(1)Cloud Computing Best Practices
Cloud Computing Best
Practices
Creating Effective Cloud Computing Contracts for
the Federal Government: Best Practices for
Acquiring IT as a Service
(2)Overview
Cloud Computing – What is it?
“Cloud First” Policy and Guidance
The Cloud Procurement White Paper
Minimizing Litigation Risk and Cost
(3)NIST Definition
“Cloud computing is a model for enabling convenient, on‐demand network access to a
shared pool of configurable computing resources (e.g., networks, servers, storage,
applications, and services) that can be rapidly provisioned and released with minimal
management effort or service provider interaction. This cloud model promotes availability
and is composed of five essential characteristics, three service models, and four
deployment models.”
Source: NIST, Definition of Cloud Computing, Draft version 15, http://csrc.nist.gov/groups/SNS/cloud‐computing/index.html
Laymen's Definition
Cloud is essentially utility computing
Automated services (no humans needed for change in services)
Services are consumed as used (“pay per drink”)
Enabled via the internet (accessible anywhere)
Elasticity in amount of services consumed (rapid provisioning and de‐
provisioning)
Transition from capital expenses to operating expense
What is Cloud Computing?
Slide 3
(4)Software
SaaS (software‐as‐a‐service)
Applications available as an on demand service
End‐user applications
Platform
PaaS (platform‐as‐a‐service)
IT and developer tools for database and testing
environments to develop applications
Development or deployment activities
Infrastructure
IaaS (infrastructure‐as‐a‐service)
Computing, Storage and Hosting Services
Network administrators
Source: http://info.apps.gov/node/17
Mainframes
Servers
Storage
IT Facilities/Hosting Services
Application Development
(Workflow and Automation)
Security Services (Single Sign‐On,
Authentication)
Database Management
Directory Services
Applications, Internet Services
Social Media (Blogs, Wikis)
Email, E‐Meetings
Productivity Tools (Office)
What Services Are In The Cloud?
Common Examples
(5)Source: http://info.apps.gov/node/17
What Types of Clouds Are There?
PRIVATE CLOUD
Operated solely for an
organization
COMMUNITY CLOUD
Shared by several
organizations – can be public
or private
PUBLIC CLOUD
Available to the general
public
HYBRID CLOUD
Composition of two or more clouds
(private, community, or public)
Slide 5
(6)Cloud: A Fundamental Shift in IT
(7)Cloud: Cheaper, Better, Faster
Cheaper
Cheaper
Better
Better
Faster
Faster
Decrease time‐to‐
market to deploy or
implement IT solutions
via secure, easy to use
contract vehicles
available to federal &
state and local
government
Decrease time‐to‐
market to deploy or
implement IT solutions
via secure, easy to use
contract vehicles
available to federal &
state and local
government
Allows key resources to
focus on mission –
critical activities and/or
use solutions and
services on‐demand or
as‐needed
Allows key resources to
focus on mission –
critical activities and/or
use solutions and
services on‐demand or
as‐needed
Save money & help
lower the cost of
government operations
while driving innovation
by avoiding duplicative
infrastructure by using
“pay‐as‐you‐go” service
models
Save money & help
lower the cost of
government operations
while driving innovation
by avoiding duplicative
infrastructure by using
“pay‐as‐you‐go” service
models
A fundamental shift: Agencies get state of the art products and services when
they need them, at lower, commodity‐based prices. Government can redirect
scarce resources to mission‐critical efforts as opposed to managing IT.
Cloud = Future State of Government IT
Slide 7
(8)“The Administration’s
Federal Cloud Computing
Strategy
requires agencies to default to cloud‐based
solutions whenever a secure, reliable and cost‐effective
cloud option exists – however, the move to the cloud
requires a dramatic shift in the way Federal agencies buy
IT – from capital expenditures to operating expenditures.
With this shift comes a learning curve as the government
analyzes how to best procure this new service‐based
model.
. . .”
‐Steven VanRoekel
U.S. Chief Information Officer, OMB
February 24, 2012
Administration’s Drive to the Cloud
(9)Federal Cloud
Computing
Strategy
February 8, 2011
Federal Timeline for Cloud
“Cloud First”
25 Point Plan to
Reform Federal IT
December 9, 2010
FedRAMP Policy
Memo
December 8, 2011
Creating
Effective Cloud
Computing
Contracts
February 24, 2012
Slide 9
(10)“Cloud First”
Policy
Point 3 of the White House’s 25 Point Plan to Reform Federal IT
Requires agencies to evaluate safe, secure cloud options before
making any new investments.
This means agencies should evaluate their technology sourcing
plans to include cloud solutions as part of the budget process.
Three Cloud Projects by June 9, 2012
“Cloud First” mandates agencies move three projects to the cloud
At least 1 project had to move to the cloud by December 9, 2011;
2 additional must move by June 9, 2012.
Cloud: 25 Point Plan to Reform IT
(11)Overview
Details benefits of cloud to
Federal government
Provides decision
framework for moving to
the cloud
Case examples to illustrate
framework
Promotes vision for
catalyzing cloud adoption
across Federal government
Cloud Computing Strategy
Slide 11
(12)Overview
Mandatory for Federal agencies via
OMB Policy Memo
Creates government‐wide security
process for cloud computing solutions
Provides assessments, provisional
authorizations, and continuous
monitoring of cloud services
Transparent processes for Federal
agencies and cloud service providers
Establishes a Federal government
standard baseline for securing cloud
environments
Federal Risk and
Authorization
Management
Program
Cloud Security:
FedRAMP
(13)Overview
Top 10 areas Federal
agencies need to address
when procuring cloud
Gives description of issues
along with ways to address
issues within contracts
Provides tactical guidance
through a questionnaire
checklist
Cloud Procurement White Paper
Slide 13
(14)“Today, the CIO Council, CAO Council, and Federal Cloud
Compliance Committee released:
Creating Effective Cloud
Computing Contracts for the Federal Government:
Best
Practices for Acquiring IT as a Service.
This guide enables Federal agencies to make smarter,
more informed cloud purchasing decisions by utilizing
lessons learned and best practices of early adopters –
moving us to a more efficient and more effective
government.”
Steven VanRoekel
U.S. Chief Information Officer, OMB
February 24, 2012
Partnership of IT, Acquisition, Legal
(15)Development of White Paper
Two‐Tier Approach to Creating Guidance.
Existing Cloud Contracts
Existing Cloud Contracts
Develop lessons learned from early
adopters
Informal data call through OMB to
collect ~15 existing Federal cloud
contracts
Review of contracts to see variance
of contract terms, establish
baseline and identify themes
Interview project managers and
contracting officers of each
contract:
What worked
What doesn’t work
How various issues were
addressed
Develop lessons learned from early
adopters
Informal data call through OMB to
collect ~15 existing Federal cloud
contracts
Review of contracts to see variance
of contract terms, establish
baseline and identify themes
Interview project managers and
contracting officers of each
contract:
What worked
What doesn’t work
How various issues were
addressed
FC3 Guidance
FC3 Guidance
Guidance Developed by Federal
Cloud Compliance Committee (FC3)
Informal interagency group
comprised of Federal Attorneys,
procurements officials, and cloud
SMEs.
Mission: create tactical guidance to
proactively assist agencies when
contracting cloud
Created four working groups:
Security
Privacy
E‐Discovery
Records Management/FOIA
Guidance Developed by Federal
Cloud Compliance Committee (FC3)
Informal interagency group
comprised of Federal Attorneys,
procurements officials, and cloud
SMEs.
Mission: create tactical guidance to
proactively assist agencies when
contracting cloud
Created four working groups:
Security
Privacy
E‐Discovery
Records Management/FOIA
Slide 15
(16)Cloud Computing and the Federal Government:
Effectively Acquiring IT as a Service
Goals of White Paper
Merge the “Cloud First” mandate and the visionary “Cloud Computing
Strategy”
The next step in government’s move to cloud with specific guidance in
effectively buying cloud services
Provide guidance to agencies in developing requirements for a cloud
computing contract.
Highlight top ten areas for Federal agencies to address in cloud
contracts
Help shape the way that cloud computing services are purchased and
consumed
Establish common practices for the Federal government to take
advantage of its position as the largest purchaser of IT
(17)1)
Selecting a Cloud Service
2)
CSP and End‐User Agreements
3)
Service Level Agreements (SLAs)
4)
CSP, Agency, and Integrator Roles and
Responsibilities
5)
Standards
6)
Security
7)
Privacy
8)
E‐Discovery
9)
Freedom of Information Act (FOIA)
10)
E‐Records
Top 10 Focus Areas
Slide 17
(18)Selecting a Cloud, End User Agreements
ONE
Selecting a Cloud Service
ONE
Selecting a Cloud Service
Agencies must choose the
appropriate cloud to meet
their needs
Determine the appropriate
service model to meet user
needs
Determine the appropriate
deployment model that
meets data protection
needs
Agencies must choose the
appropriate cloud to meet
their needs
Determine the appropriate
service model to meet user
needs
Determine the appropriate
deployment model that
meets data protection
needs
TWO
CSP & End‐User
Agreements
TWO
CSP & End‐User
Agreements
Terms of Service Agreements
(TOS) need to be negotiated
TOS must be compliant with
Federal laws and statutes
Need to ensure NDA
enforceability
End User Agreements need
to be integrated fully into
cloud contracts
Terms of Service Agreements
(TOS) need to be negotiated
TOS must be compliant with
Federal laws and statutes
Need to ensure NDA
enforceability
End User Agreements need
to be integrated fully into
cloud contracts
(19)SLAs
and CSP, Agency, Integrator
Rs
&
Rs
THREE
Service Level Agreements
THREE
Service Level Agreements
SLAs should clearly define
CSP performance standards
Need clear terms and
definitions
Need to determine how CSP
performance will be
measured
Needs to establish
enforcement mechanisms
for SLA compliance
SLAs should clearly define
CSP performance standards
Need clear terms and
definitions
Need to determine how CSP
performance will be
measured
Needs to establish
enforcement mechanisms
for SLA compliance
FOUR
CSP, Agency, & Integrator
Roles and Responsibilities
FOUR
CSP, Agency, & Integrator
Roles and Responsibilities
Establishes a contract with
(at least) three parties
Determine integrator role
with CSP
Need to clearly define the
roles and responsibilities of
all actors to ensure
effectiveness of the cloud
contract
Establishes a contract with
(at least) three parties
Determine integrator role
with CSP
Need to clearly define the
roles and responsibilities of
all actors to ensure
effectiveness of the cloud
contract
Slide 19
(20)Standards and Security
FIVE
Standards
FIVE
Standards
Agencies should ensure
CSPs align with government
standards
Map services to NIST
Reference Architecture
Ensure government
participation in standards
creation
Compliance with Internet
Protocol version 6
Agencies should ensure
CSPs align with government
standards
Map services to NIST
Reference Architecture
Ensure government
participation in standards
creation
Compliance with Internet
Protocol version 6
SIX
Security
SIX
Security
FedRAMP Compliance
Clearly defined requirements
Continuous monitoring
activities
Incident response to attacks
and vulnerabilities
Key escrow/encryption
Forensic capabilities
Multi‐factor authentication
with HSPD‐12
Audit capabilities
FedRAMP Compliance
Clearly defined requirements
Continuous monitoring
activities
Incident response to attacks
and vulnerabilities
Key escrow/encryption
Forensic capabilities
Multi‐factor authentication
with HSPD‐12
Audit capabilities
(21)Privacy and E‐Discovery
SEVEN
Privacy
SEVEN
Privacy
Ensure compliance with the
Privacy Act of 1974 and PII
requirements
Privacy Impact Assessments
Adequate privacy training
Clearly defined data location
requirements
How to respond to a breach
where privacy data was
compromised
Ensure compliance with the
Privacy Act of 1974 and PII
requirements
Privacy Impact Assessments
Adequate privacy training
Clearly defined data location
requirements
How to respond to a breach
where privacy data was
compromised
EIGHT
E‐Discovery
EIGHT
E‐Discovery
Provide information
management in the cloud
Ability to locate relevant
documents
Ability to preserve data in a
cloud environment
Moving documents through
the e‐discovery process
Cost avoidance by inclusion of
tools with CSP solution
Provide information
management in the cloud
Ability to locate relevant
documents
Ability to preserve data in a
cloud environment
Moving documents through
the e‐discovery process
Cost avoidance by inclusion of
tools with CSP solution
Slide 21
(22)FOIA and Federal Recordkeeping
NINE
FOIA Access
NINE
FOIA Access
Ability to conduct a
reasonable search to meet
Freedom of Information Act
(FOIA) obligations
Ensure the processing of
information is pursuant to
FOIA requirements
Allow for the tracking and
reporting of information
pursuant to FOIA
Ability to conduct a
reasonable search to meet
Freedom of Information Act
(FOIA) obligations
Ensure the processing of
information is pursuant to
FOIA requirements
Allow for the tracking and
reporting of information
pursuant to FOIA
TEN
Federal Recordkeeping
TEN
Federal Recordkeeping
Agencies should have
proactive records planning
before using a cloud service
Ensure the ability to have
timely and actual destruction
of records in accordance with
mandated records schedules
How to deal with permanent
records
Process for transitioning to a
new CSP
Agencies should have
proactive records planning
before using a cloud service
Ensure the ability to have
timely and actual destruction
of records in accordance with
mandated records schedules
How to deal with permanent
records
Process for transitioning to a
new CSP
(23)Overview
Translates the paper to
tactical questions to
ask when reviewing or
creating a cloud
contract
Maps to the ten areas
of focus within the
paper
Tactical approach for
Agencies to use
Appendix A: Questionnaire
Slide 23
(24)All necessary stakeholders should be included
when creating cloud computing contracts.
OCIO
OGC
Privacy
Records
E‐Discovery
FOIA
Acquisition staff
This will enable Federal agencies to more
effectively procure and manage IT as a service
White Paper: Key Takeaway
(25) CIO Council
www.cio.gov
Federal Cloud Computing Initiative
www.info.apps.gov
FedRAMP
www.FedRAMP.gov
NIST
http://www.nist.gov/itl/cloud
NARA
http://www.archives.gov/records‐mgmt/bulletins/2010/2010‐05.html
Cloud Resources
Slide 25
(26)Cloud Computing Best Practices
Questions?
Matt Goodrich
Federal Cloud Computing Initiative, GSA
[email protected]
Allison Stanton
Director, E‐Discovery, DOJ‐ Civil Division
[email protected]