Four Steps to Compliance Management in the Public Cloud
Is it possible to ensure compliance when sending services to the cloud?
Jul. 21, 2011 11:30 AM
Feeling nervous about the cloud? Many CIOs understandably hesitate to send services requiring regulatory compliance to the public cloud. Though not outsourcing such services may seem like a good idea, this approach limits your flexibility in offering the best combination of services to meet business demands. As public cloud services continue to grow in both diversity and quality, IT and the business can't afford to bypass opportunities offered there and hope to remain competitive. The compliance issue must be addressed, but how? Is it possible to ensure compliance when sending services to the cloud?
Fortunately, the answer is "yes." By using a strategy based on Business Service Management (BSM), a comprehensive approach and unified platform for running IT, you can extend the BSM processes and solutions that you use to manage your internal infrastructure to the public cloud environment.
Step 1: Divide Services into Three Categories
Start by dividing the services you have selected for public cloud sourcing into three major categories, according to their monitoring and management requirements:
1. Services Without Service Quality or Regulatory Compliance Commitments
2. Services with Service Level Agreements (SLAs)
You cannot typically monitor and manage public cloud resources to the same degree as private cloud resources. Scaling up or down is typically the responsibility of the service provider, not the consumer of the service. However, you can use BSM solutions to proactively monitor and manage the availability and performance of public cloud services. And you can do so in a unified way, with the same tools you use to manage your internally provided services.
3. Services that Require Regulatory Compliance
Even if you choose to keep compliance-mandated services in house for now, keep in mind that cloud computing is evolving, and service providers are continually improving their ability to ensure and attest to regulatory compliance. Keep your options open for switching to external providers for these services in the future.
Step 2: Develop, Document, and Enforce Internal Compliance Policies
These regulations specify various criteria with which IT organizations must comply. They also include safeguards. HIPAA, for example, covers three types of safeguards: administrative, physical, and technical.
The regulation may also include implementation specifications. A HIPAA security rule, for example, outlines 18 standards for administrative, physical, and technical safeguards, plus 36 implementation specifications to protect the confidentiality, integrity, and availability of protected health information.
Establish policies that translate the relevant regulations and standards into processes and procedures to which your IT organization must adhere, and then publicize these policies and procedures to the internal IT organization. Here, an IT controlled management solution can help you author, publish, manage, and enforce the policies.
If your IT organization is like most, your internal IT infrastructure will be heterogeneous as you move incrementally from your current environment to the cloud environment. It might include dedicated physical systems, virtualized systems, and private cloud systems. The technology you deploy should enable you to manage the entire infrastructure in a unified manner with respect to compliance.
Here again, BSM can help. For example, data access solutions help you manage the identity and authorization of entities or people that access data that come under the purview of the policies. As another example, change management solutions ensure that all changes made to the IT infrastructure are made in compliance with the policies.
Step 3: Extend Your Internal Compliance Policies to the Cloud
However, it's up to you, the customer, to reconcile the cloud provider's offerings with your own policies. While you can't directly monitor, manage, and control all aspects of the supplier's administrative, physical, and technical safeguards, you can translate your internal compliance policies into a form that is appropriate for the external providers, and then publish these transformed policies. You can leverage the same BSM solutions that you used to create and manage your internal policies to transform, publish, and manage the supplier policies.
This transformation can be a major effort and may involve manual processes. Some enterprises have pursued a path of partnering with their service provider, encouraging them to help complete a compliance checklist. While that effort isn't trivial, some service providers, eager to support a compliance-focused market, work collaboratively with customers.
In addition, you can request that external providers attest to their compliance with your published policies. This approach enables you to extend the rigor of your internal compliance and attestation processes to external service providers.
Step 4: Monitor and Manage Your Public Cloud Providers
First, evaluate and select the highest-value vendors by enforcing best-practice vendor review and approval processes. After you select the vendors, track their performance against their commitments. For example, you can create a risk scorecard for each vendor that tracks its performance in meeting your compliance policies. Finally, you need to continually optimize and consolidate your vendor portfolio by using a fact-based, systematic program for strategic vendor management based on portfolio-level analysis and reporting.
Supplier management solutions enable you to manage the entire supplier lifecycle - from evaluation through termination. These solutions centralize vendor information and help you enforce critical processes, track financials, and track and measure performance against commitments.
Fear Not the Public Cloud
Instead of avoiding the public cloud for services that come under regulatory control, you can use compliance management tools and the IT practices described here to maintain compliance in the cloud.
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