Should Cloud Contracts Cover Client Responsibilities?
The main focus of a cloud computing contract is on vendor responsibilities, but it's appropriate to consider what the client remains responsible for.
University of CaliforniaThomas J. Trappler, Director of software licensingWhen choosing a cloud provider, it's important to follow best practices in determining that the vendor's security practices align with your needs.
When I was a guest on CIO Talk Radio earlier this month, a question came up about which client responsibilities are appropriate to include in a cloud computing contract. It's a good question, and one that I haven't really talked about here, since most of my Computerworld columns have focused on vendor responsibilities that you should codify in the contract.
So what are some client responsibilities that are reasonably addressed in a cloud computing contract? While they vary depending upon type of cloud service and use case, the most common examples involve client IT governance, including the following:
When choosing a cloud provider, it's important to follow best practices in determining that the vendor's security practices align with your needs. But that's only one side of the security coin.
As with most things in IT, access to a cloud service typically requires a login ID and password. When a client enterprise acquires a cloud service, it should be the client's responsibility to figure out which end user should be given access. But to thoroughly address this responsibility, the client should define when access should be taken away from the user -- for example, upon separation from employment or upon a change in duties or responsibilities.
The cloud is a new and evolving market, vendors focused on growth can neglect security basics.
Responsibility for the security of each individual login ID and password lies with the client's end users. The recent alleged hack of Mitt Romney's email and Dropbox passwords, in which the hacker was able to easily answer "secret" security challenges and gain access, illustrates the risks. Even though there are many commonly available best practices in password security and widely publicized examples of these hacks (Romney might have done well to remember a similar hack against Sarah Palin a few years ago), human nature tends to make it difficult to maintain focus on these efforts, so diligence is necessary.
This isn't to say that cloud vendors don't retain some responsibilities related to password security. Because the cloud is a new and evolving market, vendors focused on growth can neglect security basics. For a quick primer on what not to do, read about the recent LinkedIn breach, which provided hackers with the passwords of over 6 million LinkedIn users.
In an initial evaluation of a cloud service, you try to project the use case. You think about the business criticality of the function being moved to the cloud and the type of data that would be processed or stored by the cloud service. Ideally, though, once the cloud service is operational, it takes off with your end users who begin to think of all kinds of ways to use the service that may not have been factored into your initial evaluation.
There's a good chance that these new uses involve new categories of data that may be subject to other regulations and/or security requirements. If so, they may not align with your initial risk assessment of the cloud vendor's infrastructure and security. To protect against this, the client's IT governance processes should include end-user training regarding the appropriate use of the cloud service (purposes, data type, etc.), as well as how to formally evaluate and communicate approved changes as use cases evolve.
The service model (infrastructure as a service, platform as a service, software as a service) of the cloud service that you adopt will also have an impact on your responsibilities. With IaaS, for example, the client tends to have more responsibilities, because the vendor typically provides only the raw, underlying computing infrastructure.
Under the IaaS model, the client is expected to assume responsibility for selection and management of everything that runs on top of that raw infrastructure, including the operating system and associated updates and patches, applications software, and some security configuration such as firewalls. In some cases, such as with Amazon Web Services, the client may also have the ability, and associated responsibility, to select the geographic location of the vendor data center storing or processing the client's data.
As I said, these are just some of the areas that the client can appropriately take responsibility for in a cloud computing contract. Understanding which client responsibilities are appropriate to include in the contract, as well as how the client can most effectively fulfill those responsibilities, remains an important element in the effective adoption of a cloud computing service.
As more information is disclosed from the Sony hack, it demonstrates that awareness concerns go well beyond phishing.