Public Consultation by the European Commission. Consultation on Cloud Computing. Response from the Orange France Telecom Group

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1 Public Consultation by the European Commission Consultation on Cloud Computing Response from the Orange France Telecom Group 1/22

2 Executive Summary... 3 General views... 4 Cloud computing is an opportunity for telecom providers and for European businesses...4 Clear customers benefits: cloud computing helps companies react quickly to changes in the market, while cutting their IT costs...4 Cloud computing to ensure Next Generation Networks/Next Generation Access ROI...5 Overcoming barriers to cloud computing: security for businesses...6 Overcoming barriers to cloud computing: security for citizens...7 Europe's advanced privacy regulations need harmonisation and global reach...7 Ensuring a level playing field...8 Cloud connectivity: fixed/mobile broadband...8 Answers to consultation questions... 9 Barriers for cloud providers...9 Legislative framework...12 Embracing interoperability...14 Future Research and Innovation Programs...19 Global Solutions for global problems /22

3 Executive Summary The Orange France Telecom Group is pleased to provide input to the European Commission on the Cloud Computing Consultation. Our group views cloud computing as one of the major business opportunities of the coming years: a disruptive technology which will pave the way for significant cost reduction and increased flexibility in ICT services for companies and citizens, and increase European productivity and competitiveness. Security and privacy issues arise with cloud services and our group is particularly committed in providing our customers a high level of transparency with regard to the collection and use of their personal information and activities. A sound legal privacy framework is key to building customers trust and we recognize that current European data protection legislation, which is the most advanced in the world, has developed a legal tradition which must be maintained and further elaborated. However, Member States different approaches to implementation and enforcement oblige cloud providers to build more data centers and to offer more options for data storage locations and their protection, effectively reducing the cost savings opportunity cloud solutions provide. The EC's priority should be establishing a truly harmonized internal market for cloud computing in the European Union, thus reducing the main barriers related to divergent rules and different applications of the Data Protection Directive, consumer protection rules, privacy protection rules, fiscal regulations, copyright laws, Data Retention Directive and Lawful Interception rules among EU member States. Furthermore, the current regulation was conceived at a time when flows of personal data across Member State borders were the exception 1, while today, and especially in the case of cloud services, transfers are common and very often occur between different entities of the same cloud provider approved by national Data Protection Authorities. Facilitate cross-border personal data transfers within and outside the European Union would represent a significant reduction in compliancy costs and red-tape. The EC should carefully prevent and possibly reduce national DPAs' tendency to create additional barriers to personal data flows, and instead encourage a more pragmatic approach which ensures legal certainty for companies. Companies considering using cloud-based systems will be interested in looking at ways to distribute work across multiple providers. Therefore standardisation is crucial in order to ensure cloud interoperability and must remain industry led. Industry consortia standardisation bodies are and will continue to drive the development of standards for the cloud and very likely a revival of alliances between telecom operators will ensure the interoperability of cloud managed services. The regulators' role consists in ensuring that industry consortia guarantee open procedures, nondiscriminatory access and transparent, legally certain and balanced intellectual property rights policies. Research and innovation funds are recommended for long term cloud computing research projects, particularly in the following areas: IT and network convergence, data, content and cloud management. 1 The Data Protection Directive was introduced in /22

4 General views Cloud computing is an opportunity for telecom providers and for European businesses The impact of cloud computing on the European economy is expected to be significant and will reach most the sectors, including retail, manufacturing, logistics services and energy, and should involve start-ups as well as mid-sized companies. Traditional telecommunications providers have an opportunity to extend their role by exploring new business models, providing new services and enhancing service level agreements to sell premium on-demand connectivity solutions to cloud computing companies. Analysts predict that in the coming years, an increasingly substantial percentage of indirect revenue for telecom operators will come from premium offers marketed to the top aggregators of wholesale solutions for cloud computing companies (SaaS) 2. Europe has no choice other than to establish a European cloud and position itself as a global player by developing a web-based service industry built on a unified pan- European web-based services platform. The EC has a role to play in fostering faster integration and collaboration in order to create attractive and cost-effective webbased services for business and private users and thus increase European competitiveness in the future. Web-based services developed in Europe could easily be exported to global markets using the internet. The EC's priority should be ensuring that the rules are harmonized among Member States and promote EU values outside the union. OFTG has already developed a wide ranging portfolio of cloud computing offers and is ready to take the lead in developing a strong web-based services industry based on a truly global footprint. OFTG is present in 172 countries and boasts a vast network: its submarine network spans 10 times the circumference of the earth and it enjoys a global base of business customers, with 300,000 business sites currently connected to its network. Our group is thus clearly committed to developing cloud computing, as presented in our 2015 Strategic Plan, and we have a business target of 500 M /year in additional revenue with global cloud services. Clear customers benefits: cloud computing helps companies react quickly to changes in the market, while cutting their IT costs In the age of cloud computing, companies no longer require dedicated IT facilities on their premises to provision their employees with the resources they need. This approach already exists for software, known as Software as a Service (SaaS). Employees require nothing more than a browser to access their favourite applications from their workstations. Well-known services such as Google Mail and Yahoo! work on this principle. What s new now is that other applications besides messaging are available. 2 Gartner 4/22

5 The benefits to companies are clear: companies do not have to purchase software licences or manage updates, instead, they pay for their monthly usage. They no longer need to buy servers either. They can rent machine time and storage online. Following in the footsteps of software, data centres are disappearing into the cloud. With Infrastructure as a Service (IaaS), servers, networks and storage capacity are all accessed online. Halfway between SaaS and IaaS, Platform as a Service is mainly intended for application developers. PaaS users buy IT resources such as IaaS and a number of extra tools that help them create applications and distribute them to users. The notion of Cloud Computing covers all three types of online resources, SaaS, IaaS and PaaS. With cloud computing, companies rent instead of buying transforming their IT investment from large, upfront capital into more manageable, monthly operating costs. Each month, the company pays for what it really used. If a short-term project requires more computing power, no need to buy a server; it can be quickly and easily provisioned from the cloud. When a software application for a PC requires an upgrade, it happens in the cloud. Businesses no longer need to worry about upgrading their PCs due to a lack of memory or processing power. And with everything delivered by one IT & Network service provider, accountants don't have to manage a long list of suppliers. IT departments can focus on development projects, rather renewing licences or buying extra equipment. Furthermore, in the cloud, software publishers can provide their products to customers and manage them in a clear and transparent way. When they release an update, they install it on the server without users having to change or do anything at all. An online accountancy software package, for instance, will always be up-to- date for all users when a change occurs e.g. following a change in a tax rate. Last but not least, the environment benefits too. Companies can reduce their carbon footprint by ensuring that their cloud computing service provider operates environmentally friendly data centres that use as a little energy as possible and emit the least amount of CO2 Cloud computing to ensure Next Generation Networks/Next Generation Access ROI The European Commission has a key role to play in accurately stimulating the objectives of the Digital Agenda, especially for cloud computing, with the aim of achieving a truly level playing field between all of the internet ecosystem players - including pure internet players. The diversity of current national rules is becoming a real threat to the Digital Agenda's objectives. In order to better concentrate investments on NGN/NGA roll out, the EU should take measures to apply the same rules on transparency, openness, personal data protection and VAT rate harmonization throughout the 27 Member States and should avoid taxes/levies on telecoms. Addressing these environmental and economic barriers would create growth and jobs in Europe. 5/22

6 Overcoming barriers to cloud computing: security for businesses According to independent research, the three biggest barriers preventing businesses from adopting cloud computing are security, availability and performance. Availability and performance are difficult to evaluate because they depend on several factors including cloud providers geographical location, connectivity and technical solutions. Security is even more difficult to evaluate, since it is a constant objective achieved by an appropriate combination of policies, processes, people and technology. Security is, however, such an important issue for business customers that cloud providers have started to compete on the market by offering advanced features which ensure infrastructure security in order protect users from external (firewalls, IPS, etc.) and internal (systems segregation) threats alike; advanced data lifecycle management controls are implemented for data creation, modification, archiving and destruction; user access rights: control over who accesses what, with what level of permission; supervision of and reaction to incidents: proactive supervision, Information Technology Infrastructure Library processes and clear escalation tables. Certifications also play an important role, and well-established security and quality management standards now exist for both networks and datacenters such as SAS-70 Type-II, ISO 20k and ISO It is also important to note that for small and mid-sized business with limited IT and security knowledge and resources, using cloud offers can in fact increase their level of security. Clouds solutions make the provision of dynamically scalable and virtualized resources widely and cheaply available, drastically reducing the costs of disaster recovery and business continuity planning and thus creating opportunities for small and mid-sized companies to enjoy a level of protection which was previously reserved for large corporate budgets. Figure 1 Cloud computing deployment models. It is also important to mention that, as shown in 6/22

7 Figure 1, there are several cloud models which offer different degrees of customer or cloud provider involvement in security management. Business customers can use several cloud models at the same time and adapt cloud models to suit their specific needs: sensitive data can be hosted in private clouds while less sensitive data can be hosted in public clouds. Private cloud solutions are usually the entry point for companies, which then choose community cloud, hybrid cloud or even public cloud solutions in line with the degree of security needed and the associated planned cost reductions. Overcoming barriers to cloud computing: security for citizens The main barrier to the take-off of mass market cloud applications is still believed to be people's concerns about the privacy and security of personal data. Despite this, online and photo storage services are currently the most well established mass market cloud applications. Many products in the financial services sector have already been traded electronically online for some time, and a new generation of customers who have grown up with and mobile phones are selecting their banks and insurance products based on the quality of their internet services instead of their local presence. This is a sign that the European ICT industry has reached a reasonable level of maturity in managing personal data. It is clear that existing European standards for security and data privacy will also apply in the cloud. It will be EU policy makers' role to ensure that their enforcement also applies to non-european cloud providers. New privacy and security issues which arise for cloud applications must be addressed proactively through an open dialogue among all relevant stakeholders and based on the well-established Data Protection Directive principles. Europe's advanced privacy regulations need harmonisation and global reach Back in 1995, the Data Protection Directive (DPD) created a high level of protection for the European population s personal data on the basis of general principles such as legitimate purpose, proportionality, accuracy, accountability, consent, limited use of personal data, individual access, which significantly advanced the notion of privacy protection and supported the development of standard privacy practices throughout Europe. Today, the DPD still plays a crucial role in providing Europe s population with a high level of personal data protection. The DPD is based on sound and technologically neutral principles which remain valid, and which can be applied to cloud computing applications without major revisions. As the EC 3 has also highlighted, however, DPD enforcement of is not satisfactory and there is a lack of harmonization of the current directive among Member States, which creates an unbearably complex situation for European individuals and businesses. The efforts of the EC should therefore be focused on harmonizing the application of DPD principles within the EU. 3 See EC COM(2010) /22

8 OFTG operates in multiple Member States and has to notify each national data protection authority and comply with non-standardized notification systems. Applying the DPD concept of mutual recognition amongst Member States, for example, could reduce such practical drawbacks. Ensuring a level playing field Given that internet has erased borders, the EC should recognize that international co-operation and global consensus on privacy issues are vital for the protection of the European population s personal information and in order to create fair competition for businesses. In particular, the EC should increase efforts to enforce European privacy law on U.S. cloud providers. In this regard, we support the work of international conventions on privacy standards such as the one that led to the Madrid Resolution approved in 2009, and more recently the Jerusalem Declaration calling for an intergovernmental conference in 2011 or 2012 to negotiate a binding international agreement which would guarantee respect for data protection and privacy and facilitate cross-border coordination of enforcement efforts. We would appreciate a greater commitment by the EC to taking a leading role in this global approach. Furthermore, we would like to remind that the EU regulatory framework is not neutral in respect of technology or business model: discriminatory burdens are placed on providers of electronic communication services, i.e. the e-privacy Directive, and this makes impossible a fair competition with non-electronic communication companies providing similar services. Cloud connectivity: fixed/mobile broadband The Internet and VPN provide connectivity for cloud computing services between end-users and services providers. VPNs are managed connectivity services provided by a telecom operator which can support specific and guaranteed service quality levels, while Internet connectivity is currently based on a best effort service level. Work is in progress on standards for end-to-end quality delivery across fixed/mobile networks for services such as those provided by any cloud computing configuration (private, public, hybrid). The regulatory framework which applies to fixed/mobile cloud connectivity should be proportionate to applications allowing the new business models to develop in line with the security levels needed for each specific application. 8/22

9 Answers to consultation questions Barriers for cloud providers 1. If you are a provider of cloud services, please describe your offer. What kind of barriers do you face in providing your cloud computing services within the EU? Elsewhere? Orange France Telecom Group currently offers a wide ranging portfolio of web-based cloud computing services in both the B2B and B2C markets. Our group's global footprint allows us to provide cloud offers which fully comply with local legislation and are in line with our business customers' high performance expectations in order to ensure optimal daily operations which are incompatible with the transport delay created by remote data centers. In the long term, we expect cloud offers to become global web-based services which transfer confidential data across-border even more frequently than they do now, meaning that the cost of compliancy will become a barrier, especially in the EU. The main barriers to providing cloud computing services are related to the divergent rules and implementations of the Data Protection Directive and privacy protection rules. Cloud computing services also share with all the other categories of services the long list of very well-known single market barriers created by divergent applications of laws and regulations among EU Member States, including consumer protection rules, fiscal regulation, copyright laws, Data Retention Directive implementation and Lawful Interception rules. Cloud offers for businesses Orange Business Services (OBS), the leading global integrated communications service provider for businesses, which is part of the France Telecom group, offers a full range of cloud computing offers which range from public and multi-tenant versions to fully private clouds which address specific security and compliance concerns. With the support of our Flexible 4 Business (F4B) alliance partners, Cisco, EMC and VMware, we provide comprehensive and effective infrastructure using best-of-breed technologies. OBS also works with leading global software providers such as IBM, HP and Microsoft. Recently, Orange Business Services signed an agreement with Microsoft to distribute the Microsoft Online Services suite ( and instant messaging, shared space, conference calls) in 21 countries to companies of 150 employees and more. Businesses will pay between 5 and 10 per user for these services. OBS has designed a comprehensive range of IaaS under the Flexible Computing Services banner, organized as follows and targeting medium to large businesses and national and multinational accounts which are seeking to outsource all or part of their IT infrastructure. 9/22

10 Flexible Computing Premium allows large companies to outsource part or all of their IT infrastructure. OBS offers a completely customizable virtual server architecture, scalable to several hundreds of virtual machines, available in customermanaged or fully-managed mode. OBS commits to SLAs up to 99.9 and provides detailed reporting for visibility of performance and use of infrastructure. Flexible Computing Private is a highly secure and customizable dedicated cloud computing infrastructure. It is accessed through the dedicated private OBS network and enables temporary bursts in traffic and quick implementation of additional resources. Flexible Computing Private can be hosted in our data center or your premises. Figure 2 : Orange Business Services Flexible Computing Services OBS also offers in-the-cloud Web and security, which provides comprehensive and immediate protection. Web Protection Suite is a powerful anti-malware and URL filtering solution, powered by Scansafe, which enables effective control of Web traffic, including SSL encrypted communications and remote access through laptops. By using a scalable, global, cloud-based platform and powerful web portal, our customers security policies can be instantly applied to all users and enforced at all times. Figure 3 : Orange Business Services offers based on cloud computing 10/22

11 OBS also works with popular cloud providers for its VPN Gallery service to give business customers a dedicated virtual LAN (VLAN) inside those providers' data centers, which will enable OBS to guarantee performance metrics. Cloud Ports is another OBS cloud offer which focuses on optimizing hybrid cloud environments. Within our cloud computing portfolio, Applications Stores represent a unique value proposition and business opportunity for controlling and monetizing the applications running on our network. Our challenge is to become a recognized and trusted third party which aggregates and distributes business applications delivered as a service through an online marketplace. In so doing, we will also simplify our customers' operations because we will be responsible for software licensing, providing a single unified bill that includes delivery of the application and its support. Moreover, providing an application store will also emphasize the value of the network when accessing on-demand applications, and will create incremental revenue opportunities which the likes of Google, Amazon or Yahoo are unable to achieve. In addition to the catalogue of cloud offers, OBS has announced its partnership with SITA, the air transport IT specialist, to build a managed cloud infrastructure which will deliver secure and highly available cloud computing services to the air transport industry and multinational businesses around the globe. The cloud computing infrastructure will be based on six seamlessly interconnected Tier III+ and Tier IV data centers on five continents, in Atlanta, Frankfurt, Johannesburg, Singapore, Hong Kong and Sydney. Each data center will cover its regional hemispheres and the centers will be interconnected via Orange s high-speed MPLS network. Orange Business Services and SITA will use this infrastructure to offer their individual portfolio of cloud computing services, encompassing infrastructure as-aservice, platform as-a-service, desktop as-a-service, and software as-a-service. Andromède is a joint proposal between Orange Business Service, Dassault Systèmes and Thales to the French State in the context of a government initiative for the digital economy (Investissements d'avenirs). In this context, the three industrial partners are proposing massive investments in partnership with the government (several 100m altogether) to create a French Cloud Computing provider using the public and virtual private deployment mode of the Infrastructure as a Service. We believe that the French economy could benefit from such a project by several means : savings generated by using a native Cloud Computing infrastructure by which offers a large-scale effect; creating a French/European alternative to existing IaaS players, guaranteeing data traceability; strong security focus of this infrastructure. Orange is fully committed to the success of this project which is naturally part of Orange's global Cloud Computing strategy. Since Andromède is clearly destined for European use, it would be beneficial for all parties to include it in the collaborative frameworks that are being put in place at the EU level. Mass market cloud offers OFTG provides mass market cloud services, mainly photo storage services and accounts. These services are currently offered as free options with access subscriptions, are fully compliant with privacy regulation and are locally managed. 11/22

12 There are many reasons why we are reluctant to further expand our B2C cloud services geographically and as commercial stand-alone services, and we share with other companies the list of notorious practical obstacles which apply to any kind of cross-border online service. This list includes the cost of compliance with different national privacy and consumer protection laws and fiscal regulations, the costs of providing customer care and handling customer complaints in several languages, the risk of fraud and nonpayments, copyright law fragmentation, national lawful interception rules and the diverse economic realities that do not allow us to set a unique price. Creating an international standard based on a unified and consistent approach to online privacy would benefit web users, who would enjoy the same protection wherever a website is based, and would ensure a level playing field for businesses competing with the North-American market leaders. This type of global approach would greatly reduce the privacy compliancy costs of developing borderless technologies such as cloud computing. The EU should be more proactive in extending the reach of EU principles to other nations and should take leadership of initiatives such as the ones adopted under the Madrid resolution on International Standards on the Protection of Personal Data and Privacy. The current VAT system is clearly an obstacle to the development of cross-border web services based on cloud computing. The implementation of a European harmonized and reduced VAT for online services would not only reduce the costs of managing cross-border trade but also remove a source of competition distortion. Reducing the compliancy costs of online cross-border payments is another key target for regulators. Legislative framework 3. Do you think there are updates to the current EU Data Protection Directive that could further facilitate cloud computing while preserving the level of protection? If yes, please describe. There are updates to the current Data Protection Directive that which could facilitate the adoption of cloud computing. As we highlighted in our response to the public consultation in January 2011, we believe that the DPD revision provides an important opportunity to reduce the complexity and costs associated with the current rules governing the international transfer of personal data inside and outside the European Union. Cloud service providers are increasingly organized on a global scale and apply security standards that are independent of the geographical location of data processing. Regulators should find solutions which guarantee the high standards of personal data protection that European individuals enjoy while accommodating the need to simplify 12/22

13 rules on the trans-border flow of personal data within a corporate group and to the companies associated with these groups and or subcontractors. We therefore support introducing the concept of mutual recognition amongst Member States, promoting the use of standard contractual clauses for the transfer of personal data and recognizing the concept of group of companies within a network of companies and their third parties. 4. Are you aware of specificities in member States data protection rules, or other legislation, that prevent you from using/providing cloud services within the EU? If yes, please detail. Yes, we are aware of cloud computing applications for highly sensitive data that require specific authorizations from national authorities. Recently, our group obtained specific authorization from the French government for a cloud computing application in the healthcare sector based on very robust regulations 4. Our service called Imagerie Médicale Partagée provides access to personal medical images stored in the cloud. The government authorization offers customer a guarantee that their highly sensitive personal information is handled in full respect of confidentiality, security, integrity and access control. Introducing different levels of regulations which are proportionate to the sensitivity of the applications helps generate customer confidence, and a global approach could reduce costs and provide an opportunity to create economic growth and jobs within Europe. 5. From your perspective, would it be useful if model Service Level Agreements or End User Agreements existed for cloud services so that certain basic terms and conditions could easily be incorporated into the contractual agreements? If no, why not? If yes, further thoughts about how this might/should work. Customer relations can be improved by the use of plain language in End User Agreements and clarifying legal implications linked to the use of a particular service. Providing too much detailed information annoys customers, who tend to skip daunting EUAs full of legal jargon based on regionally incompatible privacy rules. EUAs may benefit from the development of models based on plain texts and concise documents to help customers make informed decisions. Nevertheless, standard texts are perceived as annoying and only mechanically acknowledged. We therefore appreciate the EC s wish to encourage voluntary policies and Codes of Conduct that can help deliver solutions which meet customers privacy expectations. 4 Art. L of the French Public Health Code. 13/22

14 SLAs should remain the result of customer/provider negotiations. Cloud computing technology requires application-aware service provider networks which can automate bandwidth and QoS shaping as needed and provide integrated services such as customer care, billing and provisioning. Only advanced ISPs can automate their processes and make the network responsive to changing traffic demands. SLA models tend towards stiff network features and pre-determined minimum levels of quality rather than simplifying the range of available options. Embracing interoperability 6. Please describe interoperability or (data) portability issues you have encountered when using/providing cloud services or are otherwise aware of. OFTG shares the EC's view that ICT Interoperability is a key issue and we strongly encourage the fulfilment of Action 5 of the Digital Agenda 5, particularly for cloud applications. Interoperability issues Companies considering using cloud-based systems will be interested in looking at ways to distribute work across multiple providers. Our understanding of interoperability is the capability of different cloud services environments (cloud providers, cloud services, cloud infrastructure) to seamlessly work together, transfer workloads, etc. Most of the interoperability issues at the IaaS (infrastructure) layer are already addressed. There are now commonly-supported formats, such as Open Virtualisation Format (OVF) for virtual machines. One can export its virtual machine from one service and import in into another. Platform (PaaS) and Software (SaaS) services are sector-specific and therefore their interoperability will depend on the existence or inexistence of data format standards before these services are provided in the cloud (e.g., all engineering CAD/CAM drawings can be exported in IGS format). Portability issues Companies considering using cloud-based systems will be interested in not being locked into providers and in being capable to easily switch from one provider to another. Our understanding of portability is the capability of cloud services consumer to switch their data and services from one provider to another avoiding incompatibility issues. One of the main current obstacles to portability is the lack of open application programming interfaces (APIs) for interactions between cloud services providers and cloud services consumers. Once cloud consumers establish a commercial relationship with a cloud provider, they are substantially forced to use the provider s private 5 Digital Agenda, "Key Action 5: As part of the review of EU standardisation policy, propose legal measures on ICT interoperability to reform the rules on implementation of ICT standards in Europe to allow use of certain ICT fora and consortia standards." 14/22

15 interfaces to inter-exchange information and data on subscribed services. This clearly generates consumer lock-in with a specific provider, since it will be difficult and costly for a consumer to switch from one provider to another. ETNO thus believes that the industry (i.e., cloud services providers) is on the way to ensuring native interoperability and portability (see response to Q2 below on going initiatives on standards support interoperability across clouds and portability of data). It is also OFTG sunderstanding that the federation model in place is the way to address and solve interoperability and portability. It is important to understand, though, that federation (for the sake of interoperability and portability) is not a simple task, potentially implying additional costs (higher prices) and presumably not being always feasible to offer an immediate and/or automatic response (e.g., two cloud services may be interoperable, but transferring workloads from one to the other may require manual activities and human intervention). 7. Which existing or emerging standards support interoperability across clouds and portability of data (from one cloud to another)? Please list and describe. Most global standardization bodies now have launched dedicated cloud working groups, communicating through white papers and proposing new standards. To our knowledge, some of the most active currently are: Cloud Security Alliance deals with security recommendations and standards for critical areas in cloud computing; ITU-T: Cloud Computing Telecom Prospective focuses on use cases, architecture and benefits for telecoms operators but also cloud standard recommendations; ITU-T FG (Focus Group) Cloud aims at assessing standardization themes carried out within relevant SDOs (standard development organizations), to identify gaps and to propose and share with such SDOs a roadmap aimed to fill such identified gaps; Global Inter-Cloud Technology Forum focuses on world-wide inter-cloud use cases; Distributed Management Task Force (DMTF) focuses on cloud management (architecture and use cases), governance and integration into IT and business processes and also advocates the OVF as a standard to enable interoperability within virtualised environments; W3C encourages the emergence of HTML-5 with new multi-device web applications functionalities; IETF focuses on network related cloud topics; 15/22

16 Open Grid Forum (OGF) works on an Open Cloud Computing Interface (OCCI) for IaaS. Many European cloud players are involved in these workgroups and some European or local spin-offs are appearing, such as the French branch of the Cloud Security Alliance. The European Commission is funding the SIENA initiative which also targets the adoption of cloud standards in distributed computing [see figure below]. SIENA ISO: SC38, SC27, SC7 Cloud Computing IEEE: WGs P2301 and 2302 OpenStack DMTF: Cloud Management, Cloud Audit Data Federation ITU-T: Focus Group on ETSI: Cloud WG M a n a g e m e n t The Open Group: Cloud Computing Reference SNIA: CDMI Open Compute Project Apache: LibCloud, Nuvem DeltaCloud, Hadoop Cloud Security Alliance ODCA Currently one of the most relevant standardization activities is carried out within DMTF (Distributed Management Task Force) CMWG (Cloud Management Working Group), which aims to specify open APIs standardising interactions between cloud services providers and cloud services consumers. Such APIs cover the whole lifecycle of managed cloud resources, such as discovery, configuration, deployment, operation, monitoring and security. The APIs are applicable in the context of both private and public clouds and enable interoperability between different clouds. Supported functionalities are upload, download, instantiation, deployment and operation of constructs, such as (virtual) machines, volumes, networks, etc. The particular value of this standardization activity is that cloud consumers will be able to seamlessly switch from one cloud provider to another for utilizing the same cloud services with no re-design or coding needs, thus exploiting real interoperability amongst different cloud services providers. 16/22

17 OFTG is convinced of the importance of such standardization initiative and we are actively participating in the CMWG in collaboration with worldwide vendors, such as Microsoft, Oracle, VMware and IBM, to achieve vendor and technology-neutral APIs. The main existing or emerging standards that support interoperability across clouds and portability of data are: For IaaS services: DMTF CMWG is going to release a first Cloud Management API (Application Programming Interface) specification (by end-2011). In addition, DMTF s Virtualization Management and OVF will facilitate the virtual environment management portability of applications across clouds. For portability of data in SaaS: some standards such as (POP Post Office Protocol, IMAP Internet Message Access Protocol), XML (extensible Markup Language) feeds (RSS Really Simple Syndication, ATOM Publishing Protocol and Syndication Format), XQuery (XML Query Language), Open Document Format, WebDav (Web-based Distributed Authoring and Versioning), FTP (File Transfer Protocol), and web 2.0 open API specifications (e.g., Facebook and LinkedIn) have demonstrated that data-portability is possible. For bulk data access: SNIA (Storage Networking Industry Association) CDMI (Cloud Data Management Interface) can be used for data portability across clouds 8. Which are the most important standards that are currently missing but which you feel are necessary to ensure interoperability and portability? Please describe in detail the aspects they should cover. SaaS With respect to SaaS, domain-specific application data interchange standards would be needed in the way of financial services (XBRL extensible Business Reporting Language). Another option could be to make the Cloud Providers to offer open interfaces to access and retrieve application data. One of the main current gaps in cloud standards is related to the possibility to utilize open APIs to standardize interactions between cloud services providers and cloud services consumers. DMTF (Distributed Management Task Force) is working to address this gap with the specification of an open API able to standardize interactions between cloud services providers and cloud services consumers. With this API) cloud consumers will be able to seamlessly switch from one cloud provider to another and utilize the same cloud services, exploiting real interoperability amongst different cloud services providers. PaaS With respect to PaaS services, there is a lack of standardised cloud-aware development frameworks and scalable application models. Open specification of multi-language APIs and technologies would be needed. IaaS With respect to IaaS cloud, the rapid growth of virtual infrastructures underlying cloud computing services has driven the requirement for standard management 17/22

18 tools. It is also a key requirement for solutions interoperability between platforms managed by different telecom operators. Many technical solutions are available on the market and, in the absence of standards, the risk is that dominant players emerge on the back of aggressive Internet strategies, with the potential of devaluing industry s own approach. Another issue which is specifically interesting for IaaS cloud service providers is that usually they cannot easily switch between vendors providing data center management solutions. Once a vendor is selected, providers must utilize such vendor s product stack to efficiently manage virtual resources (e.g., CPU, storage and networking), virtual data centers or virtual organizations. The need is for cross-platform and cross-technology administrative management APIs which can enable a cloud service provider to perform administrative tasks (e.g., create a new customer or a new site ) independently from the underlying utilized platform [see figure below]. API Application Portal OSS/ BSS API Platform Portal API Infrastructure Portal Our recommendation is for the European Commission to support the current work in standardization bodies in which the European industry is actively working towards achieving interoperability between virtual infrastructures and to establish a standard cloud management interface that will allow users to shift from a technology-centric to a usage-driven IT approach. Security in the cloud A final issue of importance is that of security in the cloud. A globally recognized certification process and toolset allowing both cloud customers and providers to assess services deployed end to end on a cloud infrastructure is still lacking. The problem of assuring a secure service is important both for the end customer who will actually use the service and for the infrastructure provider who has to be ensured on the security of the deployed service. Conclusion OFTG strongly believes that standardization is crucial to ensure cloud interoperability and must remain industry led. Industry consortia standardization bodies are and will continue driving the development of standards for the cloud. It is also very likely that 18/22

19 a revival of alliances among telecom operators will ensure cloud managed services interoperability. Any role for regulators would consist of ensuring that industry consortia guarantee open procedures, non-discriminatory access and transparent, legally certain and balanced intellectual property right policy. Future Research and Innovation Programs 1. Which are the most important technical aspects of cloud computing that researchers are currently working on? Please explain the importance of each concrete example. The most important technology evolution for the cloud architectures and services is on advanced IaaS paradigms, including investigation of the technical feasibility of SaaS and PaaS solutions and on the management of multi-technology and multitenant clouds, based on different virtualization technologies, also enabling hybrid scenarios where resources are allocated both on customer premises and in the service provider datacenter. Advanced IaaS paradigms Resource allocation, typically optimal placement of virtual machines in multi-tenant contexts under several SLA constraints (performance, energy consumption), is a core feature of cloud IaaS (Infrastructure-as-a-Service) middleware that stirs up many research activities (especially in the academic grid computing community which is largely evolving towards cloud computing). IT and network convergence is a major research topic in cloud computing. The objective is to be able to provision and manage seamlessly IT (CPU, storage) and network resources. Technical feasibility of PaaS solutions Platform-as-a-Service (PaaS) that seeks to provide environments to develop, test, deploy and manage applications in the cloud is emerging as an important and challenging topic. The ambition to manage the complete application lifecycle in the cloud is very challenging and needs close interaction with underlying core IaaS works. In addition, there is a growing interest on technologies which could be enabling for 3 rd parties in terms of development and deployment tools for applications that could use in a more efficient way the cloud resources, and in terms of services, tool supporting the 3 rd parties business (e.g., business process modeling, registry and repository, application monitoring, SLA management) Management of multi-technology and multi-tenants clouds Interoperation -- between and the federation of -- multiple clouds and cloud management generally is a hot topic in research and standardisation (APIs, protocols). The area of data and content management (also known as personal storage cloud ) where content is distributed, replicated, synchronised between data centres and users devices, including mobile devices, is also a major research topic. 19/22

20 2. Beyond these, do you see technical problems/limitations of current cloud service offerings that will require further research in the coming years? [3 if yes, please elaborate] Yes, OFTG believe that many limitations and technical problems still remain. Current cloud computing infrastructures, platforms and services are far from fulfilling the promises of cloud computing. A major technical challenge in coming years is software design for virtualization. This encompasses the design of applications/services and platforms/infrastructures able to cope with multi-tenancy (the fact that hardware and software platforms are mutualised between multiple clients/services) and elasticity (the continuous scale up and down to accommodate services load changes). For example, elasticity is a hard multi-constraints problem where cloud infrastructures are generally able to answer partially to dynamic resources request from applications they host not to mention other optimization constraints such as energy management. Autonomic (selfmanagement) technologies are used and extended in this context. Another major technical challenge that needs further studies is dependability, which encompasses reliability/resilience (e.g., fault tolerance) and security (e.g., identity, privacy, access control). Indeed, cloud computing offers huge business opportunities but also exhibits major risks and vulnerabilities by centralizing data and services in mega data centres which represent single points of failure where single attacks or crashes may have dramatic cascading effects (as practically experienced by some major cloud providers in lasts months). Cloud networking is another challenge from IT and network convergence (central self-provisioning of both IT and network resources) to full network-as-a-service offers. This includes advances in networks such as network virtualisation (a pillar of Future Internets) to would allow for real end-to-end SLA cloud management. 4. Should public R&I funding be used to establish prototypes of new cloud infrastructures? [5 - If yes, please describe types of projects/prototypes you would see as useful, and explain why] Yes, for those which require longer-term research. OFTG has observed that most research sponsorships target shorter-term software development efforts. It would be interesting to have a test bed designed to support research into different aspects the design, provisioning and management of services in a federated cloud environment. A collaboration community could be also created in order to share best-practices. Suggested projects/prototypes could include: Federated Cloud Adoption: research on interoperability and portability which allows the progressive evolution from a company private data centre to a private-hybrid cloud and finally to a public cloud. Interoperability and portability demonstrative test beds; 20/22

21 Best Practices and Benchmarking of Cloud Technologies: cloud services architectures and technologies comparison and benchmarking. Test beds for evaluating the research results are described in Q3; Cloud-aware Application Design Patterns: project/prototype to demonstrate highly distributed and fault tolerant application design patterns for federated clouds. 365 days x 24 hours service guarantee is critical for many services. Global Solutions for global problems 1. What are the most important Cloud Computing problems that have to be discussed at global level? Please list and explain. We consider there are several key topics important for developing this market that need to be addressed at a global level: Interoperability to prevent cloud customers to be locked-in by cloud providers, by cloud providers not to be locked-in by cloud technology producers; Openness of cloud technology so as to allow the ecosystem to develop added-value tools and services above proprietary platforms; Energy consumption and green considerations; Competitiveness; Fostering commitment from the EU authorities, citizens and economy, supporting those providers who invest in the EU The above topics could be addressed via: Standardisation: Interoperability / Federation Portability Regulation: Data location Intellectual property Auditability Taxes Certification: Most of the areas suitable for certification are already covered by current standards: Security: ISO27001 Service Management: ISO20000 IT Governance: ISO /22

22 Additional areas are suitable for assessment: Quality of service (QoS) and performance. 2. Which would be the right fora/approaches to tackle them? Please expand. Standardization organizations are best placed to tackle openness and interoperability. They could be supported by political entities and possibly regulations. Green cloud issues can be pushed by political entities, such as the OECD. Global and governmental discussions should continue on global ICT policy issues and include cloud providers (IT players, telecoms operators and others) and cloud users. 22/22

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