By
Jeff Erlichman
Managed Services providers are working hard to take their
services to higher level.
Federal managers are pretty uncomfortable when their data resides
outside their installation and outside of their firewall.
After all, in a Managed Services environment, data will be in motion
and at rest outside of the firewall. It doesn’t matter if it
is in a single vendor’s data center or in a secure segment of
a public or private cloud.
Then, consider this. Much of your organization’s records are
not electronic. They are paper.
“I challenge any federal agency that’s very
concerned about who is managing their content, to go and look at what
they are doing with their paper physical records,” declared
Dan Carmel, CEO of SpringCM in a recent interview with 1105 Government
Information Group Custom Media. SpringCM is a Content Management
platform service provider.
Carmel said they are packing it up in boxes and shipping out to a third
party vendor. “Maybe it’s somebody called Iron
Mountain, maybe it’s somebody called Pitney Bowes. They are
shipping it out to a third party vendor who is managing it in a
physical warehouse side by side, co-mingled with the physical content
of every other organization’s stuff. Plus there is no backup
to the warehouse.”
Agencies have chosen to do this for years so “let’s
get away from I’m uncomfortable with content residing outside
my firewall,” said Carmel. “It is outside your
firewall right now.”
Trusted Content Keepers
The key issue in considering Managed Services is not
where the content resides, because your content already resides outside
your firewall; really the question is, what is the standard?
Is it managed by staff or contractors who may not be well trained, who
do not understand the value of the content and may not be effectively
securing the content? Or is the content managed in a secure facility
that’s like a bank data center where each employee considers
themselves to be the steward of the content? Further, the content is
backed up and managed rigorously. That’s the difference said
Carmel.
“The issue is how is your content being managed? For that,
most Managed Service providers and people who operate in the cloud like
us can produce documents and certifications,” Carmel
explained. “We spend a fair amount of money every year to
have our operational procedures documented. It’s been
developed with an auditing firm and it’s a written document
the audit firm signs off on.”
Carmel explained his company undergoes a physical audit to ensure that
it is complying with the operating procedures that they provide. The
company’s operations manual is available to anyone who wants
to look at it to measure or to compare with their own operating
standards.
SAS 70
For managed services providers such as Carmel, the key
standard – the “Good Housekeeping Seal of
Approval” – is called SAS 70.
“SAS stands for Statement of Accounting Standards and SAS 70
is the regulation under which companies like ours submit themselves to
a rigid documentation of operating procedures and parameters
first,” explained Carmel.
When considering a Managed Service it is
critical to think about: What is the standard by which the content is
going to be managed? How, with what assurances and what standards of
care?
SAS 70 Level 1 requires a manual to be produced which actually
specifies here is the ‘how’ your content is being
managed said Carmel.
“Everything from the facility, physical security, facility
access to software upgrades, quality control; anything the organization
deems important as a control variable is documented in this policy. So
the ‘how’ is documented. That’s available
for inspection and that is SAS 70 Level 1.”
Carmel said SpringCM is now in the midst of Level 2 audit, which is a
physical audit of those operating procedures so that our public
accounting service can say they have audited the company records and
found them to be in compliance with the standard.
“That’s the one-two punch that solidifies that for
anybody considering a Managed Service,” said Carmel.
“I think that is important that organizations understand that
and for lack of anything better is becoming the Good Housekeeping seal
for software service offerings in a cloud.”