Tag: privacy

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Cloud IT: Hiding Complexity and Risk

jmbunnyfeet

Cloud IT: Hiding Complexity and Risk

Cloud computing and Internet technologies have delivered previously unimagined capability for even the smallest of businesses – capability to compete, build brand recognition, and reach markets in remote geographies.  The mantra for businesses used to be “location, location, location”, but it’s become connectivity – perhaps even more than location – which now delivers business opportunity.  As technology has evolved, allowing businesses and consumers to connect regardless of time or place, the complexity of the systems and networks have also increased dramatically.  Where a business could once easily identify their various vendors or business service providers, the identification of those involved in the service ‘delivery chain’ are no longer so easily recognized.   Among the benefits of cloud computing technologies is the ability to reach beyond traditional boundaries.  The risk for many businesses is in not fully understanding how, and with whom, those boundaries are being crossed.

For many an enterprise, the convenience and efficiency introduced with cloud computing models overshadows the increased risk potential.  Service level agreements and vendor contracts are assumed to be sufficient to protect the business and its information assets, yet recent events (such as the recent reveals of PRISM and the actions of the National Security Agency) should cause businesses to look a little deeper at their entire provider network.  It’s not that the average business should be concerned about government snooping of their emails, but they should be aware of who has access to their systems and data, and which entities are responsible for which parts of the system.  It’s only prudent to know the details, and it is the best first step to mitigate business risk.

Enterprise Clouds are complex, sophisticated entities which invariably rely on a daisy-chain of third parties and contractors to help build, run and maintain their Cloud provider’s systems. The organizational and technical complexities are additive, resulting in increased systemic risk. Systemic risk is the least visible and hardest to eliminate, and those risks become real when the providers’ systemic risks become [yours].

The question is, how well does your Cloud provider manage the ecosystem of contractors and third parties that are farther down the food chain? This is even more relevant in the globalized workforce, where, paradoxically, Cloud and related technologies have greatly facilitated the outsourcing and offshoring of work to low-cost countries. http://www3.cfo.com/article/2013/6/data-security_prism-national-security-agency-edward-snowden-cloud-implications-vendor-management

Before executing a service agreement with an outsourced provider, make certain that the details of facility, connectivity, network, equipment, and other elements of the delivery and system are spelled out.  Business subscribers should know where the various points of failure exist, and which company is responsible for dealing with each.  If a carrier fails and connectivity to the data center is lost, the hosting service provider may be powerless to impact the situation, even though access to service is part of the SLA and requirement.  If a hosted software product has a vulnerability or fails to perform, the developer of the product is likely responsible, rather than a hosting service provider.  The point is that there are often multiple players in the delivery chain, and customers should be aware of this reality prior to engaging with the service.

Ultimately, the business with mission critical data in the possession of a 3rd party service provider should have a healthy helping of doubt as to whether the provider has full control over their environment.  Business owners, managers and CFOs should recognize the increased necessity of evaluating risk within their provider systems and in provider/vendor relationships, to keep trade secrets secret and prevent intellectual property from becoming the property of others.

Joanie Mann Bunny Feet

Make Sense?

J

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HIPAA Privacy and Security and the Cloud

jmbunnyfeet

HIPAA Privacy and Security and the Cloud

Is your cloud solution or hosting service HIPAA compliant?  This is among the most frequently asked questions from professionals shopping for cloud hosting service.  Unfortunately, it is also among the questions most frequently answered with ambiguity, or with naiveté.  The problem is that many businesses dealing with HIPAA compliance responsibilities as it relates to protection and security of personal health information may not fully understand their responsibilities as they extend to outsource IT and other service providers.  In the case of HIPAA compliance, many providers suggest their compliance without truly understanding what it means, and are introducing significant risk to their business and subscribing customers because of it.  With recent changes in rules relating to protection and control of personal health information, it is not just the health care provider, the health plan, 3rd party administrator or others that process health insurance claim information which must agree to provide adequate controls – the requirement may fully extend to business associates of these entities… possibly including their cloud service or hosting solution providers.

Some of the largest breaches reported to HHS have involved business associates. Penalties are increased for noncompliance based on the level of negligence with a maximum penalty of $1.5 million per violation. The changes also strengthen the Health Information Technology for Economic and Clinical Health (HITECH) Breach Notification requirements by clarifying when breaches of unsecured health information must be reported to HHS. http://www.hhs.gov/news/press/2013pres/01/20130117b.html

HIPAA guidelines and rules exist to protect and secure personal health information, a requirement growing in importance with advancements in technology, electronic health records, e-billing solutions, and cloud computing adoption.  Where the regulations were once focused on the entity directly involved in generating or processing the information, the view is now extended not only to 3rd party administrators, but also to the technology solutions and providers involved.  When a “covered entity” (an entity with a responsibility to protect and secure personal health information [PHI]) makes a decision to move this information to the cloud, a number of important and complicated issues must be addressed in the agreements with the service or solution provider.  These issues include security and privacy of information (including providing individuals the right to access and request changes to the stored information), tools which may be provided to allow the customer additional security protection, encryption of data at rest and in transmission (and who holds the keys), data location, return of data, disaster recovery, and service levels.

Cloud provider contracts and business associate agreements with cloud providers are not one-size-fits-all and should be negotiated carefully to protect PHI in a manner that accurately reflects the capabilities of the parties http://www.americanbar.org/content/newsletter/groups/labor_law/ebc_newsletter/12_winter_ebc_news/ebc12winter_cloud.html

The provider delivering cloud hosting services to the business may now be considered to be a “business associate” under HIPAA, meaning that the responsibilities of the Customer (the “covered entity”) also extend to their service provider. For any business operating under a HIPAA compliance requirement, moving to the cloud must necessarily involve a detailed discussion and set of agreements that spell out the “business associate” relationship as well as the details of the service delivery and accepted performance levels.

Joanie Mann Bunny FeetMake Sense?

J

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Are the security requirements for accounting and finance professionals using cloud services any less stringent than those governing lawyers?

jmbunnyfeet

As accounting and finance professionals look to the cloud and Internet technologies to address collaboration, mobility, and improvements in service delivery, they should also be looking at ways to ensure the protection and security of client financial information.  Professional services organizations of all types are embracing cloud products and services, sometimes without properly considering how it might impact information security and business risk.  The security requirements for accounting and finance professionals using cloud services are no less stringent than those governing lawyers.

In her article “NC Bar Council issues final opinion on the cloud “, author Nicole Black points out some of the essential considerations for using cloud computing services in a professional legal practice.  Accounting and finance professionals should recognize this guidance as being applicable to their businesses, too.

The main question stems from the ethical issues faced by “lawyers who intend to store confidential client information on servers owned and operated by third parties”.  An opinion issued by the North Carolina State Bar Council addressed two primary questions in this area:

1.     Is it OK for a law firm to use Software as a Service or cloud computing products?

2.     Are there any special vendor assessments or other measures which should be taken by lawyers who wish to minimize the security risks of implementing this type of solution?

Read the entire article by Nicole here (PDF format)

Nicole Black is a Rochester, New York attorney and the Vice President of Business Development and Community Relations at MyCase, a powerful and intuitive cloud-based law practice management platform. She is also a GigaOM Pro Analyst and is the author of the ABA book Cloud Computing for Lawyers, co-authors the ABA book Social Media for Lawyers: the Next Frontier, and co-authors Criminal Law in New York, a West-Thomson treatise. She is the founder of lawtechTalk.com and speaks regularly at conferences regarding the intersection of law and technology. She publishes four legal blogs and can be reached at nblack@nicoleblackesq.com.

Joanie Mann Bunny FeetJ

original post April 5, 2012
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There are only two types of businesses: those who have lost their data, and those who will

The portable computer was the secret business weapon of yesterday, and is today’s essential business tool.  The processing power, portability, storage, and connectivity available with laptops, tablets and even smartphones can create a seamless extension of the office.

Truly, the workforce of today is mobile and fully-enabled.  Business owners, working in conjunction with their accounting advisors and business consultants, are able to access all the information and analytical capability they need to make informed business decisions at any time, capture and collect important information, and keep productivity at the highest levels no matter where they are.

Mobility doesn’t come without risk, however.  Some studies estimate that as much as 80% of the business data that a company has (like customer files, contracts, financial data, product specifications) is stored on portable computing devices.   While these files may be recoverable from backups in the case of loss or damage, there is an even larger potential cost in terms of exposure of confidential or proprietary – or personal and private – information.

Loss or theft can create big business and legal problems, too. Customer or client privacy may be compromised, sensitive information may be exposed, and confidential plans may be made public if a business doesn’t take steps to secure mobile data.   Software and network attacks are also prevalent, with a variety of exploits designed to take advantage of any vulnerability present.

There’s an old saying we IT folks have that there are only two types of businesses: those who have lost their data, and those who will.  Imagine the potential chaos and risk exposure, not to mention the expense, of losing your valuable business data, or having it exposed to unauthorized users.

While computing mobility delivers a host of advantages to the business and the user, care must be taken to ensure security, privacy, and confidentiality of business information.  Cloud computing solutions and managed IT services will help you provide the mobile capability your business needs, but with the additional protection, additional security, and ongoing management that the value of the data demands.  Increased exposure to liability is a reality for any mobile business, and the risk is only multiplied by the number of systems a company has in the field.  The smart business reduces risk by deploying secure yet versatile platforms for their workers that allow data to be stored and protected in centralized environments, rather than on the individual computing devices. Via the cloud, businesses of all kinds are reaping the benefits of new and innovative service delivery models and enhanced security solutions, achieving the freedom and functionality (and data security) the mobile workforce demands.

Here are a few data loss statistics for your reading pleasure…

Enjoy  🙂

J

(stats drawn from summary on BostonComputing.net.  They may be a bit dated, but the numbers have only increased since then.) http://www.bostoncomputing.net/consultation/databackup/statistics/

The following statistics were gathered from various sources:

  • 6% of all PCs will suffer an episode of data loss in any given year. Given the number of PCs used in US businesses in 1998, that translates to approximately 4.6 million data loss episodes. At a conservative estimate, data loss cost US businesses $11.8 billion in 1998. (The Cost Of Lost Data, David M. Smith)
  • 30% of all businesses that have a major fire go out of business within a year. 70% fail within five years. (Home Office Computing Magazine)
  • 31% of PC users have lost all of their files due to events beyond their control.
  • 34% of companies fail to test their tape backups, and of those that do, 77% have found tape back-up failures.
  • 60% of companies that lose their data will shut down within 6 months of the disaster.
  • 93% of companies that lost their data center for 10 days or more due to a disaster filed for bankruptcy within one year of the disaster. 50% of businesses that found themselves without data management for this same time period filed for bankruptcy immediately. (National Archives & Records Administration in Washington)
  • American business lost more than $7.6 billion as a result of viruses during first six months of 1999. (Research by Computer Economics)
  • Companies that aren’t able to resume operations within ten days (of a disaster hit) are not likely to survive. (Strategic Research Institute)
  • Every week 140,000 hard drives crash in the United States. (Mozy Online Backup)
  • Simple drive recovery can cost upwards of $7,500 and success is not guaranteed