The migration of information to the cloud is largely regarded as the next major step in enabling organizations to work faster, cheaper and more efficiently. According to the Office of Management and Budget, an estimated $20 billion of the federal government's $80 billion in IT spending is a potential target for migration to cloud-based solutions. As the both government and individuals accelerate the movement of information to the cloud, major breaches and concerns mount over information vulnerability and ownership, and their risk to security, privacy and operations.
The movement of our information to the cloud
The Obama administration, with its "cloud first" policy, encourages agencies to take full advantage of cloud computing benefits to maximize capacity utilization, improve IT flexibility and responsiveness, and minimize cost. And, the president's 2012 Managing Government Records Directive details the National Archives and Records Administration to promote cloud-based services to store and manage electronic records.
Federal agencies, including NARA and the Interior Department, are increasingly committing their email and official records to cloud-based services, while individual consumers including mobile phone and email users are confidently storing their personal photos, medical and financial information in the cloud using services like iCloud, Google Drive and Microsoft SkyDrive.
Risks surrounding cloud storage
As the move to the cloud hastens, however, organizations and individuals share concerns over the risks associated with storing critical and often sensitive information, including records and personal information in the cloud. A recent MeriTalk survey discovered that four out of five federal IT professionals do not feel confident in their cloud vendor's security, including the ability to provide FISMA compliance.
Concerns range from vulnerability to hacking to data ownership to the stability of cloud providers. In an extreme example, the Labor Department and General Services Administration are now spending more than $23 million to rescue financial data from a bankrupt cloud-based financial management system vendor.
Chief concerns over the use of cloud storage include:
Vulnerability to hacking and theft including poor password protection, software flaws and lack of data encryption.
Security, privacy and ownership of information in an environment that resides outside of agency firewalls.
Lack of portability standards, moving data in and out of cloud environments into other systems, particularly when contracts end.
Cloud applications not meeting records management requirements, including:
- Maintaining records to preserve functionality and integrity throughout their life cycle.
- Maintaining links between the records and their metadata.
- Transfer of records to NARA or deletion of temporary records according to NARA-approved retention schedules.
Minimizing risks of cloud-based information storage
"There are security benefits to the cloud and its inherent economies of scale," explains information governance consultant Tim Shinkle. "On-premise solutions require a large effort and cost to secure their environment. Cloud vendors know that their success is dependent upon them ensuring information security, since the blame is squarely on them if security fails. Government standards that cloud vendors have to meet including FedRAMP are reducing risk for cloud adopters."
He also suggests considering a hybrid model of "on premise and cloud, where information management lifecycle controls manage what information is stored in what environment at what point in its lifecycle; for example, collaboration content on premise and inactive records in the cloud."
Agencies can take measures to mitigate risks to their information assets. The following are recommendations for taking precautions and creating policies to minimize risk surrounding the management of information stored in cloud environments:
Define and document your organization's information and security requirements for your cloud-based solution, including records management functionality, compliance (FISMA, NARA, etc.), metadata requirements, security and privacy controls, retention requirements, and legal requirements (eDiscovery, holds).
Include the agency records officer in the planning, deployment and use of cloud-based solutions to ensure that records management requirements are addressed.
Evaluate your cloud architecture needs. For example, a private cloud (vs. public cloud) model allows your agency to enforce the agency's own information security standards and controls and may be a consideration for storage of highly sensitive information.
Perform due diligence when selecting a cloud provider, including checking references, site visits and verifying required certifications and standards compliance.
Negotiate contractual arrangements with cloud providers to manage known risks, including corporate stability, storage location and data ownership, contract termination, service level agreements, audits and backup and recovery procedures.
There are programs helping agencies reduce their risk as they implement cloud-based solutions, such as the Federal Risk and Authorization Management Program to provide a blanket certification and authority to operate for cloud products. FedRAMP's set of security authorizations, including FISMA requirements, can reduce or eliminate the need for agencies to conduct their own security reviews.
Several vendors are providing compliant records management applications that can be successfully deployed in the cloud. DoD and federal agencies should evaluate traditional records management systems as well as SharePoint for compliance with FISMA and records management standards including DoD 5015.2. Ultimately, agencies are responsible for assessing the solutions and complying with records management regulations wherever records are created and stored.
Individual consumers should research how cloud providers manage their files, and follow security best practices, such as password formatting and reset frequency, in order to minimize their exposure to hackers, unintentional file exposure, and malware that compromise personal information.
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