The term Data Custodian, is being used with different meaning by different folks. In general the Cloud Customer ( the consumer of Cloud services ) is the data owner in all types IaaS, PaaS, SaaS. They are responsible for the data. The Cloud provider is the Data Custodian. In this question the Data Custodian seems to refer to the Data Owners, the Cloud Customer!.
I think you are seeing in the wrong perspective this. Data Owner is the main person responsible and who utilizes the information. And Data Custodian is the one which gives maintenance, administration, and set controls over the data. In this case, the custodian would never be the cloud vendor.
For example: for employees data, the Owner is HR, the Custodian is the security team or IT, and the cloud vendor acts as processor/subprocessor.
Data custodians are typically expected to have detailed knowledge of the systems that store and process their data—this includes how the data is hosted, secured, and maintained. In a PaaS or SaaS model, however, much of the underlying infrastructure, configuration, and even some application components are completely opaque to the customer.
Knowledge of systems
Explanation:
In a cloud environment, particularly with PaaS or SaaS, the underlying infrastructure and systems are managed by the cloud provider. This makes it difficult for data custodians to gain detailed knowledge of the systems hosting their data. They are often abstracted from the hardware, software configurations, and other operational details, which complicates tasks such as:
Assessing security risks.
Verifying compliance.
Understanding system-specific behaviors.
This abstraction layer poses a challenge for custodians to fully understand and manage the environment compared to traditional on-premises systems.
C. Access to data is made more challenging by a cloud implementation, especially with PaaS or SaaS. In these scenarios, the cloud provider typically manages access to data and data storage, which can make it more difficult for data custodians to control who has access to the data and how it is used.
A data custodian or data processor processes the data on behalf of the data
owner. The data custodian is responsible for adhering to the data owner’s
established requirements for using and securing the data, and must process
the data in accordance with the data owner’s established purposes.
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