This post was originally published on Cloud Computing Journal.
When describing cloud computing, terms like highly scalable, efficient, and on-demand probably come to mind. Unfortunately, those same descriptors aren’t commonly associated with operations in the federal government.
In 2010, the White House’s Office of Management and Budget set out to change that with the Cloud First Policy. Through cloud computing, the OMB aimed to help federal agencies consolidate and provide new services cheaper and faster.
But with cloud adoption comes the heightened challenge of ensuring a secure and trustworthy environment. That’s where FedRAMP comes in.
FedRAMP defines the requirements for cloud service providers’ security controls, including vulnerability scanning, incident monitoring, logging, and reporting. CSPs in use at federal agencies or in acquisition must meet the cloud computing requirements defined by FedRAMP.
Whether or not your company currently works with government agencies, there are several benefits to preparing for FedRAMP:
- Sales potential: FedRAMP compliance allows you to compete for government business, but it will also give you a competitive advantage over CSPs that haven’t gone through such a lengthy assessment. Even if you don’t end up doing business with a government agency, customers will be more confident going with a CSP that’s prepared for FedRAMP. This is especially true if your customer is also a CSP interested in bidding in a government RFP for cloud services.
- Risk management: Preparing for FedRAMP will expose vulnerabilities in your system and help you better understand them. Risk management can also draw a line in the sand to define where your risk ownership starts and stops. It’s important to communicate this to your customers to eliminate confusion.
- Unified compliance: FedRAMP requirements can map back to many industry standards, including ISO 27001, PCI, HIPAA/HITECH, COBIT, and GLBA. Done correctly, preparing for FedRAMP can help CSPs establish a unified compliance approach to the litany of compliance requirements their customers have. Unified compliance limits the duplication of assurance efforts across regulations and between a CSP and its clients.
If you have no plans to pursue government contracts, don’t blindly spend money on certification just to check a compliance box. FedRAMP aims to centralize compliance checking in a “do once, use many” process, but the costs can be quite high. In any case, simply evaluating your organization against FedRAMP’s standards will provide an invaluable risk assessment.
However, CSPs that could potentially be a part of the government ecosystem – either directly or indirectly through their customers – should prepare themselves for FedRAMP. They need to weigh the costs and benefits of determining where their organizations align with the federal government‘s Cloud First policy.
Delegate the Details
FedRAMP compliance is a highly detailed process, and the planning itself is exhaustive. You’ll need to seek outside help to create your system security plan and work with a third-party assessment organization.
Before you bring in outsiders, however, there are a few preparations you need to make internally. The FedRAMP PMO has created extensive checklists to help you do as much as possible on your own.
Once you’ve gone through the checklists, find a partner to help you do the following:
- Categorize your system. Based on the FIPS 199 template, categorize your system to determine whether your risk impact is low, moderate, or high.
- Select and/or implement security controls. Using NIST 800-53, select the baseline controls that apply to your organization. Implement those or create a plan for implementation.
- Create a system security plan. This plan documents all the details regarding the first two steps and defines the boundaries of your system. This template is one of the first things reviewed during a FedRAMP assessment.
Getting your FedRAMP certification is a lengthy process, and it’s not the right option for every company. By taking the necessary steps and preparing yourself in advance, you’ll be one step closer to enjoying the competitive advantage it affords.