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Privacy Issues of Cloud Computing in the Federal Sector
- 1. Privacy Considerations in Cloud Computing Lewis Oleinick, CIPP/G Chief Privacy and FOIA Officer Defense Logistics Agency Emerging Privacy Issues
- 2. Disclaimer The views presented herein are my own and do not represent the views of DoD or the Defense Logistics Agency.
- 5. What is “Cloud Computing?” Cloud computing is a model for enabling convenient, on-demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction. This cloud model promotes availability and is composed of five essential characteristics, three service models , and four deployment models . From: http://csrc.nist.gov/groups/SNS/cloud-computing/cloud-def-v15.doc
- 6. A Picture of “Cloud Computing”
- 9. Risks for Each Deployment Model
- 10. Cost/Benefit of Cloud Computing Models
- 11. Privacy Policy Issues in the Cloud Data Security Privacy Act E-Gov’t Act (PIA) Breach Reporting International Privacy Law Federal Records Act
- 12. Some Technology Solutions for Security in the Cloud * Encrypted Swap / No Swap Encrypted File Systems Encrypted Data Transit (In/Out) Secured, Fit for Purpose Machine Image * Ideas From July 15, 2009 Nat’l Def. Univ Presentation on Cloud Computing Architectures by Hal Stern , Vice President Global Systems Engineering, Sun Microsystems.
- 13. Tim O’Reilly on Personal Information “ The prospect of ‘my’ data disappearing or being unavailable is far more alarming than, for example, the disappearance of a service that merely hosts an aggregated view of data that is available elsewhere say Yahoo! search or Microsoft live maps.”
- 14. Possible Structures of a Public “Cloud” or, “Dude! Where is my Data?” What you think you are getting. What you may actually be getting. Trans-border data flow of personal information? To India, Malaysia or China?
- 25. Where is this all going? Data Collection Web 2.0 Cloud Computing Logistics Info e-Discovery Where is privacy?
- 27. Lew Oleinick, CIPP/G Chief Privacy and FOIA Officer Defense Logistics Agency Questions
Notes de l'éditeur
- One of the problems with “Cloud computing” is that the term itself means different things to different people. The reason for this confusion is that there are lots of different definitions for what “cloud computing” is. Here is the Wikipedia definition.
- Here is the NIST definition of “cloud computing.” My presentation’s notes contain the URL for it. For geeks, I think the first sentence of this definition is a pretty clear one for what constitutes “cloud computing.” We’ll discuss the delivery and deployment models later, but I want to touch on the “essential characteristics” of cloud computing. They are as follows: Essential Characteristics: On-demand self-service. Broad network access. Resource pooling. The provider’s computing resources are pooled to serve multiple consumers using a multi-tenant model, with different physical and virtual resources dynamically assigned and reassigned according to consumer demand. There is a sense of location independence in that the customer generally has no control or knowledge over the exact location of the provided resources but may be able to specify location at a higher level of abstraction (e.g., country, state, or datacenter). Rapid elasticity. Measured Service. From http://csrc.nist.gov/groups/SNS/cloud-computing/index.html
- For non-geeks, I think this is a better explanation.
- Tim O’Reilly, web-guru and coiner of the term “Web 2.0,” has defined 3 types of “cloud computing” Infrastructure as a Service – virtual machine instances Platform as a Service – this is where the virtual machine is hidden behind higher-level APIs Software as a Service – Google docs Mr. O’Reilly’s three “types” of cloud computing matches the NIST definitions three “delivery models.”
- The NIST Model has four (4) cloud Deployment Models Private cloud . The cloud infrastructure is operated solely for an organization. It may be managed by the organization or a third party and may exist on premise or off premise. Community cloud . The cloud infrastructure is shared by several organizations and supports a specific community that has shared concerns (e.g., mission, security requirements, policy, and compliance considerations). It may be managed by the organizations or a third party and may exist on premise or off premise. Public cloud . The cloud infrastructure is made available to the general public or a large industry group and is owned by an organization selling cloud services. Hybrid cloud . The cloud infrastructure is a composition of two or more clouds (private, community, or public) that remain unique entities but are bound together by standardized or proprietary technology that enables data and application portability (e.g., cloud bursting).
- This great slide is from Dr. Ron Ritchey, at Booz Allen Hamilton, from a presentation he gave to NIST called “Governance Considerations for the Cloud,” at the October 2009 Security Content Automation Protocol (SCAP), 5th Annual IT Security Automation Conference Cloud Session entitled “ Using SCAP to Mitigate Risks in the Cloud ” It describes some of the risks for each of the NIST cloud deployment models.
- Graph from “Cloud Computing and the DoD CIO Storefront,” by Dan Risacher of the DoD CIO Enterprise Services and Integration Office, presented on Sep. 21, 2009 and available at slideshare.net. The way to read this graphic is that the upper-right quadrant (Dedicated Mission Capabilities) is the most costly and takes the longest to implement of all technologies. As you move down and to the left the costs decrease as does the time to complete the implement the project.
- Data security Cloud computing data centers consolidate multiple organizations -- become attractive targets for hackers. Federal Information Security Management Act (FISMA) (44 U.S.C. § 3502) – “Information Security” requirement on Gov’t and Contractors One key point that needs to be addressed in “cloud computing” – at least for Federal Gov’t activities -- is the Privacy Act nexus with FISMA. Specifically, the Privacy Act authorizes disclosure of PII “to those officers and employees of the agency which maintains the record who have a need for the record in the performance of their duties.” Without establishing specific access controls for information systems located in such shared workspaces, or “clouds,” it is not possible to ensure accurate tracking of who has had access to the PII and therefore it is not possible to state that only those “officers and employees of the agency” with a “need to know” have been provided access to those records. Therefore, an individual PIA should be conducted on each information system processing PII contained in such shared spaces or clouds. Privacy Act Cloud computing environs must comply with Privacy Act – (e)(10)’s requirements and its relation to access controls have been discussed above. Do cloud computing providers agree to use/not use data they host in compliance with the Privacy Act? How are the providers bound? TOS? Contract terms? E-Gov’t Act (PIA) Who should complete Privacy Impact Assessments for cloud environments? For Gov’t owned? Contracted? “Free”? Breach Reporting Who is responsible for providing PII breach reporting notifications? Credit monitoring? Which jurisdiction/domain is the provider in? International Privacy Law Data protection is a human right in EU and other Int’l Jurisdictions Directive 95/46/EC Federal Records Act Is the information in the cloud an official government record? Does it have a record retention policy covering it? These issues must be addressed in consultation with your Records Management Officer.
- Mr. O’Reilly’s quote sums up the public’s concerns with cloud computing “safety.” I think it could be expanded as summing up the public’s concerns with other “hidden” services such as Deep Packet Inspection, etc., where the “beneficiary” of the service has no understanding of the underlying technology’s threats, safeguards, or potential benefits.
- So, you want to implement a cloud computing initiative. What jurisdiction’s statutes, regulations, etc., apply? U.S.? E.U.? A.P.E.C.?
- There are already several examples of cloud computing being used in the Federal Gov’t, Private Sector, and by the “bad guys.” I hope to give you a flavor of these examples with short summaries in the following slides.
- Of note to Federal Agencies is OMB’s Pass-back Language requiring Federal Agencies to evaluate all new IT investments against cloud computing alternatives for the FY 11 budget submission and to evaluate all IT investments involving a significant change against cloud computing alternatives for the FY 12 budget submission. Of course, I have not actually seen OMB’s Pass-back Language, because to disclose that pass-back language would be against OMB policy.
- New simulation results were needed for a presentation. All computational resources were either committed or did not support the environment needed for STAR computations. Technology developed by the Nimbus team at the U.S. Dept. of Energy’s (DOE) Argonne National Lab, allowed the STAR researchers to dynamically provision virtual clusters on commercial cloud computers and run the additional computations just in time. With cloud computing, a 100-node STAR cluster can be online in minutes. In contrast, Grid resources available at sites not expressly dedicated to STAR can take months to configure. Overloaded STAR resources were elastically ‘extended’ by additional virtual clusters deployed on Amazon’s EC2. The run used more than 300 virtual nodes at a time to complete STAR computations just in time.
- LMS = Learning Management System DOI’s NBC is focused currently on it’s CPU and storage Infrastructure-as-a-Service offerings. It is developing Acquisition and HR Software-as-a-Service offerings. Their LMS would likely need to have a PIA and Privacy Act System of Records Notice.
- U.S. Army needed a tool to track potential recruits who visited its Army Experience Center -- a new, state-of-the-art recruiting facility that allows prospective recruits to undergo simulated experiences of an Army soldier in a casual and non-threatening environment. Recruiters required the ability to track potential recruits based on their preferences and activities at the Army Experience Center. The speed to implement of 3 months is the key on these two projects.
- Not only the good-guys are using the cloud to improve efficiency. This example is about how the bad-guys could use the cloud to enhance their attack sophistication.
- “ Web OS 2009” image from http://blogs.zdnet.com/Hinchcliffe While this is a great graphic, it is already way out of date. Looming on the horizon for Federal Agencies are: Electronic Document Management and E-Discovery issues associated with implementing NARA compliant Electronic Records Schedules. “ Users being users” -- working around rules to get their jobs done. Collaborative tools coming online where the vendors have made the default setting for the collaborative space full access for everyone – typically a good thing for the private sector (perhaps), but not good when dealing with sensitive information such as PII or proprietary data.