U.S. Department of Defense sets its cloud security guidelines

Getting Your Network in the Cloud

By G C Network | May 25, 2016

Join us with Virtual Newsmakers on Saturday, May 28th at 11:00am for a YouTube Livestream on cloud computing. Virtual Newsmakers is a webcast show featuring virtual newsmakers, who are bridging…

Enterprise Networking in a Cloud World

By G C Network | May 17, 2016

Enterprises must rethink network management in the cloud computing world. This new reality is driven by the rise of software defined networking, the virtualization of everything and a business imperative…

The Game of Clouds 2016

By G C Network | May 13, 2016

In the mythical, medieval land of AWS, a civil war brews between the several noble Cloud Services over rulership. Meanwhile, across the sea, the former controlling dynasty, Traditional IT, attempts…

10 Ways to Flash Forward

By G C Network | May 7, 2016

Not to long ago I was honored to be included as a storage expert in the Dell ebook, “10 Ways to Flash Forward: Future-Ready Storage Insights from the Experts.” This…

The Future of Storage

By G C Network | April 28, 2016

A few weeks ago I had the pleasure of doing a Blab on advanced storage with Daniel Newman and Eric Vanderburg.  We covered some pretty interesting points on enterprise storage…

DevOps and Hybrid Infrastructure Synergy

By G C Network | April 3, 2016

(This post first appeared in IBM’s Point B and Beyond) The definition of DevOps emphasizes collaboration and communication between software developers and other IT professionals while automating the software delivery…

Are electronic medical records worth it?

By G C Network | March 23, 2016

The use of Electronic Medical Records (EMR) by medical professionals has increased dramatically. According to HealthIT.gov, 2015 statistics show that 56 percent of all U.S. office-based physicians (MD/DO) have demonstrated meaningful use…

Finding a Framework for Hybrid Cloud Risk Management

By G C Network | March 6, 2016

 (Sponsored by IBM. Originally published on Point B and Beyond) Hybrid cloud is rapidly becoming essential to today’s information technology processes. This is why hybrid cloud risk management has become…

Cancer, cloud and privacy shield

By G C Network | February 23, 2016

(Originally published in Dell PowerMore) For more than 10 years, the rapid rise of cloud computing has enabled an even more rapid application of cloud to genomic medicine. In fact,…

Hybrid Cloud Versus Hybrid IT: What’s the Hype?

By G C Network | February 3, 2016

(Originally posted on Point B and Beyond) Once again, the boardroom is in a bitter battle over what edict its members will now levy on their hapless IT organization. On…

Those watching federal cloud security in the defense space were pleased to learn the Defense DOD Cloud Computing Security Requirements Guide (v1) (SRG) last month. This 152-page document outlines the security requirements that Department of Defense (DOD) mission owners must adhere to when procuring cloud-based services. While the document is very thorough and is required reading if you currently, or intend to provide, cloud-based services to the DOD, I wanted to cover some of the things that stood out to me.

Information Systems Agency (DISA) released the

CSPs are not compliant, but their offerings can be. The requirements guide makes it clear that there is a distinction between a Cloud Service Offering (CSO) and the Cloud Service Provider (CSP). A CSP can have multiple CSOs, all with different security postures.

This has always been the case. However, by making this distinction, DISA has reduced some areas of common confusion. This distinction should also make it clear that utilizing a compliant infrastructure as a service (IaaS) or platform as a service (PaaS) at a CSP does not make the resulting offering compliant. The CSO itself has to be fully evaluated for the Federal Risk and Authorization Management Program (FedRAMP) compliance.

Compliance responsibility is on the prime CSP. Expanding on the last point I made: Everything you put in a CSP environment is not automatically compliant. The SRG states that, “While the CSP’s overall service offering may be inheriting controls and compliance from a third party, the prime CSP is ultimately responsible for complete compliance” (p. 3). This language gives me the sense that if mission owners want to work with a federal integrator (prime contractor) to move an application to a FedRAMP-compliant or soon-to-be-FedRAMP-compliant platform or infrastructure — and that integrator will be performing Operations and Maintenance (O&M) — they will also be responsible for the compliance of the solution and the underpinning platform or infrastructure services from a commercial cloud service provider.

In essence, the solution enabler becomes the prime CSP. This is perhaps an important nuance that may have important ramifications for the integrator and those who provide what DISA dubs commercial cloud service providers. Keep in mind that the SRG also recognizes the existence of DOD-owned and operated CSPs.

FedRAMP + controls. Because DOD systems are categorized differently from other federal government systems, the SRG lists additional security controls and enhancements that are necessary to implement for DOD systems. These controls are over and above the FedRAMP moderate baseline, and as such are called, “plus” controls. The SRG has dealt with privacy and security requirements as “overlays” to all of the FedRAMP and FedRAMP plus baseline controls.

Expanded CSP roles and responsibilities. (Appendix C-1). The SRG denotes that it is the CSP’s responsibility to provide Computer Network Defense (CND) services (all tiers) for its infrastructure and service offerings. CSPs must be willing to provide their own CND services and to be able and willing to contract for more advanced security services as required by a mission owner. Here again, a prime CSP must be willing and able to provide complete compliance, including Computer Network Defense Service Provider (CNDSP) services.

A few takeaways

While this is not an adequate summary of the SRG, this long-awaited guide has provided some clarification around DOD’s expectations from Integrators, CSPs, and DOD mission owners. The DOD has clearly laid out for Integrators and CSPs the expectations for inclusion into the DISA Cloud Service Catalog. It will be interesting to see how and if the definition of a prime CSP evolves and how the industry and government alike adapt to that distinction.

My initial reaction to the SRG is that it limits the playing field of prime CSPs that are able to comply with these requirements today. For small integrators trying to migrate applications to the cloud on behalf of the federal government, it makes the proposition riskier. For example, if small integrators move something to an Amazon Web Services or Microsoft IaaS solution, they are now responsible for the security of the application and that underlying environment. The way this is currently written, I believe that integrators will have to decide whether or not they will take the risk to take responsibility for the application and the underlying environment.

(This post was written as part of the Dell Insight Partners program, which provides news and analysis about the evolving world of tech. To learn more about tech news and analysis visit Tech Page One. Dell sponsored this article, but the opinions are my own and don’t necessarily represent Dell’s positions or strategies.)

Bookmark and Share

Cloud Musings

( Thank you. If you enjoyed this article, get free updates by email or RSS – © Copyright Kevin L. Jackson 2012)

Follow me at https://Twitter.com/Kevin_Jackson
Posted in

G C Network