UK: Seeding The Global Public Sector Cloud: Data Classification, Security Frameworks And International Standards

Last Updated: 4 November 2015
Article by Richard Kemp

All of a sudden, everywhere you look, the cloud is the new normal. Top service providers' cloud revenues are doubling year on year at the start of what is predicted to be a sustained period of growth in cloud services.  As IT workloads have migrated to the cloud, the private sector has led the charge.  Governments have been towards the rear, with cloud spend to date generally accounting for less than five percent of a given country's public sector IT budget.  This looks likely to increase quickly as the public sector starts to overcome the blockers to cloud uptake.

The classic NIST definition of the Cloud specifies Software (SaaS), Platform (PaaS) and Infrastructure (IaaS) as the main Cloud services (see figure 1 below), where each is supplied via network access on a self-service, on-demand, one-to-many, scalable and metered basis, from a private (dedicated), community (group), public (multi-tenant) or hybrid (load balancing) Cloud data centre.

The benefits of the Cloud are real and evidenced, especially between the private and public cloud where public cloud economies of scale, demand diversification and multi-tenancy are estimated1 to drive down the costs of an equivalent private cloud by up to ninety percent.

Equally real however are the blockers to public sector cloud adoption, where studies2 consistently show that management of security risk is at the centre of practical, front-line worries about cloud take-up, and that removing them will be indispensable to unlocking the potential for growth.  Demonstrating effective management of cloud security to and for all stakeholders is therefore central to cloud adoption by the public sector and a key driver of government cloud policy.

A number of governments have been at the forefront of developing an effective approach to cloud security management, especially the UK which has published a full suite of documentation covering the essentials.  (A list of the UK government documentation – which serves as an accessible 'how to' for countries who do not want to reinvent this particular wheel – is set out in the Annex to our white paper, Seeding the Public Cloud: Part II – the UK's approach as a pathfinder for other countries).  The key elements for effective cloud security management have emerged as:

  • a structured and transparent approach to data classification;
  • a transparent and published cloud security framework based on the data classification; and
  • the use of international standards as an effective way to demonstrate compliance with the cloud security framework.

Data classification is the real key to unlocking the cloud. This allows organisations to categorise the data they possess by sensitivity and business impact in order to assess risk. The UK has recently moved to a three tier classification model (OFFICIAL → SECRET → TOP SECRET) and has indicated that the OFFICIAL category 'covers up to ninety percent of public sector business'3 like most policy development, service delivery, legal advice, personal data, contracts, statistics, case files, and administrative data. OFFICIAL data in the UK 'must be secured against a threat model that is broadly similar to that faced by a large UK private company'4 with levels of security controls that 'are based on good, commercially available products in the same way that the best-run businesses manage their sensitive information'.5

Data classification enables a cloud security framework to be developed and mapped to the different kinds of data. Here, the UK government has published a full set of cloud security principles, guidance and implementation6 dealing with the range of relevant issues from data in transit protection through to security of supply chain, personnel, service operations and consumer management. These cloud security principles have been taken up by the supplier community, and tier one providers like Amazon and Microsoft have published documentation7 based on them in order to assist UK public sector customers in making cloud service buying decisions consistently with the mandated requirements.

Compliance with the published security framework, in turn based on the data classification, can then be evidenced through procedures designed to assess and certify achievement of the cloud security standards. The UK's cloud security guidance on standards references ISO 27001 as a standard to assess implementation of its cloud security principles.  ISO 27001 sets out for managing information security certain control objectives and the controls themselves against which an organisation can be certified, audited and benchmarked.  Organisations can request third party certification assurance and this certification can then be provided to the organisation's customers.  ISO 27001 certification is generally expected for approved providers of UK G-Cloud services. 

This pragmatic but comprehensive combination of data classification and cloud security framework together with the assurance that evidenced compliance with generally accepted international standards provides will go a long way to unlocking the benefits, removing the blockers and enabling the public sector cloud around the world to achieve its potential.

If you would like to see further information on this topic, please see our October 2015 white papers on Seeding the Global Public Sector Cloud, Part I - A Role for International Standards and Part II – The UK's Approach as Pathfinder for Other Countries.

Footnotes

1 Microsoft Corporation, The Economics of the Cloud (November 2010), page 16 available at https://www.microsoft.com/en-gb/search/result.aspx?q=economics+of+the+cloud&form=apps

2 See for example, KPMG International, Exploring the Cloud: A Global Study of Governments' Adoption of Cloud (March 2012) available at http://www.forbes.com/forbesinsights/government_cloud_2012/index.html; J. Mechling in Governing, Government's Slow Takeoff into the Cloud (5 March 2015) at http://www.governing.com/columns/smart-mgmt/col-government-slow-adoption-cloud-computing-collaboration.html; C. Burt in Web Hosting Industry Review (WHIR) Despite UK's Cloud First Policy, 36% of Government Workers Haven't Used Cloud Services (7 July 2015) at http://www.thewhir.com/web-hosting-news/despite-uks-cloud-first-policy-36-of-government-workers-havent-used-cloud-services;

Government Security Classifications Supplier Briefing (October 2013) at Annex, point 3.2 – available at https://www.gov.uk/government/publications/government-security-classifications

Government Security Classifications (April 2014) at Annex, point 3.1, page 17 – available at https://www.gov.uk/government/publications/government-security-classifications

5  Government Security Classifications Supplier Briefing, above

6  See the table at the Annex to our White Paper at http://www.kempitlaw.com/seeding-the-global-public-sector-cloud-part-ii-the-uks-approach-as-a-pathfinder-for-other-countries/

7  For Amazon see: https://blogs.aws.amazon.com/security/post/Tx31CWNXWOP2J09/Using-AWS-in-the-Context-of-CESG-UK-s-Cloud-Security-Principles.  For Microsoft see: http://www.microsoft.com/en-gb/enterprise/it-trends/cloud-computing/articles/14-points.aspx#fbid=MyGgwF29ZRe

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
Richard Kemp
 
In association with
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

Disclaimer

Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

Registration

Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.