The Federal Risk and Authorization Management Program (FedRAMP) is a framework that provides a standardized approach to authorizing, monitoring and conducting security assessments on cloud services. It is an integral part of the U.S. Department of the Interior’s Cloud First Policy, which is designed to help government agencies leverage cloud solutions securely and more efficiently. This program focuses on reducing redundant work, streamlining processes, closing security gaps and minimizing costs associated with authorization.
Any accredited federal agency, authorized cloud service provider (CSP) or third-party assessment organization (3PAO) can be associated with FedRAMP. However, implementing it can be challenging. It takes time to execute properly and is not comparable to common reporting frameworks such as Statement on Standards for Attestation Engagements (SSAE 16) and Service Organization Control (SOC 2). In fact, FedRAMP is one of the most complex and in-depth compliance programs an organization can undertake.
10 Steps to Evaluate CSPs for FedRAMP Compliance
Below are 10 steps organizations must take to evaluate their CSPs for FedRAMP compliance.
1. Cloud Risk Assessment
Organizations must categorize the data they plan to store and share in the cloud by type and sensitivity. It’s important to remember that data located in the cloud is inherently more difficult to control and protect. Consider whether or to what extent the manipulation or exposure of this data could affect its confidentiality, integrity or availability. You may also want to perform a security assessment to determine whether a public, private or hybrid cloud solution carries more or less risk than simply hosting the data on-premises.
2. Security Policies
The next step is to create a security policy to define the controls and risks associated with the cloud service. This policy should cover which data, services and applications are secure enough to migrate to the cloud. Work with legal counsel before engaging a CSP to ensure that all internal controls meet the organization’s needs.
Many CSPs offer encryption, which is one of the most effective protections against cyberthreats. However, it’s crucial to consider the security of the encryption keys provided by the CSP.
4. Data Backup
To achieve FedRAMP compliance, an organization must have adequate controls that back up cloud data. A business continuity and disaster recovery plan is even more critical and should be tested periodically to avoid outages.
FedRAMP compliance also requires organizations to have robust authentication protocols in place. Most CSPs require an authentication method that facilitates mutual validation of identities between the organization and provider.
These protocols depend on the secret sharing of information that completes an authentication task, which protects cloud-bound data from man-in-the-middle (MitM), distributed denial-of-service (DDoS) and relay attacks. Other methods, such as smart cards, strong passwords and multifactor authentication, defend data against brute-force attacks. Finally, elliptical curve cryptography and steganography help prevent both internal and external impersonation schemes.
6. Determine CSP Capabilities
Cloud providers offer a variety of services, such as software-as-a-service (SaaS), platform-as-a-service (PaaS) and infrastructure-as-a-service (IaaS) offerings. SaaS is a service in which software is licensed to an organization as a subscription-based model. PaaS, on the other hand, is a public or private offering that sits behind a firewall and enables organizations to develop, execute and manage applications. Finally, IaaS solutions provide controlled automation and scalable resources via an application programming interface (API) dashboard. This type of service is often regarded as a virtual data center.
These common cloud services should be evaluated according to the organization’s cloud security policy and risk assessment.
7. CSP Security Policies and Procedures
FedRAMP also requires organizations to ensure that the CSP has policies and procedures to govern security processes and responsibilities. This involves obtaining an independent audit report from an accredited assessor. It is also important to review these procedures to guarantee compliance with other frameworks, such as the International Standards Organization (ISO) 27000 series.
8. Legal Implications
CSPs must adhere to global data security and privacy laws, meaning they must disclose any and all breaches to the appropriate government agencies. Because FedRAMP’s legal guidelines are in flux, always consult with your legal department to ensure compliance with federal and state laws, which are often defined in the cloud provider agreement. In most states, the owner of the data is responsible for maintaining compliance with these regulations.
9. Data Ownership
Data ownership is a vital criterion when it comes to reviewing a cloud service contract. The parameters can be confusing for organizations that have many stakeholders, so establish a comprehensive data governance program and reflect it in the CSP’s contract.
Implement continuous local backups to make sure any cloud outages do not cause permanent data loss. Security leaders should insist that the CSP uses end-to-end encryption on data in motion and at rest. Also remember that different jurisdictions can affect the security of data that is stored and/or transmitted in a foreign country.
10. Data Deletion
Cloud security compliance should be reviewed in the context of the organization’s policies and procedures for data deletion. You must also consider the difficulty of tracing the deletion of encrypted data. Some cloud providers use one-time encryption keys that are subsequently deleted along with the encrypted data, rendering it permanently useless.
The Long Road to Cloud Security
FedRAMP can help organizations reduce costs, save time and maximize cloud-based resources. However, unlocking these benefits requires a significant investment of time and money. Companies must be extremely thorough when evaluating cloud providers, and true compliance requires many more steps than the ones listed above. But these insights can give organizations seeking to do business with government agencies in the cloud a head-start on the long road to cloud security.