G-cloud update

This Thursday I went to the tea cloud camp meeting on cloud computing held at the National Audit Office in London for an update on progress with the UK Government’s G-Cloud

Launch of Cloud Store

We heard that the UK Government’s CloudStore  could go online as early as this weekend.

CloudStore will be in effect a catalogue of suppliers who have been accredited by the UK government to provide the government with cloud services.  The accredited companies are grouped under four headings – Infrastructure as a service, Platform as a service, Software as a service (including applications such as EDRM, CRM and collaboration) and Services (including systems integrators).

This is a technology shift towards cloud solutions,   but more importantly this is a procurement revolution. It is a move towards transparent pricing, with suppliers stating their prices up front on the CloudStore, and pay as you go, easy- to enter and easy-to-leave contracts.

One IT manager told us that in her career as a civil servant she had managed so many contracts with poor suppliers (she used a stronger term than poor!).  Even though the contractors were not performing her department had no choice but to keep them because they had no plan B.  The penalty clauses for leaving the contract early were so great as to make it uneconomical to change, and the length of the procurement process meant that their were no alternatives lined up ready and waiting to step in and fill the gap left by the ousted supplier. For her CloudStore means always having a plan B.   If she has a poor supplier in future she looks at the cloud store, finds an alternative, terminates the contract with the poor supplier and starts one with an alternative provider.

She identified one of the key thing about CloudStore was that we will increasingly see IT applications bought as commodities rather than as bespoke solutions.

The benefits should work both ways. The public sector get a better price and the suppliers will benefit from the lower cost of winning business.  They will be able to strike a deal with new public sector customers much more quickly.  Another potential benefit for suppliers is that CloudStore will be viewable online by anyone.  I would not be surprised if people in other sectors and other countries looked at the UK Government’s cloud store to get an idea of what suppliers have been accredited by the UK Government, what services they offer and what prices they offer.  There is also the capability for public sector bodies to write Amazon style reviews of the service they have received.

One of the speakers mentioned how pleased she had been with the response from suppliers. Hundreds of applications were received when the CloudStore OJEU issued late last year, and companies that did not apply first time around will be given further opportunities in future to apply to get onto the store.

G-cloud pilot – a County Council puts its e-mail into the cloud

We heard from a county council who were putting their e-mail into the cloud, as a pilot G-Cloud project. They had received six bids – three from vendors offering public cloud services, three from private clouds.  They narrowed it down to three bids – Microsoft’s Office 365, Google Apps, and IBM (who offered Lotus notes from a private cloud).  Each bid provided the functionality they wanted so they went on price alone (which tells you that e-mail, calendaring and basic collaboration is now a commodity).  Google Apps won.

The Council picked an initial group of around 150 volunteers to trial Google Apps.  In order to avoid a self selecting sample of technology enthusiasts they asked volunteers to give a reason why they wanted to join trial, and picked people with a range of different motivations. The volunteers were not given face-to-face training, but were each set up on Yammer so that they could act as a support community for each other. They have only received four calls to the service desk since it started.

One of the first things they found was how quick it was to bring people onto the service. They bought some servers to use to migrate users from their existing system (Lotus notes e-mail hosted in-house) to Google Apps in the cloud.  The servers will not be needed as soon as the migrations have all taken place.  They had 15 users up and running on the service within a week of signing the deal.

They have resisted the temptation to bring the whole organisations over to Google Apps in one big bang. Running two systems alongside each other brings with it inconveniences around calendaring – some staff are using Lotus Notes calendars and some using Google Apps so it is difficult for them to share appointments etc.  Their initial volunteer group of 150 people had to be expanded to 250 simply because some of the volunteers had colleagues that they needed to be on the same calendaring system with.

The Council are going to look in the spring at integrating Google apps with their EDRMS so that it becomes easier for colleagues to save e-mails needed as records.  They may also start working with Google Sites at some point (which would bring the implementation into the filesharing /collaboration space).

G-cloud and security

The Council said one of the benefits of G-cloud for them was that they did not have to think through on their own and from scratch  the questions of security in the cloud and personal data in the cloud.   A lot of the thinking had been done centrally, on a public sector wide basis   (with the caveat that individual public sector bodies still have to assess the risks arising from their own information systems and make decisions appropriate to that level of risk).

CESG (the Government’s National Technical Authority for Information Assurance) is carrying out information assurance checks on every service that applies to join the CloudStore framework, as part of the accreditation process.

CESG has come up with a classification of business impact levels (here is the pdf)to enable public sector bodies to assess the impact of any particular type of information being compromised.    Business impact level 2 corresponds broadly to the government security classification of ‘protect’.  This is information that the government does not want to see in the public domain, but if it got in the wrong hands  the damage would be more inconvenient than disastrous.  Business impact level 3 corresponds broadly to the government security classification ‘Restricted’ – this is information where there could be serious consequences (to individuals, organisations, commercial interests or the nation as a whole) if the information got into the wrong hands.

For example personal data whose compromise is  unlikely to put an individual in danger is likely to be regarded as impact level 2, whereas personal data whose compromise could put an individual in danger is likely to be marked as Impact level 3 or above.  Impact level 2 covers vast swathes of government work.

Both Google Apps and Microsoft’s Office 365 have been accredited up to Impact level 2.  We were told that some of the vendors had started to show an interest in being able to offer a service accredited for impact level 3 information, but for at least the short term the CloudStore would not be catering for impact level 3 information.

One IT manager told us that the point of the cloud services is that it caters for the majority of government’s needs, not for all their needs. She said it may be that public  bodies simply made separate provision for restricted documentation and e-mail – even if it meant having separate booths dotted around the office with computers staff could use for  ‘restricted’ communications.

G-cloud, data protection, and the issue of storing data outside of the EU

One of the big concerns with cloud adoption has been the 8th data protection principle (present in the data protection legislation of every EU member state) which states that personal data should not be transferred outside the European Economic Area unless that country or territory ‘ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data’.

There is also  a wider concern that where information is stored out of the country, and particularly when it is stored outside the EU, then it comes under a legal framework that the UK cannot control (for example many countries have legislation giving their governments powers of inspection, on security grounds, of information held in their territory).

The speakers at the meeting referred  to Cabinet Office Guidance on Government ICT offshoring. The guidance states that no information with a national security implication should be stored outside the country (whatever the impact level).

Personal data is a slightly different matter-  the Cabinet Office guidance does not forbid personal data being stored outside the EU, provided measures are in place to ensure that the contractor treats the data in an ‘adequate’ manner (‘adequate’ meaning compliant with EU data protection principles and practice), and provided the security in the system is appropriate to the impact level of the information.  The guidelines give three ways of ensuring that a contractor operating from overseas has an ‘adequate’  data protection regime – safe harbor, model clauses and binding corporate rules.

The safe harbor scheme was set up jointly by the EU and the US.  Individual US companies that sign up for the safe harbour scheme are considered ‘adequate’ by the EU and therefore the UK public sector is not contravening this principle by storing such data with these companies.   The safe harbor arrangement has been criticised by some commentators.  Chris Connolly said ‘The Safe Harbor is best described as an uneasy compromise between the comprehensive legislative approach adopted by European nations and the self–regulatory approach preferred by the US’.     However this article from The Register last month predicts that the safe harbour arrangement will survive the proposed forthcoming overhaul of EU data protection legislation.

The second of the measures is model contract clauses with companies to ensure that the company operates ‘adequate’ protections in relation to the data it stores under the contract.  The European Commission has drawn up some such clauses and the so has the UK Government.

Binding corporate rules are where the Government accepts that the internal policies of a company operating both within and outside the EU are strong enough to ensure that an ‘adequate’ data protection regime is operated across the whole company (and not just inside the EU).  The guidance states that such corporate rules are an alternative to model contract clauses and must be approved by a relevant data privacy supervisory authority ( the Information Commissioner in the UK, or an equivalent in another member state).

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