Establish a cloud-computing program management office with authority to promulgate cloud-computing strategy and related standards and approve, coordinate, and oversee Agency-wide acquisition of cloud-computing services.
The ease with which cloud-computing services can be acquired by a business process owner (often the only thing needed is a credit card) can result in traditional IT and procurement controls being bypassed. While business process owners may value this agility, they may not be well versed in the risks associated with the use of cloud-computing services, or how best to mitigate them.
For these reasons, it can be important for the customer to establish enterprisewide resources responsible for:
* Developing best practices for the use of cloud-computing services that reflect and are aligned with the organization's policies, practices and unique tolerance for risk; and
* Providing guidance in the acquisition of cloud-computing services.
Direct all NASA CIOs to review FedRAMP and take necessary action to ensure their existing and planned cloud-computing services meet FedRAMP requirements.
While this recommendation is focused on the federal FedRAMP standard, in a more general sense, any customer organization should ensure awareness of the contract and strategy resources discussed herein. For this reason, it can be important for the resources noted above to also provide education to end users regarding these issues.
Ensure any movement of moderate- or high-impact NASA systems to public clouds conforms with Federal and Agency IT security requirements.
For any customer organization, it is important to conduct sufficient advance analysis before moving a particular function to the cloud. The business owner of these functions may be insufficiently aware of the risks to conduct this analysis on their own. For this reason, it is important for the resources noted above to also be available to provide advice in evaluating which systems or data are appropriate for use in a public cloud environment.
Require the cloud service provider or broker to develop NIST compliant security and contingency plans and conduct a test of the system's security controls.
Ensure that the responsible Information Security Officer review IT security documentation and control tests and authorize the system for operation, as appropriate.
These last two are combined because, not only do they each address appropriate infrastructure and security practices, they're also examples of ongoing actions that need to be taken after the contract has been negotiated. One thing that distinguishes the acquisition of cloud computing services from other acquisitions is that the customer's work doesn't end upon completion of the initial order and associated contract. In fact, that's when the hard work begins, since the customer must now ensure that the cloud vendor's service complies with the requirements established in the contract on an ongoing basis. For this reason, it is important that the organizational resources provisioned when adopting a cloud-computing service include resources for ongoing vendor relationship management.
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