Information Assurance in the Cloud

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1 Information Assurance in the Cloud The Status of FedRAMP, April 2013 AGA - Montgomery/Prince George s Chapter cliftonlarsonallen.com

2 Session Outline 1. Cloud Services in Federal Government The Opportunity 2. Expediting Adoption While Maintaining Assurance The Challenge 3. FedRAMP Primer The Proposed Solution 4. Where Things Stand Today Next Steps 2

3 Disclaimers Session content is derived from publicly-available, government-provided information* Opinions/conjectures offered are solely the responsibility of your speaker, not his organization apologies in advance for errors or omissions Any comments or discussion during this session will be welcome, especially if based on recent experience with FedRAMP! * See in particular FedRAMP Agency Compliance and Implementation Workshop, March 18,

4 1. Cloud Services in Federal Government The Opportunity 4

5 What do we mean by cloud? The move to the Cloud in general has been understood to refer to a set of new or differently-executed ways that service providers extend computer applications to users: Reducing dependence on dedicated infrastructure Flexibly scaling services up or down as demand changes Reducing implementation time-to-market Reducing technology costs and making them predictable Getting agencies out of the business of investing in nonmission, common services Leveraging common services widely, not reinventing Tracking more towards private sector tools 5

6 How Cloud Works Fewer products, more services (NaaS) Architecture more independent of services Components highly portable and scalable Boundaries vague by design More fluid, multi-tier conceptual design Less clear component ownership Source: 6

7 Federal timeline Cloud Computing PMO established at GSA: April 2009 GSA announces availability of cloud-based IaaS in government via initial BPA awards: 10/19/2010 Cloud First initiative: 25-Point Plan 12/9/2010 Federal Cloud Computing Strategy: 2/8/2011 NIST SP Definition of Cloud Computing: September 2011 NIST SP Guidelines on Security and Privacy in Public Cloud Computing: December 2011 NIST SP Cloud Computing Synopsis and Recommendations: May

8 2. Expediting Adoption While Maintaining Assurance The Challenge 8

9 How could the mass introduction of Cloud in government possibly go wrong? Immature industry: claims hard to support or refute Low agency capability maturity to acquire/manage Lack of common definitions and terminology Lack of clear procurement and contracting guidelines Lack of understanding of provider vs. agency roles and responsibilities Lack of directly-applicable control/assurance models Lack of clarity on assessment and IA standards 9

10 The outcome for Cloud could be bleak Cost savings might not be realized Benefits over traditional acquisition and provisioning approaches might not be achieved Fledgling market could become fragmented Adoption could be slowed Interoperability/sharing could be limited Security could be compromised Risk acceptance by agency DAA could be more difficult to gain Cloud might become another example of a promising technology advance that couldn t make the leap to Federal 10

11 3. FedRAMP primer The Proposed Solution 11

12 Where did FedRAMP come from? Working group spearheaded by NIST and GSA, with significant agency and industry support Mission: To foster the adoption of cloud across the Federal government and to address obstacles to cloud adoption Goal: Establish a government-wide program that provides a standardized approach to security assessment, authorization and continuous monitoring for cloud products and services Method: Create a do once, use many times framework that will save cost, time and staff required to conduct redundant agency security assessments 12

13 Enter FedRAMP Federal Risk and Authorization Management Program Source: FedRAMP Agency Compliance and Implementation Workshop, March 18,

14 Core Elements of FedRAMP FedRAMP Concept of Operations (CONOPS) FedRAMP Security Controls and Templates FedRAMP Standard Contract Clauses supporting: Federal Agency Buyers Cloud Service Providers (CSP) Independent (Third Party) Assessors (3PAO) Joint Authorization Board (JAB) 14

15 Responsibilities of Key Parties Source: FedRAMP Agency Compliance and Implementation Workshop, March 18,

16 Assessment Process 3PAOs initially required to comply with ISO 17020:1998 standards for inspection bodies and pass a review of information assurance competencies that include experience with FISMA and experience with testing security controls. Additionally, applicants must demonstrate technical competence in the security assessment of cloud-based information systems NOT an audit! Overall security assessment planning process and required artifacts follow RMF (SSP, SAR, POA&Ms) Independent assessment evaluates the CSP s implementation of baseline and enhanced controls 16

17 4. Where things stand today Next Steps 17

18 FedRAMP Status at 4/10/ Provisionally Authorized Cloud Service Providers under FedRAMP Initial Operating Capability (IOC) 15 Accredited 3PAOs 3PAO Accreditation being privatized, no new 3PAOs after 3/25/2013 until ~Fall 2013 ISO 3PAO organizational standard is already obsolete, superseded by ISO 17020:2012, which will become mandatory for FedRAMP 3PAOs in the future All Federal Cloud Projects must meet FedRAMP requirements by June

19 FedRAMP Status at 4/10/2013, continued FedRAMP Full Operating Capability (FOC) by Spring 2013 Possible bottleneck at JAB in granting CSP authorizations; 80 in pipeline, of which expected this year, up to 200 over 24 months (according to FCW, FedRAMP ramps up 1/8/2013); agencies can bypass JAB to grant ATO if necessary Concerns re: protest if FedRAMP contract clauses are included before they are mandatory (some exceptions exist) Agency April 2013 Portfolio Stat online data call intended to gather information on all agency cloud deployments (not just FedRAMP) 19

20 FedRAMP Status at 4/10/2013, continued Seeking information on ATO status, security controls gap analyses against FedRAMP baseline and whether/when cloud projects will be compliant ( if not, why not? ) Heightened focus on customer controls Moving forward: Open question: what consitutes significant change, and how will security across agencies sharing cloud service handle impact of a change affecting security posture? Varying incident response scenarios under FedRAMP: who s ultimately accountable in shared-service environment? Is the only what-if test seeing what happens when it breaks the first time? 20

21 Questions/Comments? 21

22 Jeff Zalusky, CISA, CIPP/G/US, PMP Director cliftonlarsonallen.com twitter.com/ CLA_CPAs facebook.com/ cliftonlarsonallen linkedin.com/company/ cliftonlarsonallen 22

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