Understanding the division of security responsibilities between the agency and cloud service providers makes it easier for CIOs to safely move their data to the cloud.
It’s been seven years since the Office of Management and Budget mandated that federal agencies adopt a cloud-first policy, yet it’s no surprise this major change is still a work in progress. While the cloud brings benefits, security remains a particular area of concern, because it’s not always clear who’s responsible for securing what. Before moving to the cloud, federal CIOs and CISOs should consider the following:
1. Responsibility and accountability: Some organizations may be inclined to think that security automatically becomes the responsibility of the cloud service provider -- but it doesn’t. The owner of the data is the responsible party, and agencies that plan to move to the cloud must develop, understand and periodically revisit their service-level agreements and terms-of-service contracts with their CSP. Thomas Trappler, the associate director for IT strategic sourcing at the University of California, recommends that SLAs should:
- Codify the specific parameters and minimum levels required for each element of the service as well as remedies for failure to meet those requirements.
- Affirm an institution's ownership of its data stored on the service provider's system and specify the organization's rights to get it back.
- Detail the system infrastructure and security standards to be maintained by the service provider along with the organization's rights to audit CSP compliance.
- Specify the organization's rights and costs to continue or discontinue using the service.
2. FedRAMP: Most federal organizations moving to the cloud know about the Federal Risk and Authorization Management Program, which provides a standardized approach to security assessment, authorization and continuous monitoring for cloud products and services.
Using a FEDRAMP-certified provider, however, does not mean that the agencies’ data will automatically be secured in the cloud. While the cloud provider may have the infrastructure to support security, most CSPs don’t provide encryption, security or segregation/separation of duties by default. Those often are considered additional services at an additional cost.
3. Public cloud vs. private cloud: Federal agencies must determine whether to move to a public cloud, where a commercial service provider makes resources, such as applications and storage, available clients over the internet, or a hosted private cloud, which offers similar services to a public cloud but is dedicated to a single organization. There are many factors that can influence a CIO’s decision -- budgetary limitations, staff and resource requirements, available physical space, capacity and workloads, to name a few. Two of most important considerations, however, should be data security and resiliency.
With a public cloud, most CSPs typically offer environment isolation in a multitenant hosting facility. Although an agency's data may be heavily firewalled from outside attack and isolated from other tenants' data, there’s still a possibility that it might become vulnerable. In fact, many IT professionals would argue that the risk of a breach goes up with public cloud. Major public cloud provider may have more tenured and technically trained cyber cloud experts, more monitoring and cyber defense tools and greater security guarantees, but they also are bigger targets than many smaller CSPs. The size of the cloud provider, how publicly known it is, the value of its hosted data and the likelihood of being targeted by cyber adversaries are all factors that agencies should consider when choosing between private and public cloud.
Private cloud can be a better choice for agencies that have the long-term funding to support it. Some may be able to afford the initial purchase of the hardware needed for a hosted private cloud, but the costs associated with hardware refreshes, physical security and hiring or retraining staff may limit agencies with smaller cloud budgets to a public cloud offering.
4. Security authorization: One of the biggest challenges for agencies using cloud-based solutions is understanding what it means to conduct assessment and authorization, formerly known as certification and accreditation, on a system whose boundaries and assets are in the cloud. Because of the complexities of a cloud environment, agencies should consider leveraging automation as a means of maintaining compliance. Automation can significantly reduce errors, but automating compliance takes significant investment. Agencies considering compliance automation should start with automating smaller components, such as security alert systems, then move on to other areas that will benefit from automation.
Authorization is really about ensuring that legitimate users on an agency's network has access to the data, applications and systems that are relevant to their jobs and roles and making sure that those who aren’t authorized to be on the network stay off of it. Because cloud resources can be accessed from anywhere with an internet connection, there’s an increased opportunity for cyber adversaries to gain access to agency data. To combat those threats and improve security in the cloud, many cloud providers will offer compliance as a service, but it’s important to understand not only the required standards and regulatory requirements, but exactly what CaaS means.
It’s easy to get excited about the benefits of moving to the cloud, but agencies must really understand the cyber implications. It can be tempting for CIOs and CISOs to think that someone else is responsible for their organization’s data once it’s in the cloud, but the truth is that the CIO and CISO are responsible for holding the CSP accountable for protecting that data.
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