Your cloud based data may be hanging by a thread and you wouldn’t even know.
Introduction
The recent Sidekick debacle proved one thing: it’s insufficient to “just trust” companies that are currently offering cloud based services. Instead, industry standards and regulations must be developed to permit use of the term.
I’ll be blunt: as per previous articles here, I don’t believe in “The Cloud” as a fundamental paradigm shift. I see it as a way of charging more for delivering the same thing for private clouds, and (as exemplified by Sidekick), something which may be fundamentally unreliable as a sole repository of data in the public instance.
Regardless of that however, it’s clear that the “cloud” moniker will be around for a while, and businesses will continue to trade on being providing “cloud” services (and thus being buzzword compliant). So, like it or lump it, we need to come up with some rules.
Recently SNIA has started an initiative to try to setup some standards for Cloud based activities. However, as is SNIAs right, and their focus, this primarily looks at data management, which is less than half of the equation for public cloud services. The lions share of the equation for public cloud services, as proven by the Sidekick debacle is trust.
Currently the cloud computing industry is like the wild west. Lots of people are running around promising fabulous new things that can solve any number of problems. But when those fabulous new things fail or fall over even temporarily, a lot of people can be negatively affected.
How can people trust that their cloud data is safe? Regulation is a good starting point.
If you are one of those people who at the first hint of the word regulation throws up your hands and says “that’s too much government intervention”, then I’d invite you to stop and think for a few minutes about the global financial crisis. If you’re one of those people who insists “industries should be self regulating”, I’d invite you to look at a certain Microsoft subsidiary called Danger that was offering a service called Sidekick. In short, self regulation doesn’t work without rigid transparency.
So, what needs to be done?
Well, there’s three key factors that need to be addressed in order to achieve true and transparent trust within cloud based businesses. These are:
- Foundation of ethical principles of operation
- Periodic certified (mandatory) audit process
- Reporting
Let’s look at each of these individually.
Ethical Principles of Operation
Whenever I start thinking about ethics in IT, I think of two different yet equally applicable sayings:
- Common sense is not that common (usually incorrectly attributed to Voltaire)
- When you assume you make an ass out of u and me. (Unknown source.)
Extending beyond the notion of “cloud”, we can say that companies should strive to understand the ethical requirements of data hosting, so as to ensure that whenever they hold data for and on behalf of another company or individual they:
- At all times aim to keep the data available within the stated availability times/percentages.
- At all times ensure the data is recoverable.
- At all times be prepared to handover said data on request/on termination of services.
These should be self evident in that if the situation were reversed we would expect the same thing. Companies that offer cloud services should work such ethical goals into their mission requirements and individual goals of every individual employee. (If the company offers cloud application services as well as just data services, the same applies.)
Mandatory, Periodic, Independently Certified Auditing of Compliance
In a perfect world, ethics alone would be sufficient to garner trust. However, as we all know, we need more than ethics in order to generate trust. Trust will primarily come from mandatory periodic independently certified auditing of compliance to ethical principles of cloud data storage.
What does this mean?
So let’s look at each word in that statement to understand what company* should have to do in order to offer “cloud” data/services:
- mandatory – it must, in order to keep referring to itself as “cloud”
- periodic – every 6-12 months (more likely every 12 months – 6 would be preferable in the fast moving world of the internet however)
- independently – to be done by companies or consultants who do not have any affiliation that would cause a conflict of interest
- certified auditing – said companies or consultants doing the auditing must have certification from SNIA for following appropriate practices
- compliance – if found to be non-compliant, SNIA (or some other designated agency) must post a warning on their web-site within 1 month of the audit, and the company be given 3 months to rectify the issue. If after 3 months they have not, then SNIA should flag them as non-compliant. This should also result in the company taking down any reference to “cloud”.
Obviously unless legally enforced, a company could choose to sidestep the entire compliancy check and just declare themselves to be cloud services regardless. Therefore there must be a “Known Compliant” list kept up to date, country-by-country, that would be advertised not only by SNIA but by actual cloud-compliant companies which partake in the process, so that end-users and businesses could reference this to determine who have exhibited certified levels of trust.
In order to achieve that certification, companies would need to be able to demonstrate to the auditor that they have:
- Designed their systems for sufficient redundancy
- Designed adequate backup and per-customer data recoverability options (see note below)
- Have disaster recovery/contingency planning in place
- Have appropriate change controls to manage updates to infrastructure or services
Note/Aside regarding adequate backup and per-customer data recoverability options. Currently this is an entirely laughable and inappropriate state. If companies wish to offer cloud based data services, and encourage users to store their data within their environment, they must also offer backup/recovery services for that data. They may choose to make this a “local-sync” style option – keeping a replica of the cloud-data in a designated local machine for the user, or, if not done this way, they must offer a minimum level of data recoverability service to their users. For example, something even as basic as “Any file stored in our service for more than 24 hours will be recoverable for 6 weeks from time of storage.” I.e., it doesn’t necessarily have to be the same level of data recovery we expect from private enterprise networks, but it must be something.
It would be easy and entirely inappropriate to say instead of all this auditing that companies must simply publish all the above information. However, that represents a potential data security issue, and it also potentially gives away business-sensitive information, so I’m firmly against that idea. The only workable alternative to that however is the certified auditing process.
Reporting
Currently there is far too cavalier an approach to reporting by cloud vendors about the state of their systems. Reporting must be publicly available, fulfilling the following categories:
- Compliancy – companies should ensure that any statement of compliancy is up to date.
- Availability – companies should keep their availability percentile (e.g., “99.9% available”) publicly available in the way that many primary industries for instance publish their “days without an injury” statistics.
- Failures – companies must publish failure status reports/incident updates at minimum every half an hour, starting from the time of the incident and finishing after the incident is resolved. It’s important for cloud vendors to start to realise that their products may be used by anyone else in the world, so it’s not sufficient to just wake IT staff on an incident, management or other staff must be available to ensure that updates continue to be generated without requiring IT staff to stop working on resolution. I.e., round-the-clock services require round-the-clock reporting.
- Incident reports – all incidents that result in unavailability should have a report generated on which will be reviewed by the auditor on the next compliancy check.
In conclusion
Does this sound like a lot of work? Well, yes.
It’s all too easy for those of us in IT to take a cavalier attitude towards user data – they should know how to backup, they should understand the risks, they should … well, you get the picture. Yes, there’s a certain level of education we would like to see in end users, but think of the flip-side. They’re not IT people. They don’t necessarily think like IT people. For the most part, they’ve been trained not to think about backup and data protection because it’s not something that’s been pushed home within the operating systems they’re using. (A trend that seems to be readily reversing in Mac OS X thanks to Time Machine.)
Ultimately, cloud failures can’t be palmed off with trite statements that users should have kept local copies of their data. Cloud services are being marketed and promoted as “data available anywhere” style systems, which creates an expectation of protection and availability.
So in short, while this is potentially a lot of work to setup, it’s necessary. It should be considered to be a moral imperative. In order to actually garner trust, the current wild-west approach to Clouds must be reined in and be given certified processes that enable users (or at least trusted IT advisers of users) to confidently point at a service and say: “that’s been independently checked: it’s trustworthy“.
Anything short of this would be a scandalous statement about deniability, legal weaseling out of responsibility and a “screw you” attitude towards end-user data.
–
* Obviously some individuals, moving forward, may in various ways choose to offer cloud access. Due to hosting and bandwidth, it’s likely in most instances that such access would be as a virtual private cloud – a cloud that’s “out there” in internet land, but is available only to select users. As such, it would fall into the realm of private clouds, which will undoubtedly have a do whatever the hell you feel like doing approach. However, in the event of individuals rather than corporates specifically offering full public-cloud style access to data, there should be a moniker for “uncertified” individual cloud offerings – available only to individuals; never to corporates.
