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Cloud & National Security: Report to the President on Cloud Computing

Can NS/EP processes be migrated to the cloud without undue risk?

In view of the the quick-moving push to modernize many national security and emergency preparedness (NS/EP) capabilities to be cloud based capabilities, the White House tasked the President's National Security Telecommunications Advisory Committee (NSTAC) to produce a report aimed at answering the central issue: Can NS/EP processes be migrated to the cloud without undue risk?

By U.S. Government [Public domain], via Wikimedia Commons

From the executive summary:

"Cloud computing is a paradigm shift in technology that changes the way applications, data and processes are performed, stored and shared. As with any technology paradigm shift, issues such as how the new technologies are used, security, policy, and oversight must be considered when weighing the benefits of adopting the new paradigm. Accordingly, as the federal government executes its Cloud First policy, implications for national security and emergency preparedness (NS/EP) must be considered as they relate to cloud computing plans and programs. Toward these ends, and in the context of a charge to examine cloud computing, two questions were posed to the President’s National Security and Telecommunications Advisory Committee (NSTAC) by the Executive Office of the President (EOP):

  • Within the context of NS/EP, what equities should the Government consider moving to the cloud, and in what priority order, if appropriate? What are the sorting/defining NS/EP considerations to determine applicability and value for migration of any given equity to a cloud computing environment?
  • For equities that do migrate to the cloud, should the requirements for providers supporting NS/EP standards and capabilities differ from the requirements established for commercial cloud providers in general? If so, how?

The central issue at the core of these questions is: Can NS/EP processes be migrated to the cloud without undue risk? In order to confidently answer the question favorably, the NSTAC
recommends that a regime of policy, legal authorities, security and oversight that is comparablyrigorous, complete and trustworthy relative to that now in place for NS/EP activities via legacy means be adopted.

This in turn required the NSTAC to examine several aspects of the described framework as it applies or could be extended to cloud computing. In that regard, the NSTAC studied:

  • Policy and legal frameworks: Both have important gaps, and recommended fixes are identified;
  • Means by which NS/EP cloud activities, contracts and programs could be identified for specific treatment inside the much larger federal cloud enterprise – An approach based on mandatory service-level agreements (SLA) was developed in detail, and is recommended;
  • Security considerations for cloud computing: The NSTAC developed an approach tailored to specific characteristics and priorities of cloud computing, and then designed controls to mitigate identified risks; and
  • Priority-access process to support emergency needs: Programs in this area need to be developed, and the NSTAC recommends what to do and how to proceed.

This analysis permitted the NSTAC to conclude that while not in place today, the needed ‘comparable’ NS/EP-support regime of policy, legal, security and other considerations can be both defined and implemented. In that context, and conditioned on the availability of such processes, the NSTAC was able to directly address the questions posed.

Within the context of NS/EP, what equities should the Government consider moving to the cloud, and in what priority order, if appropriate? What are the sorting/defining NS/EP considerations to determine applicability and value for migration of any given equity to a cloud computing environment? Conceivably any NS/EP process, including the most sensitive matters, could be moved to “some kind of” cloud, given proper attention to architectural and security decisions. The key qualifier in this judgment relates to the choice of deployment and service model, each seen in the context of the specific mission to be migrated. To support this analysis, the NSTAC deconstructed NS/EP to the mission-function level and subjected each such mission to risk-benefit analysis via a process using NS/EP-specific attributes developed by the NSTAC for this purpose. The NSTAC was able to rank and prioritize recommended progression to the cloud based on the variable benefit of doing so, mission by mission. The result of this effort was a graphical plot of relative value of cloud migration, with some missions appearing more attractive than others, but all being acceptable at some level. Details of this analysis and tables of findings and conclusions may be found in the body of the report.

For equities that do migrate to the cloud, should the requirements for providers supporting NS/EP standards and capabilities differ from the requirements established for commercial cloud providers in general? If so, how? The NSTAC has developed recommendations that address this issue in two parts. First, a list of specific security and related functionalities are identified that should be codified in standard SLAs, using the NS/EP SLAs in the Networx contract vehicle as a point of departure. These should be made mandatory as part of any NS/EP cloud computing contract awarded to any service provider. Second, the NSTAC carefully reviewed existing security-control frameworks from numerous sources, reflecting various points of view and key aspects of domain knowledge and experience of their drafters. From these the NSTAC selected best practices of the federal cloud policy and technology authorities, the cloud computing industry, the audit community and leading international organizations. These were blended into a common language and format, and then distilled into a single, comprehensive and coherent set of cloud security controls tailored for NS/EP attributes and priorities. The NSTAC recommends that these controls become mandatory for daily use in all NS/EP cloud computing implementations.
In the course of implementing the program described here, the most important recommendations included in the report are that the President:

  • Direct the appropriate Government organization to develop processes and maintain priorities as described in the body of the report for migration of NS/EP missions to cloud based environments.
  • Direct the adoption of NS/EP SLAs in all contracts pertaining to NS/EP cloud computing, which address the following functionalities:
    • Mission emphasis on continuous availability, assured capacity;
    • Identity management (authentication & authorization) for specified mission functions;
    • Periodic third-party audit;
  • Provisions for continuous monitoring;
  • Data encryption in hosted data center (data at rest);
  • Security process transparency for users (EP systems only); and
  • Certification and accreditation (C&A) of hosting systems/processes.
  • For certain national security systems, additional requirements include:
    • Data tagging; and
    • Security management conducted by government service provider.
  • Direct the National Communications System (NCS) to adopt cloud security controls developed by this study and found at Appendix E as a comprehensive NS/EP cloud security program, making their use mandatory by NS/EP service owners and auditable by third parties.
  • Broaden the definitional scope of NS/EP, as reflected in current law and federal regulation, to embrace information services, as defined, in order to permit the technical nature of cloud computing to fit within the NS/EP definition.
  • Direct the expansion of scope of the Federal Risk and Authorization Management Program (FedRAMP) to embrace those governmental information systems reportable under the Federal Information Security Management Act (FISMA) at Federal Information Processing Standard (FIPS) 199 High Impact level, thereby closing a current gap in oversight of a large number of systems relevant to NS/EP.
  • Direct the initiation of a Federal program, in collaboration with relevant industry partners, to develop a system for priority access to cloud-based equities in times of need, based on infrastructure degradation due to natural or man-made causes."

The full report is here [PDF]: 2012-05-15 NSTAC Cloud Computing.

Thanks to Bob Gourley of CTO Labs for hosting the PDF.

More Stories By Jeremy Geelan

Jeremy Geelan is Chairman & CEO of the 21st Century Internet Group, Inc. and an Executive Academy Member of the International Academy of Digital Arts & Sciences. Formerly he was President & COO at Cloud Expo, Inc. and Conference Chair of the worldwide Cloud Expo series. He appears regularly at conferences and trade shows, speaking to technology audiences across six continents. You can follow him on twitter: @jg21.

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