Clouds, FISMA, and the Lawyers

April 28, 2011
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Picture of CloudsMike “@rybolov” Smith just posted his thoughts on the recent Microsoft/Google FISMA “certification” story from last week. Thought some of you might find this interesting. Personally, I think Google misrepresented their new email service. Even though it is based on an existing service that has an Authority to Operate (ATO), that does not mean it automatically transfers to their new service. The Department of Interior’s decisions for choosing Microsoft, which does not have any ATO, adds an additional slant to the story. Oh and by the way … there is no such thing as “FISMA certified.” Enjoy!

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Interesting blog post on Microsoft’s TechNet, but the real gem is the case filing and summary from the DoJ (usual .pdf caveat applies). Basically the Reader’s Digest Condensed Version is that the Department of Interior awarded a cloud services contract to Microsoft for email. The award was protested by Google for a wide variety of reasons, you can go read the full thing for all the whinging.

But this is the interesting thing to me even though it’s mostly tangential to the award protest:

  • Google has an ATO under SP 800-37 from GSA for its Google Apps Premiere.
  • Google represents Google Apps for Government as having an ATO which, even though 99% of the security controls could be the same, is inaccurate as presented.
  • DOI rejected Google’s cloud because it had state and local (sidenote: does this include tribes?) tenants which might not have the same level of “security astuteness” as DOI. Basically what they’re saying here is that if one of the tenants on Google’s cloud doesn’t know how to secure their data, it affects all the tenants.

So this is where I start thinking. I thunk until my thinker was sore, and these are the conclusions I came to:

  • There is no such thing as “FISMA Certification”, there is a risk acceptance process for each cloud tenant. Cloud providers make assertions of what common controls that they have built across all
  • Most people don’t understand what FISMA really means. This is no shocker.
  • For the purposes of this award protest, the security bits do not matter because
  • This could all be solved in the wonk way by Google getting an ATO on their entire infrastructure and then no matter what product offerings they add on top of it, they just have to roll it into the “Master ATO”.
  • Even if the cloud infrastructure has an ATO, you still have to authorize the implementation on top of it given the types of data and the implementation details of your particular slice of that cloud.

And then there’s the “back story” consisting of the Cobell case and how Interior was disconnected from the Internet several times and for several years. The Rybolov interpretation is that if Google’s government cloud potentially has tribes as a tenant, it increases the risk (both data security and just plain politically) to Interior beyond what they are willing to accept.

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