by Dr. Jim Kennedy,
MRP, MBCI, CBRM, CHS-IV
January 2011
If
you asked a group of IT practitioners or business people what cloud computing
is they would probably answer in a manner
consistent with blind men trying to describe an elephant with only the sense of touch.
Each would have an answer consistent with their own specific perceptions.
In
fact Public Cloud Computing is a relatively new term that has been around for
only a few years and refers to the use of information technology services,
infrastructure, and resources that are provided on a subscription basis. Public
Cloud Computing is a Web or Internet accessed business solution where most or
the entire computing infrastructure (computers, network, storage, and etc.) are
contained remotely from the actual business site and is managed by a third
party.
Many
companies rely upon Public Cloud Computing in part or in whole for their
business operations critical and other wise. So as we look at disaster recovery
and Public Cloud Computing we are looking at a relatively new set of risks that
need to be addressed to properly protect a business against unforeseen events.
Before
I address the areas of concern to DR planning for public cloud computing let me
discuss the various popular forms of public cloud computing available to the
business.
There
are three basic types:
- Software as a Service (SaaS)
- Platform as a Service (PaaS)
- Infrastructure as a Service (IaaS)
Software
as a Service (SaaS) is defined as a service based on the concept of renting
software from the service provider rather than buying individually for your
business. The software is hosted on network servers which are made functionally
available over the web or intranet. This service provides software on demand
and is currently the most popular type of public cloud computing because of its
flexibility, ability to be scaled, and because maintenance is provided by the
service provider as part of the cost of the service. There are many CRM, ERM,
and unique applications that are all provided as SaaS services. With web-based
services all that employees need to do is register and log-in to the cloud
provided instance. The service provider hosts both the application and the data
so the business user is capable of utilizing the service from anywhere
potentially across the globe. With SaaS the service provider is responsible for
all issues dealing with capacity, upgrades, security and service availability.
Platform
as a Service (PaaS) is defined as a service that offers a platform for
developers. The business users develop their own code and the service provider
uploads that code and allows access to it on the web. The PaaS provider
provides services to develop, test, deploy, host and maintain applications on
their development environment. The service providers also provide various
levels of support for the creation of applications. Thus PaaS offers a quicker
and cheaper model for application development and delivery. The PaaS provider
will manage upgrades, patches and system maintenance.
Infrastructure
as a Service (IaaS) is defined as a service where the service provider delivers
the computing infrastructure as a fully outsourced service. The user can
purchase various components of the infrastructure according to their
requirements when they need it. IaaS operates on a “Pay as you go” model
ensuring that the users pay for only what they have contracted for – such as
network, computing platforms, rack space, and environmental (HVAC and power).
Virtualization has enabled IaaS vendors to high volumes of servers to
customers. IaaS users purchase access to enterprise grade IT Infrastructure and
resources and personnel to keep the infrastructure running. No application or
monitoring of data bases or data is provided by the hosting vendor above the OS
level unless contracted at an additional cost.
Basic
Flaw in the "... as a Service" Offerings
In
the cloud computing definitions that are evolving, the services in the cloud
are being provided by third-party providers and accessed by businesses via the
internet. The resources are accessed as a service on a subscription basis. The
users of the services being offered most often have very little knowledge of
the technology being used, the security being deployed, the availability of the
service being offered, or the operating best practices (monitoring, patching,
maintenance, and etc.) utilized by the service provider. The business
subscribers also have little or no control over the infrastructure that
supports the technology or service they are using.
Under
the standard of “Due Care” and charged with the ultimate responsibility for
meeting business information technology objectives or mission requirements,
senior management must ensure that the services they contract, which include
these “. . . as a Service” solutions are appropriate to meet all of the
necessary business requirements including the areas: legal, technical,
financial, and operational.
This
business continuity due diligence comes only through a thorough vetting of the
“. . . as a Service” provider in several areas. I have listed some of the more
important ones below.
Legal
& Regulatory
- Will the service provider meet any of you data breach notification requirements (remember even though you are hosting you are responsible for the data under your protection i.e. PHI, PII, and etc.)?
- Will the provider meet data retention requirements of the business?
- Will the provider meet the standards for data encryption and protection you require?Are “Safe Harbor” needs met?
- Data destruction or return on end of contract well defined to meet your business requirements?
- What is their incident management program?
- Are they prepared to react in a timely fashion in case of any eDiscovery needs of data they store for you?
Service Availability
Are the facilities housing the service
provider adequately secured (video surveillance, access control, and etc.?
Are the RPOs and RTOs consistent with the business’ requirements?
Are the RPOs and RTOs consistent with the business’ requirements?
·
How often are backups taken, are they
maintained off-site, and have backups and restores been tested to your
satisfaction?
·
Are standard backup methods and
media used just in case the business needs to bring data back into house?
· Maintenance and maintenance windows
satisfactory with your operational needs?
· What types of technical security do
they employ (i.e., firewalls, virus protection, Intrusion Detection Devices,
and etc.)
· Are their hours of operation coincident
with yours?
· If you are a global company do they
provide multilingual support?
· Are there clear escalation procedures
in case of an incident?
· Does the vendor provide global
diversity so if one goes down another can be used in its place?
Operational
·
Do they have a current SAS 70 Type II
audit findings report?
·
Have they corrected any areas of
concern to your business?
· What capacity planning do they have in
place to meet the growing needs of your business?
· What standards of practice do they
adhere to (i.e., ISO 27001, BS25999, and etc.)?
· Do they have a patch management program
in place and what is it? Does it meet your requirements?
· Do their SLAs meet your business and
operational requirements?
I
have developed a hosting questionnaire which each “. . . as a Service” vendor
is required to answer to the satisfaction of my client and I would
recommend that you do the same. Sometimes it takes a few iterations to complete
the form to the satisfaction of the client, but when completed it does provide
documentation of due diligence and a clearer picture of what can be expected
from the service provider. If the vendor will not complete the questionnaire
then it would be best to move on to another vendor – regardless of cost. If you
can’t come to terms before a contract or Statement of Work is signed it will be
ten times more difficult after signature to come to an agreement.
In
Summary
Now
this article has only scratched the surface and provided information on the
basic questions that should be asked and answered to protect businesses
utilizing “ . . . as a Service” providers. However, the intent of this article
was to inform the reader that there are many types of “. . . as a Service”
offerings and ways to reduce and/or eliminate problems that I have experienced
over the last few years. The issue the article wants to impress upon the reader
is one of due diligence. We as corporate or governmental IT security or
business continuity experts need to make sure that our organizational leaders
have the necessary information to make informed choices for the protection of
critical and sensitive information. To allow them to decide between implementing
adequate controls and safeguards now to protect against risks or to potentially
pay later in reparations and lost confidence of those whose data they (senior
management) have been entrusted to protect but have lost or allowed to be
taken.
The
Author
Dr.
Jim Kennedy, MRP, MBCI, CBRM, CHS-IV has a PhD in Technology and Operations
Management and is the Chief Consulting Officer for Recovery-Solutions. Dr.
Kennedy has over 30 years' experience in the information security, business
continuity and disaster recovery fields and has been published nationally and
internationally on those topics. He is the co-author of two books, ‘Blackbook
of Corporate Security’ and ‘Disaster Recovery Planning: An Introduction’ and
author of the e-book, ‘Business Continuity & Disaster Recovery – Conquering
the Catastrophic’. Author can be reached at Recovery-Solutions@xcellnt.com
For
more information about Business Continuity, IT Disaster Recovery and Audit
Training and Certification, visit www.sentryx.com
or contact info@sentryx.com or call
1-800-869-8460
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