included.

  4. “Can you recover if privileged access is lost or compromised?”
    Hangup: break-glass access exists but is not tested, or recovery requires a human who is unavailable.

  5. “How do third parties affect your recovery timeline?”
    Hangup: the plan ignores dependencies like payment processors, messaging, or SaaS identity.

Frequent implementation mistakes (and how to avoid them)

Mistake Why it fails Avoid it by
Treating provider availability as application DR Your app may still be down or data may be unrecoverable Document shared responsibility per service model; test workload recovery
Backups exist but restores are untested Backups can be incomplete, corrupted, or inaccessible Schedule scenario-based restore tests; capture logs and results
RTO/RPO are copied from templates Targets are not achievable or not business-aligned Run a lightweight BIA workshop and get written approvals
Runbooks are outdated Recovery steps fail during an incident Tie runbook review to change management; update after every major architecture change
Dependency blind spots Recovery fails due to missing IAM/DNS/secrets/certs Maintain dependency maps; include these components in test scope
Evidence is scattered You “did the work” but cannot prove it Standardize artifact storage and naming; link evidence to controls in your GRC system

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Treat the risk as practical and contractual: continuity failures become security incidents, customer harm, SLA breaches, and audit findings. The most common compliance failure mode is not the absence of tools; it is insufficient implementation evidence for cloud service continuity and recovery 1.

A practical 30/60/90-day execution plan

First 30 days (stabilize scope and targets)

  • Build the service inventory and tiering for cloud-delivered services.
  • Define RTO/RPO for Critical/High services and obtain business sign-off.
  • Identify top dependencies and select initial recovery scenarios per service.
  • Pick an evidence repository and a standard test report template.

Days 31–60 (build and document recoverability)

  • Confirm backup coverage for in-scope data stores and critical configurations.
  • Write or update runbooks for restore/failover, including IAM break-glass steps.
  • Align third-party terms and escalation paths with continuity objectives.
  • Implement logging/monitoring signals that can show restore completion and integrity checks.

Days 61–90 (test, remediate, prove)

  • Execute recovery tests for the top-tier services using the defined scenarios 1.
  • Produce test reports with outcomes, artifacts, and corrective actions.
  • Remediate high-risk failures and retest where necessary.
  • Build an auditor packet per critical service: objectives, architecture, runbooks, and latest test evidence.

Where Daydream fits naturally: If you struggle with evidence sprawl, Daydream can act as the control-to-evidence system of record. Map each critical service to its continuity controls, attach test artifacts, and keep a current “ready-for-audit” view without chasing screenshots across chat threads.

Frequently Asked Questions

Do we need multi-region for every cloud workload to meet the cloud service continuity and recovery requirement?

No. You need continuity capabilities that meet your approved RTO/RPO for each service 1. For some services, tested backups and a rebuild runbook may satisfy objectives without multi-region failover.

What evidence is most persuasive to an auditor?

A completed recovery test report with attached logs, tickets, and restoration validation steps is hard to dispute 1. Pair it with RTO/RPO approvals and a dependency-aware runbook.

How do we handle SaaS applications where we can’t run our own backups?

Document what the SaaS provider supports (exports, retention, restore processes) and what you control (configuration backups, user access, business continuity workarounds). Test what you can test, such as restoring configurations or executing data export and re-import steps.

What should a recovery test validate beyond “the service is up”?

Validate data integrity, access controls, and critical business transactions. A service that loads but cannot process orders, authenticate users, or reconcile data is not meaningfully recovered.

How often should we test recovery?

Test on a risk basis: more often for Critical services and after major architecture changes. Set an internal standard, document it, and follow it with retained evidence 1.

Our engineers say runbooks slow them down. What’s the minimum viable runbook?

A usable runbook has prerequisites, step order, decision points, required access, and validation checks. If a new engineer cannot follow it during an incident, it is not a runbook; it is tribal knowledge.

Related compliance topics

Footnotes

  1. ISO/IEC 27017 overview

Frequently Asked Questions

Do we need multi-region for every cloud workload to meet the cloud service continuity and recovery requirement?

No. You need continuity capabilities that meet your approved RTO/RPO for each service (Source: ISO/IEC 27017 overview). For some services, tested backups and a rebuild runbook may satisfy objectives without multi-region failover.

What evidence is most persuasive to an auditor?

A completed recovery test report with attached logs, tickets, and restoration validation steps is hard to dispute (Source: ISO/IEC 27017 overview). Pair it with RTO/RPO approvals and a dependency-aware runbook.

How do we handle SaaS applications where we can’t run our own backups?

Document what the SaaS provider supports (exports, retention, restore processes) and what you control (configuration backups, user access, business continuity workarounds). Test what you can test, such as restoring configurations or executing data export and re-import steps.

What should a recovery test validate beyond “the service is up”?

Validate data integrity, access controls, and critical business transactions. A service that loads but cannot process orders, authenticate users, or reconcile data is not meaningfully recovered.

How often should we test recovery?

Test on a risk basis: more often for Critical services and after major architecture changes. Set an internal standard, document it, and follow it with retained evidence (Source: ISO/IEC 27017 overview).

Our engineers say runbooks slow them down. What’s the minimum viable runbook?

A usable runbook has prerequisites, step order, decision points, required access, and validation checks. If a new engineer cannot follow it during an incident, it is not a runbook; it is tribal knowledge.

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