Expected to be operational by June of 2012, the Federal Risk and Authorization Program (FedRAMP) is the current administration’s attempt to set cloud computing security standards for cloud service providers (CSPs). The primary goal of FedRAMP is to streamline the authorization process for government agencies to work with public and private cloud hosting companies. This is coming on the heels of certain provisions in the 2012 National Defense Authorization Act that require the Department of Defense to migrate data to private-sector cloud solutions. This is mainly due to assessments confirming that the private-sector is more capable of providing equal or greater security at a fraction of the cost.
This is exciting news within the cloud hosting community, although there are concerns. How will FedRAMP accomplish what it proposes? As of January 6th, FedRAMP’s Joint Authorization Board has approved the control baselines for federal agencies. What this means for CSPs is that once approved, the process need not be applied again. The control baselines are universal, therefore working with multiple government agencies should, in theory, be easier. If a particular agency has additional security needs, CSPs will not be required to jump through the same hoops, as that groundwork has already been laid. Of course this is the best-case scenario, as with all bureaucracy the potential for becoming bogged down in red tape is always on the horizon.
This is a significant concern as every state and federal agency will use FedRAMP as a building point, and can if they so choose, decide to implement a host of security requirements in addition. This could effectively render FedRAMP compliance irrelevant. In fairness to these agencies, they are not all going to fit nicely into what FedRAMP will package as a cloud security standard. From a provider’s point of view the questions are many. Most CSPs are concerned about how to make legislation and compliance work effectively for the company. Yes, it is wonderful that the federal government feels that the private-sector CSPs can provide better security for less. Before we all pat ourselves on the back, we need to take a look at how IT industry standardization has played out in the past.
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IT solutions that change the landscape have outdistanced the governments ability to legislate in a timely manner for over a decade now. These changes are coming faster and faster, while the ability to create new contract programs continues to move at the same pace. Reverse auctions and seat management for example accomplished nothing more than time and debt on both sides. There really is nothing to suggest that FedRAMP will be any different, other than the refreshing idea of “do once, use many times.” The concept of laying down universal cloud-based security standards is a fundamentally sound concept. Working with government agencies will most certainly appeal to many CSPs. Corporations ready to make the move to cloud-based solutions will most likely find comfort with the knowledge that a universal security standard is in place. It unfortunately remains to be seen if the government can keep up with every new advance in the IT world without dragging it back down in the legislative process.
How will FedRAMP affect cloud security? Historically the government allows too many chefs in the kitchen when it comes to IT legislation. If this administration can manage to field the right people for the task, there are high hopes that FedRAMP is a step in the right direction for cloud security standards. The possible downside is that FedRAMP could end up obsolete before it is ever implemented, or worse do actual damage. If the private-sector is already providing a level of security superior to the federal government, is it really necessary?