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CLOUD COMPUTING: WHAT ARE THE SECURITY 

IMPLICATIONS? 

HEARING 

BEFORE THE

SUBCOMMITTEE ON CYBERSECURITY, 

INFRASTRUCTURE PROTECTION, 

AND SECURITY TECHNOLOGIES 

OF THE

COMMITTEE ON HOMELAND SECURITY 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED TWELFTH CONGRESS 

FIRST SESSION 

OCTOBER 6, 2011 

Serial No. 112–50 

Printed for the use of the Committee on Homeland Security 

Available via the World Wide Web: http://www.gpo.gov/fdsys/ 
(II) 

COMMITTEE ON HOMELAND SECURITY 

PETER T. KING, New York, Chairman 

LAMAR SMITH, Texas 

DANIEL E. LUNGREN, California 

MIKE ROGERS, Alabama 

MICHAEL T. MCCAUL, Texas 

GUS M. BILIRAKIS, Florida 

PAUL C. BROUN, Georgia 

CANDICE S. MILLER, Michigan 

TIM WALBERG, Michigan 

CHIP CRAVAACK, Minnesota 

JOE WALSH, Illinois 

PATRICK MEEHAN, Pennsylvania 

BEN QUAYLE, Arizona 

SCOTT RIGELL, Virginia 

BILLY LONG, Missouri 

JEFF DUNCAN, South Carolina 

TOM MARINO, Pennsylvania 

BLAKE FARENTHOLD, Texas 

ROBERT L. TURNER, New York 

BENNIE G. THOMPSON, Mississippi 

LORETTA SANCHEZ, California 

SHEILA JACKSON LEE, Texas 

HENRY CUELLAR, Texas 

YVETTE D. CLARKE, New York 

LAURA RICHARDSON, California 

DANNY K. DAVIS, Illinois 

BRIAN HIGGINS, New York 

JACKIE SPEIER, California 

CEDRIC L. RICHMOND, Louisiana 

HANSEN CLARKE, Michigan 

WILLIAM R. KEATING, Massachusetts 

KATHLEEN C. HOCHUL, New York 

JANICE HAHN, California 

MICHAEL J. RUSSELL, Staff Director/Chief Counsel 

KERRY ANN WATKINS, Senior Policy Director 

MICHAEL S. TWINCHEK, Chief Clerk 

I. LANIER AVANT, Minority Staff Director 

SUBCOMMITTEE ON CYBERSECURITY, INFRASTRUCTURE PROTECTION, 

AND SECURITY TECHNOLOGIES 

DANIEL E. LUNGREN, California, Chairman 

MICHAEL T. MCCAUL, Texas 

TIM WALBERG, Michigan, Vice Chair 

PATRICK MEEHAN, Pennsylvania 

BILLY LONG, Missouri 

TOM MARINO, Pennsylvania 

PETER T. KING, New York (Ex Officio) 

YVETTE D. CLARKE, New York 

LAURA RICHARDSON, California 

CEDRIC L. RICHMOND, Louisiana 

WILLIAM R. KEATING, Massachusetts 

BENNIE G. THOMPSON, Mississippi (Ex Officio) 

COLEY C. O’BRIEN, Staff Director 

ALAN CARROLL, Subcommittee Clerk 

CHRIS SCHEPIS, Minority Senior Professional Staff Member 
(III) 

C O N T E N T S 

Page 

STATEMENTS 

The Honorable Daniel E. Lungren, a Representative in Congress From the 

State of California, and Chairman, Subcommittee on Cybersecurity, Infrastructure Protection, and Security Technologies ............................................... 1 

The Honorable Bennie G. Thompson, a Representative in Congress From 

the State of Mississippi, and Ranking Member, Committee on Homeland 

Security ................................................................................................................. 3 

WITNESSES 

PANEL I 

Mr. Richard Spires, Chief Information Officer, U.S. Department of Homeland 

Security: 

Oral Statement ..................................................................................................... 5 

Prepared Statement ............................................................................................. 6 

Mr. David McClure, Ph.D., Associate Administrator, Office of Citizen Services 

and Innovative Technologies, U.S. General Services Administration: 

Oral Statement ..................................................................................................... 12 

Prepared Statement ............................................................................................. 14 

Mr. Gregory C. Wilshusen, Director of Information Security Issues, Government Accountability Office: 

Oral Statement ..................................................................................................... 18 

Prepared Statement ............................................................................................. 19 

PANEL II 

Mr. James W. Sheaffer, President, North American Public Sector, Computer 

Sciences Corporation: 

Oral Statement ..................................................................................................... 38 

Prepared Statement ............................................................................................. 40 

Mr. Timothy Brown, Senior Vice President and Chief Architect for Security, 

CA Technologies: 

Oral Statement ..................................................................................................... 43 

Prepared Statement ............................................................................................. 45 

Mr. James R. Bottum, Vice Provost for Computing and Information Technology and Chief Information Officer, Clemson University: 

Oral Statement ..................................................................................................... 52 

Prepared Statement ............................................................................................. 54 

Mr. John Curran, Chief Executive Officer, American Registry of Internet 

Numbers: 

Oral Statement ..................................................................................................... 62 

Prepared Statement ............................................................................................. 64 

APPENDIX 

Questions From Honorable William Keating For Richard Spires ....................... 73 

(1) 

CLOUD COMPUTING: WHAT ARE THE 

SECURITY IMPLICATIONS? 

Thursday, October 6, 2011 

U.S. HOUSE OF REPRESENTATIVES, COMMITTEE ON HOMELAND SECURITY, SUBCOMMITTEE ON CYBERSECURITY, INFRASTRUCTURE

PROTECTION, AND SECURITY TECHNOLOGIES, Washington, DC. 

The subcommittee met, pursuant to call, at 10:02 a.m., in Room 

311, Cannon House Office Building, Hon. Daniel E. Lungren 

[Chairman of the subcommittee] presiding. 

Present: Representatives Lungren, Walberg, Marino, Clarke, 

Richardson, Keating, and Thompson. 

Also present: Representative Duncan. 

Mr. LUNGREN. We have been informed that we are probably 

going to have votes at 8—I mean, at 10:20, or something, and then 

have about four or five votes, and so we will have a delay for our 

hearing for about 45 minutes. So we are going to try and get started very quickly, get our opening statements in and begin your testimony, and then we will have to break and beg your indulgence 

on that. 

The Committee on Homeland Security Subcommittee on Cybersecurity, Infrastructure Protection, and Security Technologies will 

come to order. The subcommittee is meeting today to examine the 

security implications of cloud computing. I would recognize myself 

for an opening statement. 

We welcome our witnesses today and look forward to their testimonies regarding cloud computing phenomena. According to NIST, 

cloud computing delivers I.T. services and applications to users by 

enabling ubiquitous, convenient, on-demand network access to a 

shared pool of configurable computing resources. 

Cloud computing enables organizations and individuals to access 

website data and on-line programs without concern about the server’s physical location, thereby promising cheaper, faster, more flexible, more effective information technology. Most organizations already utilize some form of cloud computing. On-line shopping and 

banking are prime examples of how cloud computing has transformed the way in which companies interact with and provide online services to customers. 

Improved technologies over the years have increased our computing capabilities and reduced costs. This new cloud technology 

also promises greater I.T. capability at reduced cost. 

The administration has issued a Cloud First policy to accelerate 

the pace at which Government evaluates safe and secure cloud 
2 

computing options before making any new I.T. investment. Republican Members of Congress, and I hope our Democratic colleagues, 

are always looking for ways to reduce Government spending, so 

any savings from cloud computing would, indeed, be welcome. 

However, in spite of this projected I.T. savings, we cannot ignore 

our responsibility as Members of this Cybersecurity Subcommittee 

to assure that Government information will be secure in the cloud. 

GAO reported last spring that security incidents at Government 

agencies rose 650 percent over the last 5 years. 

Our concern is the cloud offers—that the cloud offers a rich target for hackers, criminals, terrorists, and rogue nations. With 

cyber-espionage affecting every sector of our economy, aggregating 

important information in one location is a legitimate security concern. You might say it is a target-rich environment. 

Security implications cannot be an afterthought. Obviously, they 

need to be considered as cloud technology is being developed and 

deployed. 

Yesterday we Republicans released our House task force recommendation for cybersecurity legislation. We intend to work with 

our colleagues on the other side of the aisle because this is not a 

partisan issue; it is one that we need more work on, and I do believe there is a bipartisan commitment to provide that work. 

Speaker Boehner has made cybersecurity a top priority, and our 

committee will be a key player in drafting House legislation. 

So as we address our numerous cyber vulnerabilities we must 

scrutinize new technologies and their attendant risks to ensure 

that further vulnerabilities will not be created. Cloud advocates 

argue that even sensitive data can be secure in the cloud. They 

argue that the cloud providers have the resources to invest at sophisticated security—in sophisticated security systems if necessary. 

Different security levels can be designed for the various cloud 

configurations. The private cloud is appropriate for classifying the 

most sensitive of personnel data, we are told. Sensitive data can 

be—can use the hybrid model; nonsensitive data can use the public 

cloud. 

While I.T. savings are important, we cannot ignore the information security risk created by cloud technology. Assessing those risks 

responsibly will be critical if cloud computing is ever going to be 

widely accepted. 

The Federal cloud computing strategy is designed to ensure the 

security of Government information and establish a transparent security environment between cloud service providers and the Federal Government. NIST and the General Services Administration 

have developed the Federal Risk and Authorization Management 

Program, FedRAMP, to facilitate and lead the development of 

standards for security, interoperability, and portability. 

The strategy states that the transition to a cloud computing environment is an exercise in risk management that entails identifying 

and assessing risk and taking steps to reduce it to an acceptable 

level. We look forward to the testimony of Dr. McClure, from GSA, 

will outline this important FedRAMP program. 

Today we intend to examine the benefits and risks of cloud computing, and hopefully identify its security implications. I look for-
3 

ward to the testimony of all of our witnesses this morning regarding this new cloud technology. 

I would now recognize the Ranking Member of the full committee, Mr. Thompson, for any statement that he might make. 

Mr. THOMPSON. Thank you very much, Mr. Chairman. Before I 

begin my statement, let me take off on your comments about the 

Republican caucus’ release of its cyber task force recommendations 

yesterday. 

As you know, cyber is an emerging homeland security threat that 

warrants timely bipartisan action from Congress. The stakes are 

high and Federal networks alone have seen a 650-fold increase in 

cyber attacks over the past 5 years. 

As you know, the President has submitted to Congress a comprehensive plan, including a legislative proposal. Taking your comments that you look forward to a bipartisan effort on this issue, I 

can assure you from our side of this committee, we will do just 

that. 

With respect to this morning’s hearing on security implications 

of cloud computing, cloud computing can and does mean different 

things to different people. The National Institute of Standards and 

Technology, NIST, has published a definition that provides a starting place for discussing and defining security needs, but not everyone agrees with or conforms to NIST’s definition. So as of today, 

the Federal Government and industry have not reached agreement 

about how uniform rules and standards that should be adopted to 

secure the information in the cloud. 

This is not something that can be left up in the air. While I embrace technological progress, I also know that every new technology 

presents great possibilities as well as great challenges. In our eagerness to jump on the bandwagon we often forget to ask about the 

destination of the wagon, the cost of the journey, and the roads 

which we will take along the way. 

As we embark on this new journey of migrating information to 

the cloud we must not repeat mistakes of the past. We must be 

about some of the claims that are made. 

For instance, I am told that the cloud will produce cost savings 

and create efficiencies. I am told that these benefits will be 

achieved by eliminating the need for data centers, computer hardware, and other public and private sector operations that employ 

thousands of people. I have to ask about these displaced people. 

While every new technology creates displacement, it also provides opportunities. So we must ask what new opportunities will be 

provided and who will benefit? 

Finally, as cloud computing increases the Federal Government’s 

ability to communicate effectively, we must ask how to increase the 

ability to communicate will affect the security of Government operations. 

Mr. Chairman, without clear standards and uniform rules we 

cannot begin to evaluate how the security of Government data will 

be affected by cloud computing. Additionally, we must remember 

that cloud computing must be aligned with the Federal Information 

Security Management Act, FISMA. 

Given that the Federal Government currently uses the services 

of external vendors to manage its cloud operations, we must ask 
4 

how these businesses will comply with FISMA regulations governing auditing and security requirements. Industries cannot effectively compete without understanding the potential regulatory environment that will be caused by widespread use of cloud computing in the Federal Government. 

Mr. Chairman, there are many questions that must be resolved. 

However, I am certain that our witnesses today will be able to 

shine some light on the cloud. 

I yield back. 

Mr. LUNGREN. Thank you very much, Ranking Member, for that 

poetic opening statement. 

When the Ranking Member of the subcommittee appears we will 

give her an opportunity to make her opening statement. Other 

Members of the committee are reminded that opening statements 

may be submitted for the record. 

We are pleased to have a very distinguished panel of witnesses 

before us today on this important topic. 

Richard Spires was appointed as the chief information officer of 

the Department of Homeland Security 2009. He has extensive 

knowledge in senior level operations and information technology 

issues through working both the public and the private sectors. 

Previously oversaw I.T. responsibilities for the Internal Revenue 

Service as deputy commissioner for operations support, chief information officer and associate information officer for business systems modernization respectively. 

Before joining the IRS he served as the president, chief operation 

officer, and director of Mantas, Inc., a software product vendor. He 

also spent more than 16 years at SRA International, a systems integration company. 

Welcome. 

Dr. David McClure was appointed associate administrator of the 

U.S. General Services Administration’s Office of Citizen Services 

and Innovative Technologies in 2009. Dr. McClure most recently 

served as the managing vice president for Gartner, Inc.’s government research team. 

Before working at Gartner, Dr. McClure served as vice president 

for e-government and technology at the Council for Excellence in 

Government. He has also had an 18-year career with the Government Accountability Office. 

Greg Wilshusen—is that the proper—— 

Mr. WILSHUSEN. Perfect. 

Mr. LUNGREN. Thank you—is director of information security 

services at the Government Accountability Office. He has spent 

over 28 years of auditing, financial management, and information 

systems prior to this date. 

Prior to joining GAO in 1997, he was the senior systems analyst 

at the Department of Education and served as the comptroller for 

the North Carolina Department of Environment, Health, and Natural Resources; and held senior auditing positions at Irving Burton 

Associates, Inc. and the U.S. Army Audit Agency. 

Thank you, gentleman, for all being here. We have the rule of a 

5-minute testimony. We have your written statements; they will be 

included in their totality in the record. We would ask you to go in 

the order in which I introduced you. 
5 

So, Mr. Spires, the Chairman would now recognize you. 

STATEMENT OF RICHARD SPIRES, CHIEF INFORMATION 

OFFICER, U.S. DEPARTMENT OF HOMELAND SECURITY 

Mr. SPIRES. Chairman Lungren, Mr. Thompson, and Members of 

the subcommittee, thank you and good morning. Today I will discuss the changes cloud computing is having within the Government 

and at the Department of Homeland Security. Also, I will discuss 

how DHS is addressing the security challenges associated with 

cloud computing. 

Simply, cloud computing enables Federal agencies to purchase 

on-demand I.T. services using a consumption-based business model. 

Liken cloud computing to the electric power or telecommunications 

markets: we, as customers, pay for the usage of the service itself, 

whether it be so much per kilowatt-hour for electric power or minutes of usage for the use of our cell phone. As I.T. matures, many 

services are becoming commoditized and lend themselves to such a 

usage-based model. 

Cloud computing is truly transforming the I.T. business because 

it does provide significant benefits to customers. The cloud provides 

scalability and rapid deployment, full transparency for managing 

operational costs, and controlling and reducing capital expenses. 

Further, cloud computing simplifies the overall administration 

and cost of I.T. infrastructure. Early projections for DHS look to 

yield cost avoidance savings of 8 to 10 percent once we transition 

to cloud infrastructure services. 

DHS is taking an aggressive approach to the use of cloud computing, with 12 DHS offerings either in production, awarded, or in 

the acquisition phase. DHS is currently focused on two deployment 

models: Our private cloud and the use of the public cloud. 

For the DHS private cloud, we manage sensitive information 

within our two enterprise data centers and use our internal widearea network. A few examples of DHS private cloud offerings include our Email as a Service, which we expect to have more than 

100,000 users live by the end of fiscal year 2012. 

SharePoint as a Service will support more than 90,000 users by 

the end of this calendar year. Development and Test as a Service 

provides a development and test environment linked to the production environment we enable—to enable successful deployment of 

new applications. We expect to provision new servers within 1 business day with this new capability, while the legacy model averaged 

up to 6 months. 

WorkPlace as a Service will provide secure, virtual desktop access that seamlessly support mobile devices, to include cell phones 

and tablets. This service will better enable a mobile DHS workforce 

to support telework and continuity of operations. 

We are embracing the use of public cloud services to manage 

nonsensitive information. DHS has successfully deployed Self 

Check in the public cloud, and over the next 2 years will consolidate its public-facing websites, like dhs.gov, to the public cloud. 

To effectively manage security risks of cloud computing DHS is 

leveraging our private cloud environment to enable services to 

manage sensitive information. The model bolsters information security through our defense-in-depth strategy. 
6 

By hosting in the enterprise data centers the DHS private cloud 

can leverage the existing enterprise security controls as well as leverage the use of our continuous monitoring capabilities and trusted internet connections. By embedding enhanced enterprise security controls in our private cloud, DHS will provide security assurance exceeding that of our existing legacy systems. 

For public clouds there is a visibility gap between the provider 

and customer in which they cannot see into each other’s management, operational procedures, and technical infrastructure. To address security concerns of public cloud offerings, this visibility gap 

must be reduced through a series of requirements for contractual 

reporting and technical auditing and continuous monitoring data 

feeds to verify that the provider and customer are meeting their responsibilities. 

The FedRAMP program will help Federal agencies address these 

challenges as they leverage public cloud providers or establish their 

own private cloud. Continued work on the information security 

challenges will increase the defensive capabilities of cloud offerings, 

increasing the assurance level and the ability for Federal agencies 

to use public cloud computing for more sensitive information. 

Looking ahead 5 years, the cloud service commodity market appears poised to grow exponentially. Federal CIOs must focus on 

preparing departments and agencies to welcome innovation and 

changes in the way we do business. Already, at DHS we are seeing 

reduced time to market for new capabilities, reducing our capital 

expenditures, and gaining transparency into our operational expenses, all while providing improved service. 

The benefits of cloud computing far outweigh the challenges. 

Thank you. 

[The prepared statement of Mr. Spires follows:] 

PREPARED STATEMENT OF RICHARD SPIRES

OCTOBER 6, 2011 

Chairmen Lungren, Ranking Member Clarke, and Members of the subcommittee, 

thank you and good morning. Today, I will discuss the changes Cloud Computing 

is having within the Government and industry and how the Department of Homeland Security (DHS) is pursuing this capability to enhance mission performance and 

gain efficiencies in Information Technology (IT). This testimony also will provide an 

overview of the current state of cloud computing at the Department of Homeland 

Security, outlining the Department’s initiatives to move data to the cloud in order 

to implement the White House’s ‘‘Cloud First’’ policy as specified in the ‘‘Federal 

Cloud Computing Strategy’’ issued February 8, 2011, and the ‘‘25 Point Implementation Plan to Reform Federal Information Technology Management’’ issued December 

9, 2010. Finally, I will address the IT security challenges associated with cloud computing and how DHS is addressing such challenges. 

MOVING TO THE CLOUD

First, allow me to explain what cloud computing is and why it is so vital. The 

legacy IT model of separate IT infrastructures for each system—both within the 

Federal Government and industry—must evolve to meet the growing customer demands within a budget-constrained environment. The traditional model is not wellpositioned to reduce time to market for new services or provide transparency for 

operational expenses. It also introduces higher risk due to up-front capital expenditures. Additionally, customized applications hosted in traditional data center environments cannot scale fast enough to support urgent demand in real-time. These 

challenges, in addition to potential security vulnerabilities, present a call to action 

for the Federal Government and industry. 
7 

Fortunately, we are experiencing an exciting change within the IT industry—the 

rise of cloud computing. This evolutionary transformation is fast replacing the legacy IT model not only within private industry but also within the Federal Government. 

The National Institute of Standards and Technology (NIST), an agency of the U.S. 

Department of Commerce, provides the following definition of cloud computing in 

NIST Special Publication 800–145 (NIST SP 800–145): 

‘‘Cloud computing is as a model for enabling convenient, on-demand network access 

to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with 

minimal management effort or service provider interaction. This cloud model promotes availability and is composed of five essential characteristics, three service 

models, and four deployment models.’’ 

Cloud computing provides the rapid delivery of computing resources inexpensively 

to multiple users from a centralized source of related and unique service offerings 

that is shared by many customers. To provide further context, this model is similar 

to business models deployed in the electric power, cable, or telecommunications markets. That is, within this model, customers do not fund up-front costs to fully stand 

up environments, or fund on-going operations and maintenance costs. Instead these 

capital costs are borne by industry, while the customer only pays for services received in the consumption-based model. 

NIST prescribes the following five primary characteristics of cloud computing: 

1. On-demand self-service.—A consumer can unilaterally provision computing 

capabilities, such as server time and network storage, as needed automatically 

without requiring human interaction with each service’s provider. 

2. Broad network access.—Capabilities are available over the network and 

accessed through standard mechanisms. 

3. Resource pooling.—The provider’s computing resources are pooled to serve 

multiple consumers using a multi-tenant model, with different physical and virtual resources dynamically assigned and reassigned according to consumer demand. 

4. Rapid elasticity.—Capabilities can be rapidly and elastically provisioned, in 

some cases automatically, to quickly scale out, and rapidly released to quickly 

scale in. To the consumer, the capabilities available for provisioning often appear to be unlimited and can be purchased in any quantity at any time. 

5. Measured Service.—Cloud systems automatically control and optimize resource use by leveraging a metering capability at some level of abstraction appropriate to the type of service. Resource usage can be monitored, controlled, 

and reported, providing transparency for both the provider and consumer of the 

utilized service. 

NIST also identifies three discrete service offerings, each of a unique value to the 

customer. As customers move up this offering chain, they gain greater efficiencies, 

yet more standardization is required: 

1. Cloud Infrastructure as a Service (IaaS).—The capability provided to the consumer is to provision processing, storage, networks, and other fundamental 

computing resources where the consumer is able to deploy and run arbitrary 

software, which can include operating systems and applications. The consumer 

does not manage or control the underlying cloud infrastructure but has control 

over operating systems, storage, deployed applications, and possibly limited control of select networking components (e.g., host firewalls). This model provides 

the most flexibility for the customer, however will not provide all the potential 

efficiencies gained at the Software as a Service model. 

2. Cloud Platform as a Service (PaaS).—The capability provided to the consumer is to deploy onto the cloud infrastructure consumer-created or acquired 

applications created using programming languages and tools supported by the 

provider. The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, or storage, but has control over the deployed applications and possibly application hosting environment 

configurations. 

3. Cloud Software as a Service (SaaS).—The capability provided to the consumer is to use the provider’s applications running on a cloud infrastructure. 

The consumer does not manage or control the underlying cloud infrastructure 

including network, servers, operating systems, storage, or even individual application capabilities, with the possible exception of limited user-specific application configuration settings. 

Finally, NIST identifies four primary deployment models, which are generally accepted across Government. These deployment models range from models that are 
8 

more secure to those that are more available. Federal agencies will employ models 

based on risk-based decisions that address their financial, operational, and security 

needs. The four models include: 

1. Private cloud.—The cloud infrastructure is operated solely for an organization. It may be managed by the organization or a third party and may exist onpremise or off-premise. 

2. Community cloud.—The cloud infrastructure is shared by several organizations and supports a specific community that has shared concerns (e.g., mission, 

security requirements, policy, and compliance considerations). It may be managed by the organizations or a third party and may exist on-premise or offpremise. 

3. Public cloud.—The cloud infrastructure is made available to the general public or a large industry group and is owned by an organization selling cloud services. 

Hybrid cloud.—The cloud infrastructure is a composition of two or more clouds 

(private, community, or public) that remain unique entities but are bound together by standardized or proprietary technology that enables data and application portability (e.g., cloud bursting for load-balancing between clouds). 

DHS is currently focused on two of the four deployment models, private cloud and 

public cloud. DHS will house our private cloud computing capabilities within our 

two enterprise data centers, while our public cloud will be hosted by organizations 

selling cloud services. I will provide more detail on these momentarily, but first 

allow me to briefly address the differences between the cloud and the traditional IT 

business model. 

THE BENEFITS AND RISKS OF CLOUD COMPUTING

Cloud computing is truly transforming the IT business. It is difficult to say which 

is more compelling—the cloud’s significant scalability and rapid deployment, or full 

transparency for managing operational costs. For many, controlling and reducing 

capital expense (the expenditures used to acquire physical assets, including both 

equipment and office space) is uppermost, while others argue meeting demand is the 

foremost concern. The cloud addresses both and is clearly becoming vital to how we 

align IT to support mission and business requirements. 

For example, the deployment of private cloud services at DHS enables the Department’s many components to outsource hosting and other services capabilities to 

DHS’s two Enterprise Data Centers (EDCs). This model enables components to pay 

on a per-use basis, rather than standing up isolated capabilities throughout the organization that duplicate efforts and costs. In fact, early projections for these services look to yield cost avoidance savings of 8 to 10 percent once we fully transition 

to private cloud infrastructure services. 

As DHS moves more of its operations to cloud computing models, it will simplify 

the overall administration and oversight of its IT infrastructure. DHS will move 

from having to manage operations of its infrastructure at the server level, to one 

in which DHS ensures that cloud-based service level agreements (SLAs) are being 

met by the service provider. Such simplification will enable discretionary resources 

to be moved to better understanding and fulfilling customer needs, so that IT organizations can focus more of their efforts on addressing core business and mission 

needs. 

Migration to the cloud, however, is not without information security risks. The 

Federal Cloud Computing Strategy specifies: 

. . . it is not sufficient to consider only the potential value of moving to cloud services. Agencies should make risk-based decisions which carefully consider the readiness of commercial or government providers to fulfill their Federal needs. 

It is important to recognize that many Federal departments and agencies are targeted by Advanced Persistent Threat (APT) campaigns by adversaries that attempt 

to compromise Government information systems to further their own objectives. 

These APT campaigns are aggressive, well-financed, and difficult to detect and prevent. APTs target the systems necessary to achieve their goals, regardless of the 

cloud or traditional computing environments in use by the Federal department or 

agency. Some cloud environments have capabilities necessary to defend against and 

provide recovery from these threats, such as advanced monitoring capabilities and 

cleared information security professionals, while other cloud environments may not, 

because the increased costs to provide these security capabilities may price their 

cloud offering outside of the competitive marketplace for their customers. Thus, the 

security capabilities of the cloud offering must be considered to determine cloud 
9 

readiness before use by a Federal department or agency, and why DHS considers 

use of both public and private cloud computing important, as I will discuss later. 

BUILDING THE CLOUD AT DHS

At DHS, we are pursuing private and public cloud offerings. Specifically, we are 

establishing private cloud services to manage sensitive but unclassified information, 

while using the public cloud for non-sensitive information. We have already made 

significant strides through nine DHS cloud service offerings that are either in the 

planning, acquisition, or sustainment phase. 

DHS has committed to nine current and planned private cloud services: 

• Email as a Service (EaaS).—DHS is in the process of rolling out our messaging 

capability across Headquarters and Federal Emergency Management Agency 

(FEMA). We expect to have more than 100,000 users DHS-wide on this service 

offering by the end of fiscal year 2012. 

• SharePoint as a Service (SHPTaaS).—We are currently migrating Headquarters 

and United States Citizenship and Immigration Services (USCIS) users to our 

secure collaboration program. We expect to have nearly 90,000 users DHS-wide 

on this service by the end of the 2011 calendar year. This migration will significantly improve information-sharing capabilities across DHS. 

• Development and Test as a Service (DTaaS).—Establishing development and 

test offerings in the cloud will have tremendous positive impact on DHS. Currently, DHS has multiple development environments spread across the Department and industry locations. Because all environments are different, moving 

new releases to production or changes to existing environments presents highrisk and multiple challenges and new releases or changes may not always work 

in production, leading to significant inefficiencies. Moving and hosting development and test services to our enterprise data centers provides not only a simple 

path to transition from project creation to implementation, but also accelerated 

delivery. In fact, we expect to provision new servers within 1 business day with 

this new capability, while the legacy model averaged up to 6 months to provision one server. Additionally, this service will provide on-demand testing and 

application management tools, which will significantly improve the quality of 

our new offerings. DHS plans to roll out DTaaS over the next 60 days. 

• Infrastructure as a Service (IaaS).—Complementary to the Development and 

Test as a Service (DTaaS) offering is our Infrastructure as a Service (IaaS) offering to provide virtualized production services, including operating systems, 

network, and storage, that is consistent with new industry standards. These 

services will provide a logical destination for code developed in the development 

and test environment. We aim to stand up new services in the cloud in less 

than 1 week, while the legacy model typically averaged up to 12 to 18 months. 

DHS expects to have initial IaaS capabilities by the end of the 2011 calendar 

year. 

• WorkPlace as a Service (WPaaS).—Enabling a mobile workforce is a priority 

within the Department. We are working closely with the Department’s other 

line-of-business chiefs to modernize how DHS employees work. This offering will 

provide robust virtual desktop, remote access, and other mobile services over 

the next 24 months. This capability enables telework and Continuity of Operations (COOP), not only in the National Capital Region (NCR), but for DHS personnel Nation-wide. Additionally, we expect to reduce our out-year expenditures 

on traditional desktop and laptops as we consume more mobile enabling technologies. 

• Project Server as a Service (PSaaS).—This offering will provide a robust project 

management platform to publish project schedules that can more easily be 

shared across offices, divisions, and components. We expect this service to better 

enable standardization of project management disciplines and directly support 

our efforts to improve the management of both IT and non-IT programs. DHS 

plans to make available PSaaS service within the next 30 days. 

• Authentication as a Service (AuthaaS).—We have already established a core 

fundamental offering that provides robust authentication services across 

250,000 Federal and contractor employees. This service eliminated the need for 

duplicative authentication services, while significantly enhancing the Department’s information-sharing needs. Nearly 70 DHS applications are using this 

service today. 

• Case and Relationship Management as a Service (CRMaaS).—Over the next 6 

months, we will rollout our Case and Relationship Management offering. This 

offering, leveraging Enterprise License Agreements (ELAs), will better enable 

CRM and case workflows across DHS. Utilizing these services, the Department 
10 

will be piloting a litigation case management capability for ICE, partnering 

with TSA on modernizing the redress service, improving customer relationship 

capabilities within USCIS, and deploying a regulations tracking service for 

DHS. • Business Intelligence as a Service (BIaaS).—The Department is already piloting 

an early version of a Business Intelligence capability which started in March 

2011 and will run through fiscal year 2012. The Department will leverage this 

current offering to enhance transparency into departmental programming and 

expenditures. By the end of fiscal year 2012, we expect the Department will 

have visibility to information sources across the investment life-cycle, including 

IT, financial, human resources, asset management, and other information 

sources. Based on the successful pilot and maturing offerings in service, the Department will look to move to a full Business Intelligence as a Service offering 

in fiscal year 2013. 

Establishing these private cloud services is critical to our success. Our private 

cloud offerings will provide real value to the organization. As mentioned previously, 

private cloud services will enable components to outsource secure, commodity IT 

services to DHS’s two enterprise data centers to eliminate redundancy and reduce 

costs, while ensuring information security. Each service will be rolled out with a 

minimum ‘‘Federal Information Security Management Act of 2002’’ (FISMA) rating 

of Moderate or High. Clearly, our private cloud services will streamline our time to 

market and enhance our security posture, better enabling DHS to accomplish its 

mission. 

But DHS is not wedded to only establishing private cloud services at its two enterprise data centers. We are embarking on a public cloud strategy as well. The Department will leverage public cloud capabilities to enhance Government-to-citizenservices and gain operational and financial efficiencies. In addition, the FedRAMP 

initiative will address critical security concerns of agency Chief Information Officers 

(CIOs) over the next few years by having cloud services receive provisional security 

authorities to operate. 

The Department has three public cloud initiatives underway. Two are already deployed, and the third will be piloting in Quarter 1 of fiscal year 2012. • Identity Proofing as a Service (IDPaaS).—We successfully deployed an innovative identity proofing service in the cloud in March 2011. This offering met 

USCIS’s EVerify Self Check requirement to allow individuals in the United 

States to check their employment eligibility status before formally seeking employment and is the first on-line E-Verify program offered directly to workers 

and job seekers. This service is now available in more than 20 States, including 

the District of Columbia. This voluntary, free, fast, and secure service was developed through a partnership between the DHS and the Social Security Administration (SSA). 

• Enterprise Content Delivery as a Service ECDaaS.—For the past several years, 

DHS has used cloud service for Enterprise Content Delivery (ECD) to ensure 

our public-facing websites are always available. The private sector uses this capability extensively, and DHS adopted EDC for protection against denial of 

service attacks, to help manage surge requirements, and to significantly reduce 

hosting costs. This service proved invaluable during the July 4, 2009, denial of 

service attack on multiple Federal websites. DHS.gov experienced a nearly 100- 

fold increase in traffic, and no services were lost to the public. The Department 

has 70% of its externally-facing websites using this service today. 

• Web Content Management as a Service (WCMaaS).—Finally, building off our 

success with our ‘‘RestoretheGulf.gov’’ implementation in the public cloud in 

late fiscal year 2010, the Department awarded a public cloud hosting contract 

off the General Services Administration’s (GSA) Infrastructure as a Service 

(IaaS) Blanket Purchase Agreement (BPA). Within this offering, the Department will leverage open source software hosted in the public cloud and consolidate all public-facing DHS websites. We expect to complete this consolidation 

over the next 2 years. During the next 6 months, the Department will pilot multiple websites in the cloud, including websites from U.S. Immigration and Customs Enforcement (ICE), United States Citizenship and Immigration Services 

(USCIS), and Federal the Emergency Management Agency (FEMA). 

DHS has taken an aggressive stance regarding the use of both private and public 

cloud computing services. The Department continues to evaluate its enterprise 

needs, and we certainly expect to deploy additional cloud services. Further, as the 

FedRamp model is deployed across the Federal Government, we anticipate that 

there will be a number of public cloud offerings that have been provisionally certified at the FISMA Low and Moderate levels within the next 2 years. Given DHS’s 

mission, we believe a robust private cloud solution will always be needed for DHS’s 
11 

most sensitive applications and data. Further leverage of public cloud services will 

enable the Government to ensure there is robust competition for such services, driving down costs and improving overall service levels. 

SECURING THE CLOUD AT DHS

As stated earlier, at DHS, we are pursuing private and public cloud offerings, and 

the DHS cloud security strategy employs both public and private cloud services as 

a risk mitigation tool. The move to DHS’s private cloud model bolsters information 

security through the DHS IT security Defense-in-Depth (DiD) strategy. DiD is built 

upon a robust security architecture and enterprise architecture, and adopts the 

NIST definition of private cloud computing. Hosting in the enterprise data centers 

is a primary feature of the DHS private cloud and provides multiple subordinated 

services, allowing components and systems to inherit the inherent enterprise security controls for system security. The DHS private cloud includes the full DHS enterprise security capabilities outlined in the DiD, including security operations, 

OneNet, Trusted Internet Connections (TICs), and Policy Enforcement Points 

(PEPs). The technologies are from the various programs within the layers of the DiD 

and aids in combating advanced threats, providing enterprise security controls to all 

users in DHS, regardless of their component and mission function. 

For the DHS private cloud, we are leveraging continuous monitoring and migration to common controls at the DHS data centers. Embracing information security 

controls through an inherited approach allows large, complex organizations like 

DHS to build on economies of scale in a private cloud infrastructure to reduce the 

workload for individual system owners. As common controls are defined and vetted 

by the DHS enterprise and provided as a service to system owners, only the systemspecific controls need to be defined and implemented by system owners. By centrally 

managing the development, implementation, and assessment of enterprise common 

security controls at the DHS enterprise data centers and through the DHS private 

cloud, security responsibility can be shared across multiple information systems. 

While private clouds incorporate new technologies that may be challenging to secure, public clouds introduce additional risks that must be addressed through controls and contract provisions that ensure appropriate accountability and visibility. 

Though many distinctions can be drawn between public and private cloud computing, a fundamental measure of readiness is their ability to meet security requirements. By design, FedRAMP provides a common security risk model that supplies 

a consistent baseline for cloud-based services, including security accreditation designed to vet providers and services for reuse across Government. Reducing risk and 

bolstering the security of clouds, while ensuring the delivery of the promised benefits, FedRAMP not only applies to public cloud services, but private, too. Ultimately 

the consumption of cloud services requires acknowledgement of a shared responsibility and governance. From the fact that accountability can never be outsourced 

from the Authorizing Official (AO) to the need to continue to meet Government requirements, all require acknowledgement of a shared responsibility between the 

cloud service provider and customer. For public clouds, there is a ‘‘visibility gap’’ between the provider and customer, in which they cannot see into each other’s management, operational, and technical infrastructure, and procedures. As such, the visibility gap must be reduced through a series of requirements for contractual reporting and technical auditing and continuous monitoring data feeds. The key to secure 

use of cloud computing is the shared understanding of the division of security responsibilities between provider and client, and the ability to verify that both are 

meeting their responsibilities. As DHS advances in the use of public cloud computing, we will be ensuring we have the proper visibility based on a determination 

of risk given the cloud service and underlying data in order to ensure the security 

of our information. 

NEW CHALLENGES FOR CIOS

While cloud computing is fundamentally changing Federal Government IT, it is 

not without its challenges. The decision to embrace cloud computing is a risk-based 

management decision, supported by inputs from stakeholders, including the CIO, 

Chief Information Security Officer (CISO), Office of General Counsel (OGC), privacy 

official, and the program owners. From a security perspective, agency CIOs face a 

number of issues in delivering both private and public cloud capabilities. These 

issues range from determining different levels of security visibility and responsibilities, ensuring strong authentication, adopting and implementing standards for 

cloud portability and interoperability, to establishing contingency planning that recognizes cloud computing is a shared capability and identifying new opportunities for 
12 

real-time continuous monitoring capabilities but require new audit technologies implemented within the cloud environment. 

Cloud computing also leads to significant management and governance shifts for 

a department or agency. CIOs must work closely with acquisition, procurement, and 

finance communities to address the new business paradigm represented by cloud 

computing. While cloud computing requires some technological change, the most significant changes will be to the business and contracting models. Such models will 

need to ensure that agencies can move forward effectively with cloud solutions while 

maintaining necessary Federal control and oversight, complying with Federal procurement and competition laws and requirements, and managing funding limitations. CIOs must also address changes to the workforce based on this changing paradigm. As the cloud transforms the way CIOs deliver IT service, the traditional 

roles of IT specialists change, too. CIOs must provide leadership to update skills for 

existing personnel and recruit new staff in an environment under significant 

change. 

These challenges are already inherent in the CIO’s role. And, they have one thing 

in common—change. Perhaps above all, the cloud challenges CIOs to lead cultural 

change within their organization. 

THE FUTURE OF THE CLOUD

Looking forward, as FedRAMP and Federal acquisition models mature, the options for Federal agencies to leverage public and community clouds clearly provide 

real value to citizens. Continued work on information security challenges will increase the defensive capabilities of cloud offerings, increasing the assurance level 

and the ability for Federal agencies to use cloud computing for more sensitive information. 

For example, community clouds could provide agencies with a suite of specialized 

cloud hosting services that include the standard IaaS, PaaS, and SaaS offerings 

with a more robust security, business, and mission portfolio offerings such as financials, law enforcement, intelligence, medical/health, and the increased security and 

privacy controls necessary to process more sensitive information. The value of a 

community of cloud offerings across a broad suite of verticals for customers may be 

realized as the true evolution of the cloud in the years to come. 

Looking 5 years into the future, the cloud service commodity market appears 

poised to grow exponentially, creating significant innovation as a result of intense 

competition. Federal CIOs must focus on preparing departments and agencies to 

help foster and welcome innovation that changes the way we do business. By embracing the opportunities of cloud computing, we will redefine the role and capabilities of IT in the Federal Government. 

While we in the Federal Government face challenges to successfully implementing 

cloud capabilities to enhance mission performance and realize cost efficiencies, the 

benefits far outweigh the challenges. Already at DHS we are seeing reduced time 

to market for new capabilities, and soon, we will begin to reduce our capital expenditures while gaining transparency into our operational expenditures in ways we 

have never been able to before. In conclusion, we should not think of the cloud as 

simply a technology opportunity. It is a far more interesting discourse—and a significant change to the fundamental business model for how IT is delivered in the 

Federal Government. 

Thank you. 

Mr. LUNGREN. Thank you very much. 

Dr. McClure. 

STATEMENT OF DAVID MC CLURE, PH.D., ASSOCIATE ADMINISTRATOR, OFFICE OF CITIZEN SERVICES AND INNOVATIVE 

TECHNOLOGIES, U.S. GENERAL SERVICES ADMINISTRATION 

Mr. MCCLURE. Thanks, Mr. Chairman. 

Good morning, Mr. Thompson and Mr. Keating. 

Thanks for having me here on behalf of GSA to talk about cloud 

computing and cloud security. 

I just wanted to start by making two critical points about cloud 

computing itself. It really offers a compelling opportunity to substantially improve the efficiency of the Federal Government. When 

it is implemented with sound security risk management ap-
13 

proaches, cloud computing can ensure more consistent protection of 

the Government’s I.T. infrastructure, our data, and our applications. 

Second, the practical use of cloud computing really offers substantial performance benefits for Government. For example, tangible cost reductions resulting from more efficient data storage, 

web hosting, and even analytics performed on our vast data repositories. 

It can enhance productivity by shifting some of our workforce to 

high-value process improvement activity, problem solving, and customer service excellence. It allows us greater flexibility and 

scalability, as Richard just talked about—the ability of CIOs to actually stand-up services in hours, days, rather than months, and in 

some cases, years. It allows or creates an improved self-service environment: On-line, streamlined, commodity-like purchasing for I.T. 

resources rather than a very long and arduous I.T. acquisition. 

We are playing a leadership role in facilitating easy access to 

cloud-based solutions from commercial providers that meet Federal 

requirements, such as virtualization technologies for our data centers in the Government, cloud e-mail, disaster recovery and 

backup, and infrastructure storage. Our Government-wide procurement vehicles enable agencies to evaluate viable cloud computing 

options that meet their business needs. 

Now let me turn to cloud security. Cloud computing, like any 

technology, presents both known and new risks alongside the benefits that it offers. Different types of cloud services—public, private, 

community, hybrid—create their own set of security challenges in 

the Government setting. 

To address these risks in a more uniform and comprehensive 

manner we will soon launch a new Government-wide cloud security 

program. 

Mr. Chairman, you referred to it, the FedRAMP program. 

We have worked in close collaboration with cybersecurity and 

cloud experts in NIST, DOD, DHS, NSA, OMB, the Federal CIO 

Council, and with private industry. Let me be real clear: The intent 

of FedRAMP is to strengthen existing security practices associated 

with cloud computing solutions, which, in turn, will build greater 

trust between providers and consumers and accelerate appropriate 

adoption of security cloud solutions across the Government. 

FedRAMP ensures consistency and quality of system security 

certification and accreditation; it creates a transparent and trusted 

security environment in Government that will incentive more 

reusability of security testing and authorizations; and it fosters the 

push toward near real-time security assistance monitoring. It does 

this by standing up six critical capabilities. 

It standardizes a minimal baseline for Government-wide security 

controls for low and moderate risk cloud systems based upon existing NIST standards and additional controls vetted with all interested parties. It manages a process for accrediting independent 

third-party assessors to ensure greater competency, consistency, 

and compliance with required Government security controls. 

It creates a joint authorization board, comprised of CIOs and 

technical representatives from DOD, DHS, and GSA, to grant provisional authorizations for cloud systems that can be leveraged by 
14 

multiple agencies. It also allows agencies to focus on their own specific security requirements and address legitimate deltas with the 

baseline controls rather than repeating work already competently 

done by another Federal entity. 

Consistent with FISMA changes, it requires cloud service providers to perform continuous monitoring, especially for persistent 

threats, and will eventually automate the exchange of status information on specific controls on a near-time—near real-time basis. In 

concert with DHS, it controls and manages the incident response, 

mitigation, and proof of resolution for FedRAMP-authorized cloud 

systems. 

Last, it will create a secure data repository to facilitate Government access to security authorization packages, sample contract 

language and templates, examples of cloud service-level agreements, best practices, and continuous monitoring information. 

So, Mr. Chairman, we think these kinds of steps can really advance more secure cloud computing in the Government. I am happy 

to answer questions for the subcommittee. 

[The prepared statement of Mr. McClure follows:] 

PREPARED STATEMENT OF DAVID MCCLURE

OCTOBER 6, 2011 

Chairman King, Ranking Member Thompson, and Members of the subcommittee: 

Thank you for the opportunity to appear before you today to discuss the General 

Service Administration’s (GSA) leadership role in on-going efforts to enable and accelerate adoption of secure cloud computing across the Federal Government. Cloud 

adoption is a critical component of the administration’s plan to improve management of the Government’s IT resources. The IT reforms we have underway are enabling agencies to use information more efficiently and effectively, delivering improved mission results at lower cost. 

CLOUD COMPUTING ADOPTION IN THE FEDERAL GOVERNMENT

Before I discuss the security of cloud computing, and the Federal Risk Authorization and Management Program (FedRAMP) in particular, I would like to make a 

two important points. First, cloud computing offers a compelling opportunity to substantially improve the efficiency of the Federal Government. It moves us from buying and managing physical assets to purchasing IT as a commoditized service. Agencies pay for only IT resources they use in response to fluctuating program demands, 

avoiding the expenses of building and maintaining costly IT infrastructure. When 

implemented with sound security risk management approaches, cloud computing 

also ensures more consistent protection of the Government’s IT infrastructure, data, 

and applications. 

Second, practical use of cloud computing offers substantial performance benefits 

for the Government. Federal agencies are moving to consolidate and virtualize the 

more than 2,000 Federal data centers. Cloud technologies provide an ideal path forward to maximize value in IT investment dollars while substantially lowering 

costs—an essential focus given Federal budget constraints. Case studies we have 

collected from agencies point to benefits that include: 

‘‘tangible cost reductions (data storage, web hosting and analytics performed on the 

Government’s vast data repositories); 

‘‘enhanced productivity (shifting workforce to more high-value process improvements, problem solving, and customer service excellence); 

‘‘greater flexibility and scalability (enabling CIOs to be much more responsive to 

pressing service delivery expectations); and 

‘‘improved self-service capabilities (on-line streamlined commodity-like purchasing 

for IT resources rather than long, arduous IT acquisitions).’’ 

GSA is playing a leadership role in facilitating easy access to cloud-based solutions from commercial providers that meet Federal requirements. This will enable 

agencies to analyze viable cloud computing options that meet their business and 

technology modernization needs, while reducing barriers to safe and secure cloud 
15 

computing. We are developing new cloud computing procurement options with proven solutions that leverage the Government’s buying power. These cloud procurement 

vehicles ensure effective cloud security and standards are in place to lower risk and 

foster Government-wide use of cloud computing solutions such as virtualization 

technologies for Government data centers, cloud e-mail, disaster recovery/backup, 

and infrastructure storage. Useful information about cloud computing and available 

solutions is accessible from our web page, Info.Apps.gov. 

GSA’s Federal Cloud Computing Initiative was started and is managed under 

GSA’s e-Government program. In fiscal year 2010 and fiscal year 2011 GSA’s Federal Cloud Computing Initiative (FCCI) Program Management Office (PMO) focused 

on five primary tasks: 

• Establishing procurement vehicles that allow agencies to purchase IT resources 

as commodities, culminating in the award of the Infrastructure as a Service 

(IaaS) Blanket Purchase Agreement under GSA Schedule 70 to 12 diverse cloud 

service providers; 

• Addressing security risks in deploying Government information in a cloud environment—resulting in the development of the Federal Risk Authorization Management Program (FedRAMP); 

• Establishing a procurement vehicle that will allow agencies to purchase cloudbased e-mail services, which created GSA’s Email as a Service (EaaS) Blanket 

Purchase Agreement; 

• Supporting the Government-wide collection and assessment of data center inventories, and assisting agencies in the preparation and execution of plans to 

close and consolidate data centers. Current work includes developing a comprehensive data center Total Cost Model for agencies to use to analyze alternative consolidation scenarios, enables data-driven decision-making for infrastructure cost and performance optimization. Operationalizing a data center 

marketplace that would help optimize infrastructure utilization across Government by matching agencies with excess computing capacity with those that 

have immediate requirements is also being pursued. 

• Creating apps.gov, an on-line storefront that provides access to over 3,000 

cloud-based products and services where agencies can research solutions, compare prices and place on-line orders using GSA’s eBuy system. 

Initial funding provided by the e-Gov Fund has allowed GSA to be an effective 

catalyst for secure cloud technology adoption Government-wide. However, there are 

critical activities that still need to be accomplished to fully realize the significant 

cost savings and productivity improvements that GSA can help agencies achieve. 

The continuation of these cost-saving initiatives is dependent on fiscal year 2012 

eGov Fund budget levels and decisions. 

FEDRAMP: ENSURING SECURE CLOUD SYSTEMS ADOPTION

Cloud computing—like any technology—presents both known and new risks 

alongside the many benefits outlined above. To address these risks in a more uniform and comprehensive manner, we will soon launch a new Government-wide cloud 

security program—the Federal Risk and Authorization Management Program 

(FedRAMP). The primary goal of the administration’s Cloud First policy is to 

achieve widespread practical use of secure cloud computing to improve operational 

efficiency and effectiveness of Government. Today, each agency typically conducts its 

own security Certification and Accreditation (C&A) process for every IT system it 

acquires, leading to unnecessary expense, duplication, and inconsistencies in the application of NIST-derived security controls testing, evaluation, and certification procedures. According to the 2009 FISMA report to Congress, agencies reported spending $300 million annually on C&A activities alone. 

At GSA, we have worked in close collaboration with cybersecurity and cloud experts in NIST, DHS, DoD, NSA, OMB, and the Federal CIO Council and its Information Security and Identity Management Subcommittee (ISIMC) to develop 

FedRAMP. An OMB policy memo officially establishing the FedRAMP program is 

expected shortly. The intent is to strengthen existing security practices associated 

with cloud computing solutions which, in turn, will build greater trust between providers and consumers and accelerate appropriate adoption of secure cloud solutions 

across Government. Accordingly, FedRAMP establishes a common set of baseline security assessment and continuous monitoring requirements for FISMA low- and 

moderate-impact risk levels using NIST standards that must be adhered to by all 

cloud systems. Figure 1 illustrates how FedRAMP will address three fundamental 

challenges with how the Federal Government approaches ensuring cloud security. 
16 

Ensuring Consistency and Quality in Cloud Security Certification and Accreditation 

FedRAMP approves qualified, independent, third-party security assessment organizations, ensuring consistent assessment and accreditation of cloud solutions based 

on NIST’s long-standing conformity assessment approach. As noted above, security 

C&As are currently performed with varying quality and consistency. This is true for 

situations where a third-party service provider is contracted to do a security assessment of a CSP-provided system, product, or service and where Government security 

organizations perform the work themselves. As a result, trust levels are low for 

reusing this work across agencies. 

To address this challenge, FedRAMP will require that cloud services providers be 

assessed using these approved, independent, third-party assessment organizations 

(3PAOs). The 3PAOs will initially apply for accreditation through the FedRAMP 

PMO and be assessed using established conformity assessment criteria developed by 

NIST. This will ensure higher-quality assessments, done much more consistently, 

using agreed-upon FedRAMP security assessment controls. This can save millions 

of dollars in expenses borne both by Government and industry in running duplicative assessments of similar solutions by each agency. 

Building Trust and Re-Use of Existing C&A Work 

All IT systems, including cloud solutions, must receive an Authority to Operate 

(ATO) from the buying agency before they can be made available for purchase and 

implemented. The ATO is based on a thorough review by agency security professionals of the security packages submitted following the C&A process described 

above. To accelerate cloud adoption and enable C&A re-use, FedRAMP will provide 

a single, provisional authorization that can be used by all agencies as the basis for 

issuing an ATO. If additional security assessment evaluation and testing is needed 

for specific agency cloud implementations, the C&A should only address any additional controls needed above the existing FedRAMP-approved baseline. 

FedRAMP establishes a Joint Authorization Board (JAB) that reviews all cloud 

systems that have been assessed by approved 3PAOs using FedRAMP controls and 

processes. The JAB membership consists of CIOs and Technical Representatives 

from DOD, DHS, and GSA. The JAB reviews the C&A work and decides whether 

to grant the ‘‘provisional authorization’’—a seal of approval on the C&A work. The 

security packages, assessments and documented decisions will be accessible within 

Government from a secure central repository. While each agency must grant its own 

ATO for systems under its control, FedRAMP will facilitate greater use of an ‘‘approve once, and use often’’ approach, leveraging more ATOs across Government. 

Moving Towards More Real-Time Security Assurance 

FedRAMP shifts risk management from annual reporting under FISMA to more 

robust continuous monitoring, providing real-time detection and mitigation of per-
17 

sistent vulnerabilities and security incidents. Using the expertise of industry, NIST, 

NSA, DHS, and ISIMC, nine initial continuous monitoring controls have been identified that are among the most common persistent threat vulnerabilities in cloud 

and non-cloud systems environments. Cloud Service Providers (CSPs) must agree to 

near-real time reporting of continuous monitoring data feeds to DHS and/or agency 

Security Operations Centers (SOCs). We are finalizing data reporting details, with 

the expectation that the process will eventually use automated data feeds to maximize efficiencies and timeliness. When done in addition to the C&A evaluations, this 

will result in valuable situational cyber awareness—a relevant and timely picture 

of a CSP’s security posture. In addition, this approach provides visibility of prompt 

mitigation and tangible evidence of resolution; ensuring quick steps are taken to 

minimize threats to Government data and operations. 

In short, FedRAMP offers the following improvements for cloud security assessments conducted in the Federal Government: 

There is strong support and demand for stronger cloud security from agencies 

seeking to adopt cloud services, as required by the administration’s Cloud First policy. Industry cloud services providers need to know the specific cloud security capabilities for which they are accountable. They also desire more efficiency in how 

C&As and ATOs are leveraged Government-wide to avoid unnecessary, duplicative, 

costly security evaluations. Ensuring IT security is an on-going challenge. We fully 

expect to make improvements to the process based on collaboration with all key 

stakeholders, including industry, lessons learned, and the continuous evolution of 

security standards and controls based upon the careful, deliberative work of NIST. 

FedRAMP will be launched in phases that incrementally build toward sustainable 

operations and allows for risk management by capturing on-going lessons learned 

and process improvement. Initial rollout will occur this Fall. Initial Operational Capabilities will have limited scope and cover a relatively small number of cloud service providers. Full operations are expected to begin next Spring with more robust 

operational capabilities and larger intake of cloud service providers for FedRAMP 

review and approval. Late in 2012, we expect sustaining operations to scale by demand using a privatized board for 3PAO accreditation. We will discuss the rollout 

in more depth with the Congress, Government executive branch agencies, industry, 

and the public prior to the initial launch date. 

CONCLUSION

Considerable progress has been made in adopting successful cloud solutions. 

‘‘Cloud computing’’ is now an accepted part of the Federal IT lexicon. However, there 

continues to be a need for more thorough understanding of cloud deployment models, unique security implications, and data management challenges. Agency executives should not focus on cloud technology itself; rather, they should focus on the 

desired outcome driving the need for cloud adoption delivered in a secure environment. 

FedRAMP will provide a sound, cost-effective framework for secure cloud computing. CIOs need to work with their line of business executives and program managers to develop and deploy effective cloud roadmaps that address pressing agency 
18 

mission needs, taking into account appropriate security and risk management. 

Agencies should analyze business needs and identify cloud solutions that best fit 

their requirements by making secure cloud adoption part of an overall IT portfolio 

management and sourcing strategy. Consistent with the Federal Cloud Computing 

Strategy, NIST is currently working on the first draft of a USG Cloud Computing 

Technology Roadmap, to be released for public comment in November, 2011. If 

linked to cloud provider products and services, it would greatly assist in this decision-making. 

Mr. Chairman, thank you for the opportunity to appear today. I look forward to 

answering questions from you and Members of the subcommittee. 

Mr. LUNGREN. Thank you very much, Dr. McClure. 

Now, Mr. Wilshusen. 

STATEMENT OF GREGORY C. WILSHUSEN, DIRECTOR OF INFORMATION SECURITY ISSUES, GOVERNMENT ACCOUNTABILITY OFFICE 

Mr. WILSHUSEN. Chairman Lungren, Mr. Thompson, Mr. 

Keating, thank you for the opportunity to participate in today’s 

hearing on cloud computing security. I believe this is a vitally important topic. 

Earlier this week GAO issued a report on Federal information security in which we note that the number of security incidents reported by Federal agencies increased by over 650 percent during 

the past 5 years. This fact helps to underscore the need for effective security in cloud computing environments. 

Today I will describe the information security implications of 

Federal use of cloud computing services. I will also discuss GAO’s 

previous reporting on Federal efforts and guidance on cloud computing and agencies’ actions to implement our recommendations to 

improve cloud security. 

But if I may, Mr. Chairman, I have first like to recognize Assistant Director Vijay D’Souza and Shaunyce Wallace, from my staff, 

who are here, and also Nancy Glover, who is not here, for their diligent efforts in reviewing cloud security as well as preparing my 

statement. 

Mr. Chairman, cloud computing can have both positive and negative information security implications. Potential security benefits 

include those related to broad network access, possible economies 

of scale, and the use of self-service technologies. For example, Federal agencies frequently cited the prospect of on-demand security 

controls, the consistent application of those controls, and low-cost 

disaster recovery and data storage as potential benefits. 

However, the use of cloud computing can also create numerous 

information security risks. Twenty-two of the 24 major Federal 

agencies reported that they were either concerned or very concerned about the potential security risks with cloud computing. 

These risks include the ineffective or noncompliant security practices of the service provider, an inability to examine controls of the 

provider, the prospect of data leakage to unauthorized users, and 

the loss of data if the cloud service is terminated. These risks generally relate to dependence on the security practices and assurances of the service provider and the sharing of computing resources. 

In a report GAO issued last year, we noted that Federal agencies 

had begun efforts to address information security for cloud computing, but specific guidance was lacking and efforts remained in-
19 

1GAO, Information Security: Federal Guidance Needed to Address Control Issues with Implementing Cloud Computing, GAO–10–513 (Washington, DC: May 27, 2010). 

complete. We also reported that OMB and GAO—I am sorry, 

GSA—had launched Government-wide initiatives but had not completed key actions pertaining to cloud computing security. 

For example, OMB had not finished its cloud computing strategy 

or defined how information security issues would be addressed in 

that strategy. Accordingly, in that report GAO made recommendations to OMB, GSA, and NIST to take several actions to address 

these issues. 

Since that report was issued in May 2010 these agencies have 

made progress in implementing our recommendations, but additional actions are still needed to assist agencies in securely implementing cloud computing. For example, in February OMB issued 

its cloud computing strategy, which does reference the establishment of FedRAMP and other security issues; however, it does not 

address the need for agency-specific guidance, the use of standards 

for control assessments of cloud service providers, or the division 

of security responsibilities between customer and provider. 

Consistent with our recommendation, GSA, in collaboration with 

the CIO Council, further developed FedRAMP, as Mr. McClure has 

indicated in his opening remarks, and intends to issue additional 

guidance on FedRAMP later this quarter. In addition, NIST has 

issued three of four guidance documents related to cloud computing 

and expect to finalize guidelines on security and privacy in the 

public cloud computing later this quarter. These actions and the 

issuance of appropriate guidance will help, yet the true test will be 

their effective implementation over time. 

To summarize, Mr. Chairman, the use of cloud computing offers 

the promise of efficient service, but it also carries risk. OMB, GSA, 

and NIST have taken steps to develop a strategy, processes, and 

guidance on cloud computing security. Nevertheless, continued efforts will be needed to ensure that cloud computing is implemented 

securely in the Federal Government. 

Mr. Chairman, this concludes my statement. Be happy to answer 

any questions. 

[The prepared statement of Mr. Wilshusen follows:] 

PREPARED STATEMENT OF GREGORY C. WILSHUSEN

OCTOBER 6, 2011 

INFORMATION SECURITY: ADDITIONAL GUIDANCE NEEDED TO ADDRESS CLOUD

COMPUTING CONCERNS

Chairman Lungren, Ranking Member Clarke, and Members of the subcommittee: 

Thank you for the opportunity to participate in today’s hearing on the security implications of cloud computing. My statement today summarizes our report issued 

last year, titled Information Security: Federal Guidance Needed to Address Control 

Issues with Implementing Cloud Computing 1 and describes actions taken by Federal 

agencies to implement our report’s recommendations. 

Cloud computing, an emerging form of delivering computing services, can, at a 

high level, be described as a form of computing where users have access to scalable, 

on-demand information technology (IT) capabilities that are provided through internet-based technologies. Examples of cloud computing include web-based e-mail applications and common business applications that are accessed on-line through a 

browser, instead of through a local computer. Cloud computing can potentially deliver several benefits over current systems, including faster deployment of com-
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2The 24 major Federal agencies are the Agency for International Development; the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services, 

Homeland Security, Housing and Urban Development, the Interior, Justice, Labor, State, Transportation, the Treasury, and Veterans Affairs; the Environmental Protection Agency; the General Services Administration; the National Aeronautics and Space Administration; the National 

Science Foundation; the Nuclear Regulatory Commission; the Office of Personnel Management; 

the Small Business Administration; and the Social Security Administration. 3GAO, Cybersecurity: Continued Attention Needed to Protect Our Nation’s Critical Infrastructure and Federal Information Systems, GAO–11–463T (Washington, DC: Mar. 16, 2011) and Cybersecurity: Continued Attention Needed to Protect Our Nation’s Critical Infrastructure, GAO– 

11–865T (Washington, DC: July 26, 2011). 4GAO, High-Risk Series: Information Management and Technology, GAO/HR–97–9 (Washington, DC: February 1997). 5GAO, High-Risk Series: An Update, GAO–11–278 (Washington, DC: February 2011). 

puting resources, a decreased need to buy hardware or to build data centers, and 

more robust collaboration capabilities. However, along with these benefits are the 

potential risks that any new form of computing services can bring, including information security breaches, infrastructure failure, and loss of data. Media reports 

have described security breaches of cloud infrastructure and reports by others have 

identified security as the major concern hindering Federal agencies from adopting 

cloud computing services. 

My statement today will provide a description of: (1) The information security implications of using cloud computing services in the Federal Government, (2) our previous reporting on Federal efforts and guidance to address cloud computing information security, and (3) our recommendations and subsequent actions taken by Federal 

agencies to address Federal cloud computing security issues. In preparing this statement, we summarized the content of our May 2010 report on cloud computing security. In conducting the work for that report, we collected and analyzed information 

from industry groups, private sector organizations, the National Institute of Standards and Technology (NIST), and 24 major Federal agencies.2 In addition, we followed up with agencies to determine the extent to which the recommendations made 

in that report have been implemented. The work for the report on which this statement is based was performed in accordance with generally accepted Government auditing standards. 

BACKGROUND

We have previously reported that cyber threats to Federal information systems 

and cyber-based critical infrastructures are evolving and growing.3 Without proper 

safeguards, computer systems are vulnerable to individuals and groups with malicious intentions who can intrude and use their access to obtain and manipulate sensitive information, commit fraud, disrupt operations, or launch attacks against other 

computer systems and networks. 

In addition, the increasing interconnectivity among information systems, the 

internet, and other infrastructure presents increasing opportunities for attacks. For 

example, since 2010, several media reports described incidents that affected cloud 

service providers such as Amazon, Google, and Microsoft. Additional media reports 

have described hackers exploiting cloud services for malicious purposes. The adoption of cloud computing will require Federal agencies to implement new protocols 

and technologies and interconnect diverse networks and systems while mitigating 

and responding to threats. 

Our previous reports and those by agency inspectors general describe serious and 

widespread information security control deficiencies that continue to place Federal 

assets at risk of inadvertent or deliberate misuse, mission-critical information at 

risk of unauthorized modification or destruction, sensitive information at risk of inappropriate disclosure, and critical operations at risk of disruption. We have also 

reported that weaknesses in information security policies and practices at major 

Federal agencies continue to place confidentiality, integrity, and availability of sensitive information and information systems at risk. Accordingly, we have designated 

information security as a Government-wide high-risk area since 1997,4 a designation that remains in force today.5 To assist agencies, GAO and agency inspectors 

general have made hundreds of recommendations to agencies for actions necessary 

to resolve control deficiencies and information security program shortfalls. 
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6 Virtualization is a technology that allows multiple software-based virtual machines with different operating systems to run in isolation, side-by-side on the same physical machine. Virtual 

machines can be stored as files, making it possible to save a virtual machine and move it from 

one physical server to another. 

Cloud Computing Is a Form of Shared Computing with Several Service and Deployment Models 

Cloud computing delivers IT services by taking advantage of several broad evolutionary trends in IT, including the use of virtualization.6 According to NIST, cloud 

computing is a means ‘‘for enabling convenient, on-demand network access to a 

shared pool of configurable computing resources that can be rapidly provisioned and 

released with minimal management effort or service provider interaction.’’ NIST 

also states that an application should possess five essential characteristics to be considered cloud computing: On-demand self-service, broad network access, resource 

pooling, rapid elasticity, and measured service. 

Cloud computing offers three service models: Infrastructure as a service, where 

a vendor offers various infrastructure components; platform as a service, where a 

vendor offers a ready-to-use platform on which customers can build applications; 

and software as a service, which provides a self-contained operating environment 

used to deliver a complete application such as web-based e-mail. Figure 1 illustrates 

each service model. 

In addition, four deployment models for providing cloud services have been developed: Private, community, public, and hybrid cloud. In a private cloud, the service 

is set up specifically for one organization, although there may be multiple customers 

within that organization and the cloud may exist on or off the premises. In a community cloud, the service is set up for related organizations that have similar requirements. A public cloud is available to any paying customer and is owned and 

operated by the service provider. A hybrid cloud is a composite of the deployment 

models. Figure 2 further illustrates each model. 
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CLOUD COMPUTING HAS BOTH POSITIVE AND NEGATIVE INFORMATION SECURITY

IMPLICATIONS

Cloud computing can both increase and decrease the security of information systems. Potential information security benefits include the use of virtualization and 

automation to expedite the implementation of secure configurations for virtual machine images. Other advantages relate to cloud computing’s broad network access 

and use of internet-based technologies. For example, several agencies stated that 

cloud computing provides a reduced need to carry data in removable media because 

of the ability to access the data through the internet, regardless of location. In response to the survey we conducted for our 2010 report, 22 of the 24 major agencies 

also identified low-cost disaster recovery and data storage as a potential benefit. 

The use of cloud computing can also create numerous information security risks 

for Federal agencies. In response to our survey, 22 of 24 major agencies reported 

that they are either concerned or very concerned about the potential information security risks associated with cloud computing. Several of these risks relate to being 

dependent on a vendor’s security assurances and practices. Specifically, several 

agencies stated concerns about: 

• the possibility that ineffective or non-compliant service provider security controls could lead to vulnerabilities affecting the confidentiality, integrity, and 

availability of agency information; 

• the potential loss of governance and physical control over agency data and information when an agency cedes control to the provider for the performance of certain security controls and practices; and: 

• potentially inadequate background security investigations for service provider 

employees that could lead to an increased risk of wrongful activities by malicious insiders. 

Of particular concern was dependency on a vendor. All 24 agencies specifically 

noted concern about the possibility of loss of data if a cloud computing provider 

stopped offering its services to the agency. For example, the provider and the customer may not have agreed on terms to transfer or duplicate the data. 

Multitenancy, or the sharing of computing resources by different organizations, 

can also increase risk. Twenty-three of 24 major agencies identified multitenancy as 

a potential information security risk because, under this type of arrangement, one 

customer could intentionally or unintentionally gain access to another customer’s 

data, causing a release of sensitive information. Agencies also stated concerns related to exchanging authentication information on users and responding to security 

incidents. Identity management and user authentication are a concern for some 

Government officials because customers and a provider may need to establish a 

means to securely exchange and rely on authentication and authorization information for system users. In addition, responding to security incidents may be more difficult in a shared environment because there could be confusion over who performs 

the specific tasks—the customer or the provider. 
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Although there are numerous potential information security risks related to cloud 

computing, these risks may vary based on the particular deployment model. For example, NIST stated that private clouds may have a lower threat exposure than community clouds, which may have a lower threat exposure than public clouds. Several 

industry representatives stated that an agency would need to examine the specific 

security controls of the provider the agency was evaluating when considering the 

use of cloud computing. 

FEDERAL AGENCIES AND GOVERNMENT-WIDE INITIATIVES HAD BEGUN TO ADDRESS

INFORMATION SECURITY ISSUES FOR CLOUD COMPUTING, BUT REMAINED INCOMPLETE

In our report, we noted that Federal agencies had begun to address information 

security for cloud computing; however, they had not developed corresponding guidance. About half of the 24 major agencies reported using some form of public or private cloud computing for obtaining infrastructure, platform, or software services. 

These agencies identified measures they were taking or planned to take when using 

cloud computing. These actions, however, had not always been accompanied by development of related policies or procedures. 

Most agencies had concerns about ensuring vendor compliance and implementation of Government information security requirements. In addition, agencies expressed concerns about limitations on their ability to conduct independent audits 

and assessments of security controls of cloud computing service providers. Several 

industry representatives were in agreement that compliance and oversight issues 

were a concern and raised the idea of having a single Government entity or other 

independent entity conduct security oversight and audits of cloud computing service 

providers on behalf of Federal agencies. Agencies also stated that having a cloud 

service provider that had been precertified as being in compliance with Government 

information security requirements through some type of Government-wide approval 

process would make it easier for them to consider adopting cloud computing. Other 

agency concerns related to the division of information security responsibilities between customer and provider. As a result, we reported that the adoption of cloud 

computing by Federal agencies may be limited until these concerns were addressed. 

Several Government-wide Cloud Computing Information Security Initiatives Had 

Been Started, but Key Guidance and Efforts Had Not Been Completed 

In our May 2010 report, we also noted that several Government-wide cloud computing security activities had been undertaken by organizations such as the Office 

of Management and Budget (OMB), General Services Administration (GSA), the 

Federal Chief Information Officers (CIO) Council, and NIST; however, significant 

work remained to be completed. Specifically, OMB had stated that it had begun a 

Federal cloud computing initiative in February 2009; however, it did not have an 

overarching strategy or an implementation plan. In addition, OMB had not yet defined how information security issues, such as a shared assessment and authorization process, would be addressed. 

GSA had established the Cloud Computing Program Management Office, which 

manages several cloud computing activities within GSA and provides administrative 

support for cloud computing efforts by the CIO Council. The program office manages 

a storefront, www.apps.gov, established by GSA to provide a central location where 

Federal customers can purchase software as a service cloud computing applications. 

GSA had also initiated a procurement to expand the storefront by adding infrastructure as a service cloud computing offerings such as storage, virtual machines, and 

web hosting. However, GSA officials reported challenges in addressing information 

security issues as part of the procurement. As a result, in early March 2010, GSA 

canceled the request and announced plans to begin a new request process. GSA officials stated that they needed to work with vendors after a new procurement was 

completed to develop a shared assessment and authorization process for customers 

of cloud services purchased as part of the procurement, but had not yet developed 

specific plans to do so. 

In addition to GSA’s efforts, the CIO Council had established a cloud computing 

Executive Steering Committee to promote the use of cloud computing in the Federal 

Government, with technical and administrative support provided by GSA’s Cloud 

Computing Program Management Office, but had not finalized key processes or 

guidance. A subgroup of this committee had developed the Federal Risk and Authorization Management Program (FedRAMP), a Government-wide program to provide 

joint authorizations and continuous security monitoring services for all Federal 

agencies, with an initial focus on cloud computing. The subgroup had worked with 

its members to define interagency security requirements for cloud systems and services and related information security controls. However, a deadline for completing 
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7OMB, Federal Cloud Computing Strategy (Washington, DC: February 2011). 8 CIO Council, Proposed Security Assessment and Authorization for U.S. Government Cloud 

Computing, Draft version 0.96 (Washington, DC: November 2010). 

development and implementation of a shared assessment and authorization process 

had not been established. 

NIST is responsible for establishing information security guidance for Federal 

agencies to support the Federal Information Security Management Act of 2002 

(FISMA); however, at the time of our report, it had not yet established guidance 

specific to cloud computing or to information security issues specific to cloud computing, such as portability, interoperability, and virtualization. The NIST official 

leading the institute’s cloud computing activities stated that existing NIST guidance 

in Special Publication (SP) 800–53 and other publications applied to cloud computing and could be tailored to the information security issues specific to cloud computing. However, both Federal and private sector officials had made clear that existing guidance was not sufficient. 

AGENCIES HAVE MADE PROGRESS IN IMPLEMENTING GAO RECOMMENDATIONS, BUT ADDITIONAL ACTIONS ARE NEEDED TO ASSIST AGENCIES IN SECURELY IMPLEMENTING

CLOUD COMPUTING

In our May 2010 report, we made several recommendations to OMB, GSA, and 

NIST to assist Federal agencies in identifying uses for cloud computing and information security measures to use in implementing cloud computing. These agencies 

generally agreed with our recommendations. Specifically, we recommended that the 

Director of OMB establish milestones for completing a strategy for implementing 

the Federal cloud computing initiative; ensure the strategy addressed the information security challenges associated with cloud computing, such as needed agencyspecific guidance, the appropriate use of attestation standards for control assessments of cloud computing service providers, division of information security responsibilities between customer and provider, the shared assessment and authorization 

process, and the possibility for precertification of cloud computing service providers; 

and direct the CIO Council Cloud Computing Executive Steering Committee to develop a plan, including milestones, for completing a Government-wide security assessment and authorization process for cloud services. 

In response, in February 2011, OMB issued its Federal Cloud Computing Strategy,7 which references the establishment of a shared assessment and authorization 

process for cloud computing. In addition, the strategy discusses other steps to promote cloud computing in the Federal Government, including ensuring security when 

using cloud computing, streamlining procurement processes, establishing standards, 

recognizing the international dimensions of cloud computing, and establishing a governance structure. However, the strategy does not address other security challenges 

such as needed agency-specific guidance, the appropriate use of attestation standards for control assessments of cloud computing service providers, and the division 

of information security-related responsibilities between customer and provider. Until 

these challenges are addressed, agencies may have difficulty readily adopting cloud 

computing technologies. 

We also recommended that the Administrator of GSA, as part of the procurement 

for infrastructure as a service cloud computing technologies, ensure that full consideration be given to the information security challenges of cloud computing, including 

a need for a shared assessment and authorization process. 

In response, GSA issued a request for quote relating to its procurement for cloud 

services that included the need to use FedRAMP once it is operational. FedRAMP 

was further developed by GSA, in collaboration with the Cloud Computing Executive Committee, as a shared assessment and authorization process to provide security authorizations and continuous monitoring for systems shared among Federal 

agencies. The CIO Council, in collaboration with GSA, issued a draft version of the 

shared assessment and authorization process in November 2010;8 however, the process has not yet been finalized. GSA officials stated that they intend to release additional information on FedRAMP once OMB issues a policy memorandum related to 

cloud computing, expected in the first quarter of fiscal year 2012. 

Last, to assist Federal agencies in implementing appropriate information security 

controls when using cloud computing, we recommended that the Secretary of Commerce direct the Administrator of NIST to issue cloud computing information security guidance to Federal agencies to more fully address key cloud computing domain 

areas that are lacking in SP 800–53, such as virtualization, data center operations, 

and portability and interoperability, and include a process for defining roles and responsibilities of cloud computing service providers and customers. 
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9 NIST, Guide to Security for Full Virtualization Technologies, SP 800–125 (Gaithersburg, MD: 

January 2011). 10 NIST, NIST Cloud Computing Standards Roadmap, SP 500–291 (Gaithersburg, MD: July 

2011). 11 NIST, NIST Cloud Computing Reference Architecture, SP 500–292 (Gaithersburg, MD: September 2011). 12 NIST, Guidelines on Security and Privacy in Public Cloud Computing, Draft SP 800–144 

(Gaithersburg, MD: January 2011). 

NIST has also taken steps to address our recommendations. In January 2011, it 

issued SP 800–125, Guide to Security for Full Virtualization Technologies.9

Virtualization is a key technological component of cloud computing. SP 800–125 discusses the security characteristics of virtualization technologies, provides security 

recommendations for virtualization components, and highlights security considerations throughout the system life cycle of virtualization solutions. In July 2011, 

NIST issued SP 500–291, NIST Cloud Computing Standards Roadmap,10 and in 

September 2011, SP 500–292, NIST Cloud Computing Reference Architecture.11 Collectively these documents provide guidance to help agencies understand cloud computing standards and categories of cloud services that can be used Governmentwide. Among other things, these publications address cloud computing standards for 

interoperability and portability. 

NIST also issued a draft publication on cloud computing, SP 800–144, Guidelines 

on Security and Privacy in Public Cloud Computing,12 which addresses the security 

concerns associated with data center operations and the division of responsibilities 

among providers and customers. In addition, the guide discusses the benefits and 

drawbacks of public cloud computing, precautions that can be taken to mitigate 

risks, and provides guidance on addressing security and privacy issues when outsourcing support for data and applications to a cloud provider. According to NIST 

officials, SP 800–144 will be finalized in the first quarter of fiscal year 2012. 

In summary, the adoption of cloud computing has the potential to provide benefits 

to Federal agencies; however, it can also create numerous information security risks. 

Since our report, Federal agencies have taken several steps to address our recommendations on cloud computing security, but more remains to be done. For example, OMB has issued a cloud computing strategy; however the strategy does not fully 

address key information security challenges for agencies to adopt cloud computing. 

The CIO Council and GSA have also developed a shared assessment and authorization process, but this process has not yet been finalized. In addition, NIST has 

issued several publications addressing cloud computing security guidance. Although 

much has been done since our report, continued efforts will be needed to ensure that 

cloud computing is implemented securely in the Federal Government. 

Chairman Lungren, Ranking Member Clarke, and Members of the subcommittee, 

this concludes my prepared statement. I am pleased to respond to any questions. 

Mr. LUNGREN. Thank you very much. 

Thank all three of you for that. I understand we are going to 

have votes in about 10 minutes so we will see if we can get through 

a couple of 5-minute question periods. I will start. 

If I were to summarize what I heard, it is that Mr. Spires and 

Mr. McClure have the glass-half-full approach, and Mr. Wilshusen, 

you have the glass-half-empty approach. 

Mr. Spires and Mr. McClure, can you tell me which glass I 

should take up? 

Mr. SPIRES. Well, sir, I do have the glass-half-full approach. I believe that cloud computing is going to transform I.T. as things become more commoditized. The world is moving that way; we need 

to move with it because the advantages are so great. 

Mr. LUNGREN. So it is inevitable that we are going to move 

there? 

Mr. SPIRES. I think it is inevitable. 

Mr. LUNGREN. So the question we have here is: How secure can 

we make it? 

Dr. McClure, you—if I were to just listen to what you had to say 

I would be very, very pleased that it is very secure right now or 

on the process of getting even more secure. But the gentleman to 
26 

your left is paid to poke holes in arguments that people like you 

make, and he has poked some holes. 

Sometimes things sound too good to be true, and most of the time 

I have found that is true. What assurance do we have as we move 

toward this cloud computing—well, let me put it this way: In the 

report that we issued yesterday, and this is consistent with what 

we have heard before this committee, there has been the suggestion that 85 percent of computer intrusions, unwarranted interference, et cetera, could be stopped by good computer hygiene, 

which suggests that we have a lot to do in terms of public and private awareness. 

One of the key aspects to security on cloud computing would be 

awareness. How am I to be able to tell my colleagues and my constituents that the awareness that evidently isn’t there now with 

the way we are doing things is going to be there as we move to 

computing? Because isn’t that the essential question? 

You can set up the best sort of secure systems possible, but if 

there is not the awareness of what you have to do, both in terms 

of what we are talking about here, the ultimate user, that is, the 

Government employee, but also the vendor, and the vendor’s employees—it is not going to happen. So is that computed into what 

you said today, that we have the awareness, we are going to have 

the awareness, it is built in, or it is easier in a cloud computing 

atmosphere than what we have had thus far? 

Mr. MCCLURE. Well, thank you, Mr. Chairman. As Greg knows, 

I used to be a hole-poker, as well, because I sat in GAO, so there 

is no—this is a really challenging area, so I don’t think it is a halffull, half-empty glass. We are never done in this area. I think all 

of us here at the table would agree with that. 

We can put the best controls in place, the best policies, the best 

people, but you are going to always be advancing in your knowledge and in your ability to deter threats and vulnerabilities to your 

system. So it is a given. 

So I think that is one thing we need to do is to dispel the myth 

that there is some magical control or formula that we are not using 

and if we just put in place we would—we will be absolutely secure. 

Security is an on-going exercise. 

Mr. LUNGREN. True. But how do we answer the question to those 

who would be skeptics of what we think we need to do, that if you 

move in the direction of cloud computing you are necessarily creating greater target-rich environments? That is, if I can invade a 

cloud that has multiple—more data points than a small network I 

would target my energies on that, and if I am successful, boy, I 

really have a tremendous amount of information, and connected information, where I may not have it if it is divided over 2,700 different networks. That is the concern I have expressed to me. 

On the other hand, I hear the argument, ‘‘Well, wait a second. 

We can put more capital investment into cloud technology. They 

can be more up-to-date, more timely. They can find things more 

quickly because they have a greater observation point.’’ I understand that. 

But I think you understand the point about a greater target-rich 

environment with the concern people then have that you have got 
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to have a promise that the security of the cloud is going to be 

measurably better than the security we have in the current system. 

Mr. MCCLURE. Yes, and I would absolutely agree, that is the way 

forward. Our problems in security are not unique cloud computing 

systems, by the way. So if you look at what we are putting in place 

in FedRAMP, we need, first of all, agreement on what the baseline 

controls actually are, and I think we have achieved that by working 

across a huge community in the Government to have that dialogue. 

Second, we have to agree on what are the additional controls 

that are warranted in a cloud environment, much as you described, 

where there are extended vulnerabilities that are not necessarily 

applicable to traditional systems. So we have done that. We have 

tried to introduce new controls. 

Third, we have to move to continuous monitoring. We have to 

make sure that agencies are applying managerial, technical, and 

operational controls to their systems for clouds, but we also have 

to report on a real-time basis the posture of the cloud security provider’s environment, and that we have to see and we have to be 

able to take action, and we have to demand a solution be put in 

place. Then we can really bump up, I think, our security posture 

to more tolerable levels. 

Mr. LUNGREN. Thank you very much. 

Now, I either recognize the gentlelady or Mr. Thompson. 

No, whoever you want to—— 

Mr. THOMPSON. Well, thank you very much. 

Mr. LUNGREN. Because we have, I think, 5 minutes, probably, before we have to go vote. Votes have already been called. So—— 

Mr. THOMPSON. Right. Well, thank you, Mr. Chairman. I appreciate the Ranking Member’s indulgence. 

Clearly, the cloud is kind of cloudy right now to a lot of us, and 

we are trying to get better. But as we go forward, I am a little concerned about how our Government moves forward without the necessary safeguards in place. 

Mr. Spires, let us talk about one of my concerns. I understand 

that DHS has contracted with a company called CGI Federal, Inc., 

to move its public website to the cloud. Now, I understand that this 

is not a U.S. company. Am I correct or incorrect? 

Mr. SPIRES. Actually, sir, CGI Federal—well, you are correct, we 

are—we have contracted, through the GSA infrastructure as a 

service vehicle for CGI Federal to provide cloud services so we can 

move our public-facing websites to the cloud. That is correct. 

CGI Federal is a U.S.-based company. The parent company is a 

Canadian-based company. 

Mr. THOMPSON. So it is a U.S.-based company—— 

Mr. SPIRES. Yes, sir. 

Mr. THOMPSON [continuing]. Owned by a Canadian company? 

Mr. SPIRES. That is correct, sir. 

Mr. THOMPSON. Okay. Does that cause you any concern? 

Mr. SPIRES. In awarding the contract, sir, and going through the 

evaluation, we followed all the proper regulations from the FARR. 

I worked with our procurement organization, worked with GSA’s 

procurement organizations. 

I should also point out, sir, that we put a clause into that contract or that task order that States that everyone that works on 
28 

that particular contract needs to be a U.S. citizen unless we grant 

a waiver, and I don’t expect we would be granting a waiver to that, 

and that all the data that is—that we would use in running those 

public websites needs to be resident within the United States. 

Mr. THOMPSON. Can you provide the committee with a copy of 

that task order? 

Mr. SPIRES. We certainly can, sir. 

Mr. THOMPSON. So none of the work—none of the hosting or anything will be done out of the—— 

Mr. SPIRES. No. The hosting will be done in two geographic diverse data centers that are both located within the United States, 

sir. 

Mr. THOMPSON. Thank you very much. 

Dr. McClure, when you testified before the House Oversight and 

Government Reform Committee last year you called security one of 

the most significant obstacles to the adoption of cloud computing. 

Is that still your position or have you modified it? 

Mr. MCCLURE. No, and I think it is a—the top challenge. There 

are others that we have alluded to. 

Security, because of these issues we have been bringing up this 

morning—the lack of consistent standards, the lack of the quality 

of the work being done to assess cloud systems, the lack of real continuous monitoring, real-time capabilities—it presents real challenges, particularly in cloud environments. But we are addressing 

those; that is what we are trying to do. 

The other two, though—and I think Greg may have mentioned 

this—are portability—I park my data onto a cloud provider’s system; I, either by choice or because they are going out of business, 

I want to get that data off of their cloud system and into a new 

one. Can they aggregate and reconstitute that data and give it back 

to me? It is a huge question that Federal officials have to ask of 

their cloud service provider. 

Mr. THOMPSON. So that is still a concern? 

Mr. MCCLURE. Absolutely. 

Mr. THOMPSON. Well, I understand that we have 12 companies 

that have been approved for some services under these contracts, 

while only four have been—of those 12—have been fully vetted. Is 

there some issues around security, or what? 

Mr. MCCLURE. Absolutely. Once the 12 entities were found to be 

qualified and awarded business under that BPA, the second step 

is to go through a security authorization process, which is controls 

and testing to make sure they meet all Federal requirements. To 

date, four have, and they are subcontractors, and the remaining 

are going through the completion of that security authorization. 

Mr. THOMPSON. So another Federal agency couldn’t pick from the 

eight at this point? 

Mr. MCCLURE. Correct. 

Mr. THOMPSON. They can only take the four? 

Mr. MCCLURE. They can take the four. They can actually, if they 

wanted to, enter into business with one of the other eight if they 

themselves performed the security assessments. We are doing it at 

GSA in order for all agencies to be leveraging off of that rather 

than repeating it. 
29 

Mr. THOMPSON. Well, and I guess for the GAO person in my last 

second, I am a little concerned that some of the vetting is not complete with some of the companies. Have you looked at that and 

whether or not you have some concerns around that, also? 

Mr. WILSHUSEN. Well, we haven’t specifically looked at GSA’s authorization and assessment process yet, but certainly if we 

haven’t—or the GSA or Federal agencies have not yet assessed the 

security controls over the cloud environment, they are doing—if 

they use that environment they are doing so at risk, and at an increased risk. 

Mr. THOMPSON. Yes. Thank you. 

Mr. LUNGREN. All right. We are expected at a series of five votes 

on the House floor that has already started. We have, I think, 5 

minutes to get over there to vote. 

The subcommittee will stand in recess until the conclusion of 

these votes, reconvene immediately following the last vote, which 

will probably be between 45 minutes to an hour. 

[Recess.] 

Mr. LUNGREN. With the acceptance of the Minority I am going 

to ask a few questions, and then, when Ms. Clarke gets here she 

will have the chance, or Mr. Keating returns from the floor, so we 

can allow the first panel to go as quickly as possible. 

Let me ask you, Mr. Spires, how is the Department evaluating 

the different needs for different data sets? That is, if we have an 

agreement that there are different categories of clouds that are appropriate for different levels of security based on the nature of the 

data, what is the criteria you are using in evaluating those different needs? 

Mr. SPIRES. My apologies. Yes, sir. We are using different evaluation—or, using evaluation criteria based on the sensitivity of the 

data itself. So in our case, we are starting off fairly simple right 

now. 

All of what we would consider sensitive data, including data that 

would be for official use only and higher sensitivity data—law enforcement sensitive, for instance, in the unclassified realm—right 

now we are keeping that within what we call our private cloud, and 

that private cloud is hosted out of our two enterprise data centers. 

It runs within our own wide-area network, and hence, we are able 

to control that environment and really have the insights through 

continuous monitoring into the security stature of that environment. 

We are aggressively looking at public cloud for what we would 

say is nonsensitive data. So the example I used in my testimony 

of us moving our public-facing websites, like dhs.gov, fema.gov, to 

public cloud, and we are trying to get experience using the public 

cloud. 

As the FedRAMP process matures we would anticipate over time 

looking at how that evaluation criteria could change, because I am 

a real believer, having been in the private sector for a good part 

of my career, that we always want to foster competition; we always 

want to have choice. So as we have more and more comfort over 

time that public cloud services can provide the security levels, 

okay, and the continuous monitoring capabilities that we need we 

would look, then, over time to start to relax that criteria or shift 
30 

it so that more sensitive data would be able to be moved into the 

public cloud. 

Mr. LUNGREN. Now, what is the interplay between Department 

of Homeland Security and GSA in terms of assurance of cybersecurity as we move to the cloud? DHS appears to be the point agency 

for—I don’t want to say looking over the shoulder, but looking at 

other Government agencies and departments to assure that they 

are taking cybersecurity seriously. I know we have the office in the 

White House, which is an office that I would suggest is sort of a— 

my definition, sort of a focal point for policy, but DHS is the operational point. 

How do you interface with GSA on something like this, with respect to their responsibilities in the areas that they have authority? 

Mr. SPIRES. Let me provide an answer, and I am sure Dr. 

McClure will then want to weigh in. 

First, I should state that I am the CIO for the Department of 

Homeland Security; there is another part of DHS within what we 

call our NPPD organization that really has this mission, if you will, 

to provide—really look at cybersecurity, of course, for the Nation, 

but in particular, for the civilian government agencies. 

Mr. LUNGREN. Hopefully you folks talk to one another. 

Mr. SPIRES. We talk to one another all the time. As I like to say, 

we are the biggest guinea pig for what they want to do next. I 

think we should be, right? So we work very, very closely with them. 

So they have, for instance the US–CERT operation, which gathers—— 

Mr. LUNGREN. Right. 

Mr. SPIRES [continuing]. Incident response information from 

throughout the Government to be able to share, analyze that information. That organization is working very closely with our organization and with GSA as we look at how we are going to roll out 

this FedRAMP initiative. 

For instance, as FedRAMP rolls out and we look at continuous 

monitoring for public cloud service providers, those feeds would be 

provided to the Department of Homeland Security, to US–CERT, 

for continual analysis, as well as to the agency, so that we can continue to monitor, if you will, public cloud capabilities, if you will, 

real-time throughout the Government for the use of the public 

cloud. 

Mr. LUNGREN. Dr. McClure. 

Mr. MCCLURE. Yes, it is a—excuse me, Mr. Chairman—it is a 

very complementary relationship. FedRAMP has actually been devised with heavy DHS participation, both from Richard’s office, representing the CIO angle, and from Greg Schaffer’s office, the NPPD 

directorate that Richard referred to, which does the operational 

monitoring and runs a lot of the—a lot of the US–CERT capabilities. 

So what we are doing in FedRAMP is designed to actually incorporate the role of DHS into that process. We are not replicating, 

we are not eliminating anything that is really clearly in DHS 

space. 

In fact, if you look at the recent change made to FISMA that requires agencies to do monthly reporting of continuous monitoring, 
31 

FedRAMP is simply building on top of that. It is utilizing that process as we designed our process for FedRAMP. 

Mr. LUNGREN. In either your opening statement or an answer to 

a question you indicated that continuous monitoring was one of the 

essentials as we move to cloud computing. Is the suggestion that 

this needs to be increased in intensity? Is it a relatively new concept? Is it one that has been implemented across the board in Government agencies and departments, or is it sporadic? 

Given what you said about this being an essential, one would 

think it would be essential now, and one would also ask whether 

it is treated as something essential now. 

Mr. MCCLURE. Absolutely. The issue with the continuous monitoring controls is the agreement upon the standard for the control 

and on the data elements that actually would be passed to show 

compliance. 

What we want to do is to make sure that that has been agreed 

to with industry as well as inside of Government. So that is the 

process that is underway now, establishing those standards for the 

controls and the continuous monitoring are and coming up with 

agreement on the actual data elements that would be shared between entities to show compliance. 

Once that is worked out, I think we can begin moving to a near 

real-time view of what is happening in the provider space, whether 

it is an internal or external provider that is doing—— 

Mr. LUNGREN. Mr. Wilshusen, do you have any comments, 

please? 

Mr. WILSHUSEN. Yes, I do. Thank you very much. 

As you know, we issued a report just this week on Federal information security. One of the issues we discuss had to do with continuous monitoring. 

It is a relatively new phenomenon and requirement within the 

Federal Government. NIST recently issued some guidance that included it in its risk framework. I believe that came out back in 

February, perhaps, of 2011, or—I think it was February 2011, if I 

remember correct. 

Right now the experience with Federal agencies in continuous 

monitoring is still immature, if you will. There is still a great deal 

that needs to be done. In some respects it is required that agencies 

have the capability to have automated tools in place in which they 

can gather this information and feed it on a regular near-real-time 

basis, and many of the agencies so far don’t have those capabilities 

over all of their assets. 

It is also important to know that with continuous monitoring 

there is that automated aspect of it, but there is still a need for 

testing and evaluation of the effectiveness of the controls to assure 

that the information that is being provided through these automated tools is accurate and reliable. 

Mr. LUNGREN. One of the key risks the GAO report identifies relating to cloud computing is the dependency on vendor. There was 

mention by Mr.—by Dr. McClure when we were doing the first 

round of questions about the scenario in which you terminate a 

contract or a vendor ceases operations. 
32 

Any thoughts on how you protect against the vulnerability there? 

What do you have to build in to protect the Government’s essential 

needs at that point? 

Mr. WILSHUSEN. Well, that certainly is a key risk to Federal 

agencies. When we did our report last May all 24 of the 24 agencies 

cited loss of information as a key risk should their cloud service be 

terminated. 

So in terms of being able to help mitigate those risks, it is imperative for agencies to establish comprehensive service-level agreements that specify clearly up front what the roles and responsibilities of the cloud service provider is as well as what the customer 

is with regard to providing information should they go out of business. It is also—or service is discontinued. 

It is also imperative that interoperability and portability standards be developed and implemented so that agencies have the capability to take their information that is being processed by a cloud 

service provider and use it either internally or to another provider 

should the need arise. 

Mr. LUNGREN. Mr. Spires, is there anything technologically 

unique about cloud computers that causes more difficulty with this 

particular concern—that is, termination of services? 

Mr. SPIRES. Not on the technical side, sir, but I would echo what 

Greg said, that one of our big concerns about moving to the public 

cloud is exactly that, that we want to be able to assure continuity 

of service to our customers, right, in all events. So we have to work 

those scenarios as to what happens in the hopefully unlikely event 

that that cloud service provider can no longer offer that service— 

so data archiving capabilities, having the standards set—and I 

know this is something NIST is working on—for cloud interoperability so that we can quickly shift to another cloud service provider if necessary. 

Mr. LUNGREN. So cloud interoperability would presume that you 

have equal security measures available. 

Mr. SPIRES. Well, I think that comes back to the FedRAMP initiative and the idea of having these provisional authorizations in 

place for, hopefully over time, many cloud service providers so that 

that makes it much easier for us, as CIOs, to have choice and to 

be able to much more easily move our services. Goes back to my 

competition point earlier. It also gives us a more competitive playing field, which will drive down costs over time and, of course, provide better service. 

Mr. LUNGREN. Before I yield to the gentlelady, the Ranking 

Member, the Ranking Member of the full committee brought up the 

question about the contract with the first that is a U.S.-based firm 

but a wholly-owned subsidiary of a Canadian firm. We are close to 

Canada, but it is another country, as I recall. 

I think Congressman Thompson was bringing up the question of 

the—I don’t know the visuals of that or how we tell the American 

people, ‘‘Yes, we are going to have—the Government is going to use 

vendors that have cloud computing with all of the assets but also 

the vulnerabilities we talked about, and it is going to be a company 

that answers to people who aren’t in this country.’’ 

You answered it specifically. Do you understand the—at least the 

question some people might have there? 
33 

Mr. SPIRES. Sure. The more general point—certainly at the Department of Homeland Security within my office, we would be— 

want to always make sure, sir, that our data is protected, that for 

any sensitive data as we move forward that we would want U.S. 

citizens to only have access to that data, that it be housed—for sensitive information, that we would only have that data housed in 

data centers that were on American soil. That would go without— 

I mean, it is the given, okay? 

All I can say, sir, is we followed the regulations. We did an open 

competition within the providers that were available to us through 

the GSA vehicle, and based on the evaluation criteria, this firm 

won that particular task order. 

Mr. LUNGREN. Okay. Thank you very much. 

The gentlelady, the Ranking Member of the subcommittee, is recognized for 5 minutes. 

Ms. CLARKE. Thank you very much, Mr. Chairman. 

Let me thank our panelists and thank you for your patience. We 

need clones around here, that is all I can say. 

But let me say that in the brief moments I have had in the hearing I am not as concerned about our capability to secure the cloud, 

and I say that simply because we were innovative enough to invent 

it. I believe that our knowledge, our capability, our skills will enable us to protect. So I am going to be affirmative. 

Then when I think about young people today and their level of 

curiosity, their innovativeness, I know that somewhere seated in 

some classroom today is the person that is going to come forth who 

will enable us to do what we need to do to move forward with the 

innovations that we have as a civil society. So I am coming at this 

not as a scary person but as someone who is ready for the adventure. 

Having said that, I would like to ask this question of both Mr. 

Spires and Mr. Wilshusen: Did you look at the experiences of other 

Federal agencies in using public clouds before undertaking this effort? If so, what lessons did you learn and how did you apply them? 

What about State and private sector experiences? Were those also 

taken into account? 

Mr. SPIRES. Ma’am, we certainly have, within our strategy, had 

numerous discussions, both with other Federal Government agencies—NASA, the Veterans Administration come to mind, both of 

which have been very aggressive at looking at cloud capabilities. 

We have also talked to a number of—I have personally talked to 

a number of CIOs within private sector firms as well as my staff, 

who have been very involved in reaching out, as well as to advisory 

services that work in the I.T. industry and serve that industry. 

A few of the lessons learned—and I think we are still learning 

a lot of these lessons, right? I mean, one of our biggest issues, beyond security, because that is probably the biggest issue; we have 

been talking about that. But the next one is really, this is fundamentally a different business model, and it changes—I mean, we 

are buying a service-level agreement; we are not, you know, out 

there purchasing hardware and licensing software and integrating 

together. 

Fundamentally, how we procure this is very, very different. So 

we have been working across the Federal Government—and as a 
34 

matter of fact, in a couple weeks the Federal CIO Council and the 

Federal Chief Acquisition Officer Council are going to be meeting 

together to talk about this very issue: How do we work out the procurement issues, the business model issues, so that we put ourselves in the best position to leverage this capability from a business perspective? 

I would say that is where a lot of the lessons learned are. I think 

many of us are still feeling our way, to be honest, as to what is 

the right business model moving forward. 

Mr. WILSHUSEN. Ms. Clarke, when we conducted our review last 

year over cloud computing security we went to a couple of different 

agencies and looked at some of the pilot cases that were underway. 

We went to DOD and looked at the DISA RACE, which is the 

Rapid Access Computing Environment, and also looked at NASA’s 

Nebula cloud environment. 

A couple of lessons learned that they experienced had to do with 

just the assuring that they are having to reengineer some of their 

business processes in order to accommodate the use of the cloud 

computing. They also found that one of the challenges that they 

had was also clearly specifying and delineating the responsibilities 

for security of the client personnel, you know, at NASA, as well as 

the cloud provider. 

Now, in both cases each of their implementations were private 

cloud implementations. They decided in each case to take a kind 

of a slow, cautious approach before jumping in and maybe going to 

a public cloud. But in both cases they went to the private cloud implementation, which generally will have a lower threat exposure 

than public cloud. 

Ms. CLARKE. Then I want to ask, are there any agency applications or services that should never move to the cloud, or is everything an agency does open to the move? In either case, why would 

it be the case? 

Mr. WILSHUSEN. Well, I will take an initial stab at that. There 

is probably implementations and information that is so sensitive, 

perhaps, you know, classified information that needs to be particularly protected that it should not be placed out into a cloud environment, particularly a public cloud environment, given the current security capabilities present. So certainly classified information probably should not be placed in a public cloud environment. 

Ms. CLARKE. So would you say never, or do you foresee in the 

future that that capability will exist? Because my question was 

never. 

Mr. WILSHUSEN. Right. Well, I was taught from a very early age 

never to say never, and I think I will keep to that now. 

Mr. SPIRES. I think I have essentially the same answer, Ms. 

Clarke. In the I.T. field I have learned to never say never because 

things change so much, since, certainly, in the years I have been 

in this field. 

That being said, I would agree wholehearted with Greg. It is 

going to be quite a while before we would have any comfort in putting any classified information into a public cloud environment, 

and it may never happen. I think it will quite a few years before 

we would look to do that. 
35 

Mr. MCCLURE. Yes. The only thing I would add, Ms. Clarke, is 

that it goes back to what the agency sets as its requirements for 

what it is trying to do with its data and its service delivery. If the 

data demands protection levels that are beyond the capabilities of 

either in-house or out-house providers then you have got to address 

that. 

So the term ‘‘public cloud’’ is used pretty loosely. Actually, there 

are instances, I think, where you will see Federal agencies claiming 

they do have things in public cloud but it is not the equivalent of 

what you might find a consumer such as ourselves doing from our 

own homes. 

We have security requirements, records management requirements, 508 requirements. They have all these other requirements 

that still these providers have to show that they are able to provide 

that even though they may be called a public cloud solution. 

Ms. CLARKE. Thank you very much, Mr. Chairman. 

Mr. LUNGREN. Mr. Keating, you are recognized for 5 minutes. 

Mr. KEATING. Thank you, Mr. Chairman. 

With the new technologies I think there is a possibility of increased risk on infringement of copyright holders’ rights because of 

the nature of this, that it is faster, cheaper, and it is easier to engage with unauthorized reproduction and distribution of public performances of types of copyrighted works. To what extent can the 

increased reliance on the data storage through cloud computing 

services contribute to this kind of copyright infringement? Do you 

see an issue there? 

I will throw it open to the whole panel. 

Mr. MCCLURE. Sure. I will take a stab at it first. 

I think it goes back to in any environment, private or public 

cloud regardless, you have still basic security and privacy standards that have to be met. Access controls come to mind in this particular case. Who has access to information in these cloud environments is still a huge issue. If you don’t define that and put the controls in place then you are subject to losing information no matter 

what kind of cloud environment you have it in. 

Mr. KEATING. Yes. 

Anyone else? 

Mr. Spires. 

Mr. SPIRES. I would just add, sir, that one of the things we are 

really working on within Homeland Security is strengthening our 

identity credential and access management capabilities, to pick up 

on what Dr. McClure said. We foresee in the future having a much 

stronger authentication model to protect against these very types 

of things, whether it be copyright infringement, or in our case we 

are very concerned about privacy and civil liberties, right, and access to the data that we store. 

That really transcends whether you are in a cloud environment 

or whether this is just a more traditional kind of I.T. system and 

database. But these are the things that we are working on right 

now that strengthen the safeguarding side yet still enable the right 

kind of information-sharing to protect the homeland. 

Mr. KEATING. Okay. 

Mr. WILSHUSEN. I would just like to add that I agree that authorization and identification and verification is going to be key in 
36 

this respect. The one additional wrinkle—not to poke a hole or anything—is that the responsibility for sharing that the authorization 

is correct and the identity of the user is actually verified and 

claimed may no longer reside with the Federal Government or the 

Government agency with the cloud service provider. So the effectiveness of the cloud service provider’s controls and access controls 

come into play as well. 

Mr. KEATING. Okay. That is interesting. 

Thank you very much. I had just one other—might be a bit tangential, but, you know, in terms of the Government security and 

securing Government data, there is the use of flash drive-type 

products as well. Is there any advantage or differentiation that is 

being made when you have that kind of, you know, product, in 

using a hard drive kind of system versus a software authentication? 

Do you get anything more out of—from a secure basis—out of the 

hardware kind of authentication for that type of product than just 

the software itself? I mean, is it—where do you see it going? I 

mean, do you need both? Is it fine just with software, or do you 

think there is a need for that going forward for secure data? 

Mr. WILSHUSEN. Well, I will take the initial stab. Yes, I think, 

you know, the hardware’s authentication and security is something 

that can definitely help protect information, and particularly with 

flash drives and thumb drives. It, as you know, is a key risk because those devices can contain—— 

Mr. KEATING. Right. 

Mr. WILSHUSEN [continuing]. Large volumes of information and 

they are extremely portable, as they are designed to do. Some 

agencies, like the Department of Defense, has banned their use on 

their systems because they also are carriers or can be used to carry 

malicious software and install that on devices on an agency’s internal network. 

Mr. KEATING. Okay. 

I will yield back my time, Mr. Chairman. Thank you. 

Mr. LUNGREN. Thank you very much. 

I want to thank this first panel for not only testifying but understanding we have votes that interrupt, I understand that this takes 

a portion of your day, and we appreciate you being here. We thank 

you for your testimony. 

The Members would request the Members of the committee may 

have some additional questions for you that we might submit in 

writing. We would ask that you would respond to those in writing. 

With that, I am happy to thank you and dismiss you, and we will 

move on to the second panel. 

I am going to ask unanimous consent that Mr. Duncan, who is 

a Member of the full committee but not a Member of the subcommittee, can sit for this second panel and have the privilege of 

introducing someone from his State when we get there. 

So thank you, to the first panel. 

If the second panel would come up, Mr. Sheaffer, Mr. Brown, Mr. 

Bottum, and Mr. Curran? 

Today we have the opportunity to hear from a distinguished second panel on the question of ‘‘Cloud Computing: What Are the Security Implications?’’ 
37 

We have Mr. James Sheaffer, the president of Computer Science 

Corporation’s North American Public Sector. Previously, Mr. 

Sheaffer served as vice president for CSC as well as a general manager of Prime Alliance—that is CSC’s partnership with the IRS— 

to support the business systems modernization program. Prior to 

joining CSC Mr. Sheaffer spent 27 years in the American Management Systems, Inc. working on telecommunication in North America and Europe. 

Mr. Timothy Brown is vice president and the chief architect for 

security management at CA, Inc. With more than 20 years of information security experience, Mr. Brown has been involved in many 

areas of security, including threat research, vulnerability management, consumer and enterprise identity, access management, network security in the encryption compliance and managed security 

services. 

John Curran is the president and CEO of American Registry for 

Internet Numbers. He serves as the chief technology officer and 

chief operating officer for ServerVault as well as the chief technology officer at XO Communications and BBN/GTE Internetworking. Mr. Curran also has been an active participant in the 

Internet Engineering Task Force. 

It is my privilege to allow Mr. Duncan to introduce the next gentleman, who, as I understand, had something to do with Purdue 

University. Since I went to Notre Dame I would like you to introduce him. 

Mr. DUNCAN. Okay. Thank you. 

[Laughter.] 

Mr. DUNCAN. Thank you, Mr. Chairman. Thanks for giving me 

the opportunity, and thanks to the committee for allowing me to 

sit on the dais with you this morning. 

It is my distinct pleasure to introduce one of my constituents, but 

he is also someone from my alma mater, Clemson University. Jim 

Bottum is a chief information officer and vice provost for computing 

and information technology for Clemson University. 

Clemson, Mr. Bottum leads efforts focusing on high-performance 

computing and communication as well as collaborating with State 

and National government entities. Under his leadership, Clemson 

University’s Palmetto Cluster has appeared at No. 60 in the world’s 

top 500 computing sites alongside Clemson’s Computational Center 

for Mobility Systems, ranked at No. 100. 

Mr. Bottum currently serves on the NSF Advisory Committee for 

Cyber-Infrastructure, NSF Advisory Committee for CRPA Assessment, and the I–2 or Internet 2 Board of Trustees. Prior to coming 

to Clemson, Mr. Bottum was the first CIP and VP for computing 

at Purdue, where he was responsible for planning and coordinating 

all computing and information systems across the university. 

He has also served on other NSF committees as well as National 

laboratory boards and provided consulting services for major universities across the United States. He has worked extensively on 

issues of cloud computing and should provide an excellent perspective of this issue from his academic research and experience. 

I look forward to hearing his testimony and thank you for having 

him here today. I yield back. 

Mr. LUNGREN. I thank the gentleman. 
38 

* The information has been retained in committee files. 

We thank you all for being here. We thank you for your indulgence, in that I know you had to wait as well, as we went over to 

vote. 

We have the procedure here that your written remarks will be 

made a part of the record in their entirety, and we would ask you 

to limit your verbal remarks to 5 minutes apiece, and I would ask 

Mr. Sheaffer to go first. 

STATEMENT OF JAMES W. SHEAFFER, PRESIDENT, NORTH 

AMERICAN PUBLIC SECTOR, COMPUTER SCIENCES CORPORATION 

Mr. SHEAFFER. Thank you. Mr. Chairman, Ranking Member 

Clarke, Mr. Duncan, it is an honor for me to appear before you 

today. 

My name is Jim Sheaffer. I am president of CSC’s North American Public Sector, with 29,000 employees who proudly serve and 

support the missions of Federal agencies. 

I also recently served as vice chair for the Public Sector for 

TechAmerica Foundation’s Commission on the Leadership Opportunity in U.S. Deployment of the Cloud. In July our commission 

issued a report called ‘‘Cloud First, Cloud Fast’’ that included 14 

specific recommendations for the Federal Government to accelerate 

the adoption of the cloud, and I respectfully request that that document be entered into the record.* 

Let me offer a brief word about CSC. Last year we had revenues 

of just over $16 billion. We are acknowledged as a leading global 

provider of I.T. services. We deliver large-scale projects for both 

public and private sector clients, and we provide cybersecurity to 

some of the world’s largest companies and some of the most sensitive U.S. Government agencies. 

By leveraging shared computing resources, higher utilization 

rates of hardware, and economies of scale, cloud computing is ushering in an I.T. revolution. Users pay only for what they consume. 

Cloud computing and the as-a-service delivery model enable organizations to cut costs of computing, build capacity for growing volumes of data, and burgeoning requirements for computation. 

Cloud is a hot topic, but it is only the latest evolutionary step 

in the field. I began first with custom-build computers, moved to 

mainframes, on to personal computers, then to client-servers, and 

then to the internet. 

What is different about the cloud is the rate of adoption. The economics are compelling and the take-up of this technology is much 

faster than some of the earlier technologies that were adopted. In 

fact, the global nature of the cloud makes this a different kind of 

phenomenon. 

Today’s austere Federal budget climate offers an added incentive 

for agencies to adopt the cloud, but it also raises questions of trust. 

Trust is more than just security. U.S. citizens and users must believe in the integrity and reliability of cloud computing in addition 

to security. 
39 

We acknowledge the challenges. One, the speed of cloud advancement requires new security policies and even new security technologies and procedures. 

The internet, which is the foundation for the cloud, was originally designed without a primary focus on security, and since then 

we have had to play catch-up to make it secure. In the future it 

will require the design of intrinsically secure architectures to ensure security. 

A second risk is that all required security standards for cloud are 

not yet in place, as we heard from the prior—the previous panel. 

The National Institute of Standards and Technology and the Cloud 

Security Alliance, a nonprofit coalition, are developing, with industry support, those standards, and we believe that they need to be 

global standards, not just standards here in the United States. 

Third, cyber threats are serious and dynamic, and becoming 

more pernicious. Threats are more severe than we experienced in 

the past, and the capabilities of bad actors are evolving swiftly. 

The risks and challenges to cloud computing are substantial but 

not insurmountable and should not be used as an excuse to shrink 

from the adoption of the cloud. Fundamentally, cybersecurity must 

be integral to the architectures and not bolted on after the fact. We 

at CSC are confident that prudent cloud computing adoption can 

meet the stringent security requirements. 

How should those risks and challenges be addressed? The key is 

to align the risk profiles of various types of data and their uses 

with the levels of protection required. 

One-size-fits-all approaches provide neither effective security nor 

the lowest cost. Each application and data set must be evaluated 

to identify its specific security requirements, and then appropriate 

cloud solutions can be implemented, choosing from private, public, 

or hybrid clouds. 

As an evolving technology, it is important to gain feedback and 

lessons learned from the implementation of cloud computing. Lessons will need to be shared across agencies, as one of your previous 

questions indicated. 

The Department of Homeland Security is laudably reaching out 

to foster a more secure and resilient cyber environment. The Department is leaning forward to show leadership in cloud adoption. 

In consolidating infrastructure from the 22 components of the 

primary data center at Stennis and its backup, DHS is increasing 

the productivity of its capital investment in computing and it has 

also implemented a private cloud behind its firewall and security 

systems. The Department is clearly an early and prudent adopter 

of cloud computing. 

One example of the success of this approach is our systems. With 

our assistants at DHS we are designing and implementing a private cloud for DHS that will reduce the time to provision new software development and test environments from months to just a 

couple of days. 

In conclusion, cloud computing offers enormous opportunity to 

improve performance and reduce costs. Security issues can be managed. The United States is a leader worldwide in cloud adoption, 

and we can and must maintain that position. 

I welcome your questions. Thank you. 
40 

[The prepared statement of Mr. Sheaffer follows:] 

PREPARED STATEMENT OF JAMES W. SHEAFFER

OCTOBER 6, 2011 

Mr. Chairman, Ranking Member Clarke, and Members of the subcommittee, it is 

an honor to appear before you today to discuss security implications of cloud—or 

shared—computing. The subcommittee laid a good basis for today’s discussion in its 

April 15 hearing on promoting Department of Homeland Security cybersecurity innovation and securing critical infrastructure, and its June 24 hearing on the homeland security impact of the administration’s cybersecurity proposal. 

I am Jim Sheaffer, President of CSC’s North American Public Sector. Recently I 

served as Vice-Chair for the Public Sector of the TechAmerica Foundation’s Commission on the Leadership Opportunity in U.S. Deployment of the Cloud (CLOUD2). 

The mandate of the Commission was to provide recommendations on how the Federal Government could deploy and accelerate the adoption of cloud technologies, and 

to address public policies that would enable U.S. innovation in the cloud. In July, 

the Commission issued a report—Cloud First, Cloud Fast—that addresses some of 

the issues we are discussing today. 

Let me begin by offering a brief word about CSC. Last year we had revenues of 

just over $16 billion. Three-fifths derived from IT services provided to the private 

sector, and two-fifths from a range of services for the public sector. Acknowledged 

as a leading global provider of IT services, CSC delivers large-scale IT projects for 

both public and private sector clients. We provide cybersecurity to some of the 

world’s largest companies, including critical infrastructure providers, and some of 

the most sensitive U.S. Government agencies. 

CLOUD COMPUTING

By leveraging shared computing resources, higher utilization rates of computing 

hardware, and economies of scale, cloud computing is ushering in an IT revolution 

which promises far lower costs while greatly improving capacity and performance. 

Cloud computing combines self-service provisioning of software applications and IT 

infrastructure with on-demand scaling of computing and storage in which users pay 

only for what they consume. Cloud computing and ‘‘as-a-service’’ delivery enable organizations to slash unit costs of computing, and build capacity for rapidly growing 

volumes of data and burgeoning requirements for computation. 

Cloud computing is a hot topic. In essence, it is just the latest evolutionary step 

that has taken us from custom-built computers to mainframes to personal computers to client-servers, and then to the internet. What is different about cloud computing is the accelerating pace of change, rapid adoption rates, and global nature 

of its use. 

Cloud innovation allows entrepreneurs and public sector innovators to create 

value at little to no capital expense in computing resources, unlike the previous 

waves. Cloud computing disrupts existing business models and enables wholly new 

ones. The explosion of mobile computing catalyzes even faster adoption of cloud computing. 

Cloud computing hardware can reside on-premise at an organization’s facility, or 

off-premise, such as at an IT provider’s facility. The National Institute of Standards 

and Technology (NIST) defines four types of environments for cloud computing: (1) 

Private cloud that is operated by an organization and may exist on-premise or offpremise; (2) Community cloud that is shared by multiple organizations related to 

a specific community and may exist on-premise or off-premise; (3) Public cloud that 

is available to the general public, owned by a commercial vendor and located offpremise; and (4) Hybrid cloud that is a combination of two or more clouds (private, 

community, or public). 

TRUST

Today’s tight Federal budget climate offers an added incentive to agencies to 

adopt the cloud. But while cloud computing offers substantial benefits, such as cost 

savings, speed, and responsiveness to mission needs, it also raises questions of trust. 

Trust encompasses such concepts as security, availability, reliability, transparency 

to the user, and ability to extract data. 

The pace and degree of adoption of cloud delivery services will depend on establishing a basis of trust. This begins with understanding the risks and challenges. 

Can important data be entrusted to the cloud? Are there new risks and challenges 

to trust, especially the security of data? 
41 

Let us look at the new risks and challenges to trust. One, the speed of cloud technology advancement requires new security policies, and even new technologies and 

procedures, to keep pace with cloud advancements. Most current knowledge about 

IT security is based on a world in which most computer resources are under the 

direct control of a person or organization and in which physical and technical means 

exist, including software firewalls, to control access. Moreover, the internet was 

originally designed without a primary focus on security; since then computer security specialists have played catch-up. 

Many of those security concepts must be reconsidered for a world in which cloud 

computing enables a much broader spectrum of solutions and much greater cost savings derived from the sharing of computing, storage, and network resources, bringing new economies of scale. For example, firewall technologies designed for operating inside the virtual fabric of cloud architectures—the design of cloud computing 

systems—are just now becoming available, and they remain largely untested. 

A second risk is that all of the required security standards for cloud computing 

are not yet in place. Clear, understandable, and verifiable standards are essential 

for building trust. The National Institute of Standards and Technology and the 

Cloud Security Alliance—a non-profit coalition of practitioners, companies, and associations—are conducting research and developing new cloud security standards. 

Third, while not specific to cloud computing but relevant to it, cyber threats are 

serious and dynamic—and becoming more pernicious. Business and Government 

alike face threats much more severe than in the past, and more likely to change 

and do so swiftly. 

Advanced Persistent Threats tend to be state-sponsored and target especially sensitive information, such as military and financial data and intellectual property. 

Such information lies at the heart of America’s security and economic well-being. 

The risks and challenges to cloud computing are substantial but not insurmountable. Of fundamental importance, cybersecurity must be integral to cloud computing 

architectures and not be ‘‘bolted-on’’ after the fact. CSC participates in various forums that develop standards. CSC’s rigorous validation and testing programs promote innovation for security solutions. 

On balance, we are confident that prudent cloud computing will satisfy stringent 

security requirements. USCYBERCOM Commander General Keith Alexander said 

it best to a House Armed Services Subcommittee last March: 

‘‘The idea is to reduce vulnerabilities inherent in the current architecture and to exploit the advantages of cloud computing and thin-client networks, moving the programs and the data that users need away from the thousands of desktops we now 

use—up to a centralized configuration that will give us wider availability of applications and data combined with tighter control over accesses and vulnerabilities and 

more timely mitigation of the latter.’’ 

WAYS TO ENHANCE SECURITY

How should security risks and challenges be addressed? The key is to align risk 

profiles of varying types of data and uses with levels of protection required. 

Understanding the risk profiles of data being considered for the cloud is key to 

determining the required levels, and hence costs of security. One-size-fits-all approaches provide neither effective security nor the lowest-cost solution. Each software application and data set must be evaluated to identify its specific security requirements. For example, published scientific research may be suitable for lessstringent cloud computing environments than are needed for classified intelligence 

data on potential terrorists. CSC is assisting Federal agencies to develop roadmaps 

that outline risk profiles of data sets and identify appropriate cloud solutions. 

It will be important to gain feedback and learn lessons from implementations of 

cloud computing. They can help identify best practices and improve security for future uses. 

FEDERAL POLICY

Federal policy on cloud computing and its security has evolved rapidly. In 2002 

the Federal Information Security Management Act, or FISMA, came into force. It 

establishes a ‘‘comprehensive framework designed to protect government information, operations and assets against natural and man-made threats,’’ and requires 

program officials, chief information officers, and inspectors general to conduct annual reviews of information security. 

The Federal Risk and Authorization Management Program, or FedRAMP, was initiated in 2010 to provide a standard approach across the Federal Government for 
42 

assessing and authorizing cloud computing services and products. A common security risk model enables the Federal Government to ‘‘approve once, and use often.’’ 

In the 25-Point Implementation Plan to Reform Federal Information Technology 

Management, issued on December 9, 2010, the Office of Management and Budget 

called for reducing the number of Federal data centers by at least 800 by 2015 and 

creating a Federal-wide marketplace for data center availability. Curiously, not one 

of OMB’s 25 points focused on cybersecurity. 

On February 9, 2011, OMB issued a Federal Cloud Computing Strategy, which 

gives more attention to security. It cautions that cloud security is an exercise in risk 

management, ‘‘identifying and assessing risk, and taking the steps to reduce it to 

an acceptable level.’’ Risk management based on intelligent risk assessment enhances the protection of the most valuable information and is more cost-effective 

than compliance-based approaches. 

The Federal Strategy points to several potential security benefits of cloud computing. The first is the ability of the cloud provider to focus centralized resources 

on security services. Second, the greater uniformity and homogeneity of the cloud 

platform eases security management and improves response times. A third benefit 

is the improved resource availability of the cloud provider through scalability, redundancy, and disaster recovery capability. Fourth are the improved backup and recovery capabilities and procedures that a cloud provider can offer. A fifth potential 

benefit of cloud computing is the ability to leverage, as needed, services from other 

data centers. 

At the same time, the Federal Strategy highlights potential vulnerabilities of 

cloud computing. One is the inherent system complexity of a cloud computing environment. A second vulnerability is dependency on the service provider to maintain 

secure logical separation in a shared computing resource, or what is called a multitenant environment. A third potential vulnerability is the cloud user’s need to have 

sufficient knowledge of potential threats and vulnerabilities to know how to make 

decisions and set priorities on security and privacy. 

Increasing experience in the implementation of cloud computing, with careful attention to security, will help validate and refine our collective understanding of its 

benefits and risks. 

The Department of Homeland Security is laudably reaching out across the Federal Government and the private sector to foster a more secure and resilient cybersecurity environment. The DHS Chief information Officer is leaning forward to show 

leadership in cloud adoption. 

In moving data from 22 separate components into the primary DHS Stennis data 

center and a secondary backup center, DHS has increased the productivity of its 

capital investment in computing. While migrating into the two consolidated data 

centers, DHS has also implemented a private cloud behind a DHS-controlled firewall and security systems. As new security standards are developed and effectively 

verified, more data will be ready to move to the cloud. In addition to private cloud 

implementation, DHS is moving certain public-facing websites, such as DHS.gov 

and FEMA.gov, into a public cloud in order to increase efficiency and productivity. 

DHS is an early and prudent adopter of cloud computing and its experience may 

be instructive for others. 

CLOUD EXAMPLES

Let me outline three examples of how cloud computing can be implemented in a 

homeland security context. 

First, CSC helps a global chemical company that is part of America’s critical infrastructure. Its research unit must allow access to scientists and others from inside 

and outside the company to foster collaboration for new discoveries. Researchers require high-performance computing and surge IT capacity, and they store highly sensitive intellectual property. The research unit must accommodate projects that start 

and stop abruptly and then restart. 

CSC has installed a private cloud that the chemical company manages to satisfy 

its own special security requirements. The company has deployed cloud access at 

each of its laboratories around the world, and CSC federates and orchestrates cloud 

services across the chemical company’s global IT infrastructure. 

In a second example, DHS wanted more responsive computing. It opted for cloud 

computing for the development and testing of new computer application systems. 

This eliminates costly and time-consuming tasks of procuring, installing, and testing 

new computer hardware and software every time a software development team 

starts a new project. 

To support DHS, CSC designed and is implementing a private cloud that will reduce the time to provision new development and test environments from months to 
43 

just a couple of days. We are also assisting with a strategy and plan for helping 

DHS encourage management and cultural changes required to take best advantage 

of the cloud. 

A third example is the potential for increased use of unmanned aerial vehicles to 

help DHS monitor U.S. borders. Evolving technology will allow aerial platforms to 

collect greatly increasing amounts of ground imagery. As this develops, cloud computing could assist DHS to expand data collection and processing while holding 

down computing costs. 

RECOMMENDATIONS

I wish to call special attention to four important recommendations from the 

TechAmerica Commission Report, and offer a fifth recommendation. 

First, the Federal Government and the private sector should support the creation 

of international standardized frameworks for securing, assessing, certifying, and accrediting cloud computing. 

Second, the public sector and the Federal Government should accelerate the development of an identify management ecosystem to facilitate the adoption of strong authentication technologies, enabling more secure access to cloud services and 

websites. 

Third, a law is needed to clarify responsibilities of companies to notify customers 

in the event of data breaches, and strengthened criminal laws are required against 

those who attack computer systems, including cloud services. 

Fourth, the Federal Government and the private sector should develop and execute a more robust joint research agenda for cloud computing. 

Fifth, verification and continuous monitoring of cloud security ought to be standardized. Independent, professional third-party audit of cloud providers should become standard practice, along with real-time transparency in the security posture 

of cloud-based systems. 

CONCLUSION

In conclusion, as the use of cloud computing accelerates, better security must go 

hand-in-hand with saving money and improving performance. Cybersecurity must 

be integrated into cloud computing architectures at the outset, rather than be left 

to ‘‘catch up.’’ This will enhance trust in the information revolution that underlies 

so much of America’s prosperity and homeland security. 

I welcome your questions and comments. Thank you. 

Mr. LUNGREN. Thank you very much, Mr. Sheaffer. 

Now, Mr. Brown. 

STATEMENT OF TIMOTHY BROWN, SENIOR VICE PRESIDENT 

AND CHIEF ARCHITECT FOR SECURITY, CA TECHNOLOGIES 

Mr. BROWN. Chairman Lungren and Members of the subcommittee, I want to thank you for the opportunity to talk to you 

today. CA Technologies is one of the world-leading I.T. management software companies that provides software and services to enterprise, governments, and cloud providers. 

The hype and promise to the cloud continue to accelerate, but it 

is clear that significant confusion remains about exactly what cloud 

computing is and the risks and benefits associated with it. Security 

is the concern cited most. 

When you consider the loss of direct control involved with the 

cloud these concerns are expected, but they must be addressed for 

the cloud to be successful. From a security perspective, any service 

that is accessed outside of an enterprise’s direct control should be 

considered a cloud service. 

Services like ADP, for check processing, and a 401(k) portal are 

good examples of—that have been around for a long time. Cloud is 

not new, but the current momentum and explosion of new cloud 

services gives us opportunity to enhance cybersecurity. 

Mr. LUNGREN. I think we lost your mike there. 
44 

Mr. BROWN. Am I back? 

Mr. LUNGREN. There you are. 

Mr. BROWN. All right. We will move up. Here we go. 

So CA Technologies believes the responsibility for cloud security 

lies with both the providers and the consumers. The cloud is neither inherently more secure nor less secure than other I.T. services. 

Security fears and arguments that those fears are overblown 

have muddied the waters about this vital issue. To provide some 

clarity I will focus on four critical areas affecting cloud security. 

First, it is important to note that cloud won’t replace all other 

technologies and service delivery options. As organizations move to 

the cloud it will be one of many platforms that must be operated 

and managed together to minimize risk and security 

vulnerabilities. We should be wary when people say that cloud will 

replace all technologies. 

Second, the responsibility for security rests with both the provider and the consumer of cloud technologies. Different cloud services have different risk profiles. 

What is important is transparency. Customers and providers 

need to agree upon those security expectations and know that the 

service being deployed meets those requirements. 

Customers must have trust in their cloud service providers but 

also must have the ability to verify their claims and performance. 

Cloud customers need to be vigilant in their investigation, auditing, 

and oversight of their providers. Cloud providers must approach securing their customers’ data with the same degree of seriousness 

as the owner of the data. 

Third is that a strong trusted identity system that enables the 

right people to have the right access to the right information at the 

right time is vital to securing the cloud. Many of the data breaches 

we read about today find their root cause in weak identity and access management controls. 

To be certain the move to the cloud doesn’t create new security 

risks cloud consumers should ask the following: Who has and needs 

access to what? What can they do with that access? What can they 

do with the information they obtain? Finally, what did they do with 

that information? 

On-line banking and bill pay services provide an example of how 

transactions between different cloud services can be accomplished 

using strong identity management. As most of us know, different 

on-line banking transactions have different risks, and banks have 

implemented tiered security requirements based on that risk. Simply accessing your account balances requires one level of authentication, while transferring funds may require a higher degree of 

security. 

If you want to authorize your bank to pay a bill, your bank may 

need to access a bill payment service in the cloud on your behalf. 

This type of transaction requires that the bank and the bill pay 

service have trusted and transparent security practices that are audited and enforced. 

Finally, the adoption of standards is critical to the security and 

operability in the cloud. CA Technologies contributes actively to the 
45 

efforts of standards organizations, such as OASIS, and collaborates 

with NIST. 

There are two efforts I would like to highlight. The first is 

FedRAMP. 

FedRAMP offers the promise that solutions can be accredited 

once and used many times across Federal agencies. While we await 

the final draft of FedRAMP, several questions about its scope and 

its implementation remain. We recommend that Congress continue 

oversight to be sure these important questions are answered. 

The second is the National Strategy for Trusted Identities in 

Cyberspace, or NSTIC. NSTIC is aimed at enhancing trust by 

strengthening industry-based identity management practices and 

minimizing the proliferation of username and password combinations we use on-line. 

NSTIC has asked for its first budget in fiscal year 2012. We recommend that Congress fund this important effort. 

Finally, I would like to offer several additional recommendations 

for your consideration. First, because we are in the nascent stage 

of cloud adoption, Congress should look at cloud policy issues 

through the lens of outcomes, not specific technologies. Static rules 

and mandated checklists are not adequately flexible and will rapidly become outdated as new technologies emerge. 

Second, Congress should avoid adopting policies that create a 

country-specific—country-specific policy. For U.S. businesses in 

competing markets all over the world, global harmonization policy 

will enable industry to build solutions that can be delivered in multiple markets and will enhance our competitiveness. 

Finally, the cloud is an opportunity for new business models, enhanced security, and for the United States to drive innovation and 

technical leadership. We recommend that Congress support the important policy recommendations from the TechAmerica Cloud2 commission. 

I appreciate your opportunity to be here for you today. I would 

be happy to answer any questions. Thank you. 

[The statement of Mr. Brown follows:] 

PREPARED STATEMENT OF TIMOTHY BROWN

OCTOBER 6, 2011 

Good morning Chairman Lungren, Ranking Member Clarke, and Members of the 

subcommittee. My name is Tim Brown and I’m honored to be here today to testify 

on cloud computing security risks and opportunities. I am the senior vice president 

and chief architect for security at CA Technologies. CA Technologies (www.ca.com) 

is one of the world’s largest information technology management software providers. 

The company has expertise across IT environments—from the mainframe and distributed computing to virtual and cloud technologies. CA Technologies manages and 

secures IT environments and enables customers to deliver more flexible IT services. 

The majority of the global Fortune 500 and most major Federal and State government agencies rely extensively on CA Technologies software to manage their constantly evolving technology environments. Founded in 1976, CA Technologies is a 

global company with headquarters in New York, 150 offices in more than 47 countries, and thousands of developers and researchers worldwide. 

CA Technologies was honored to serve on the TechAmerica Foundation’s Commission on the Leadership Opportunity in U.S. Deployment of the Cloud (CLOUD2), 

and was heavily involved in the development of the Commission’s recommendations. 

Since another member of the Commission is participating in the hearing today, I 

will focus the bulk of my remarks on a number of specific cloud security issues CA 

Technologies believes are critical to ensure secure adoption of cloud computing. 
46 

However, CA Technologies supports the recommendations of the CLOUD2 report 

and I address many of the issues covered in the Commission’s report in my testimony today. 

CA Technologies believes that cloud computing is neither inherently more nor less 

secure than other IT platforms, and that securing the cloud is a shared responsibility of both providers and consumers of cloud services. There are a number of policy issues that must be resolved to realize the cloud’s potential and we will focus 

on those issues on our testimony today. 

INTRODUCTION

While both the hype and promise surrounding cloud computing continue to accelerate at a feverish rate, it is clear that significant confusion remains in global markets about what exactly cloud computing is and what the risks and benefits are associated with transitioning to this latest technology. Corporate and governmental organizations across the globe are anxious to reap the cost, performance, and agility 

benefits that the cloud can offer, but at the same time are wary of a range of risks 

that accompany a different way of buying and consuming technology solutions. 

Chief among concerns raised in survey after survey of both current and potential 

cloud customers is security. Security is often followed by related concerns about data 

privacy as well as interoperability, availability of cloud services, performance, and 

transparency of providers. When one considers the loss of direct control that accompanies cloud deployments, concerns about security risks associated with moving to 

the cloud are not only reasonable, but also expose critical operational risk management issues that must be discussed and addressed when determining if and when 

to move particular services to the cloud. 

It is important to keep in mind that from a security professional’s perspective, any 

service that runs outside of the operationally-controlled environment of an IT organization is considered a cloud service. This is true in the case of commonly-known 

cloud services like Salesforce.com, Google Docs, and cloud email, but also includes 

services like ADP, 401(k) programs, corporate travel sites, and health plans. No two 

applications or systems are alike, and pragmatic implementation of cloud technologies necessitates that risk-based processes be used to determine what services 

and applications may or may not be feasible to move to the cloud, their level of sensitivity, what platform is most suitable, whether a private or public cloud environment is appropriate, and the specific security and operational controls that are 

needed. 

The use of cloud computing represents an exciting new opportunity for IT organizations and for CIO’s in both business and Government to remake the way in which 

they work together with their customers and the user communities that rely on ITbased services. Because cloud computing enables IT organizations to focus on business services rather than infrastructure, technology organizations will have increased agility to build new solutions to support their customers with minimal investment. 

In my testimony today, I would like to focus on the four key areas that CA Technologies feels must be considered in evaluating both the opportunities and risks associated with the transition to cloud: 

• The reality of new complexities introduced with the adoption of cloud computing; 

• Security considerations for the cloud; 

• The critical role that identity management and authentication play in enabling 

cloud security; and 

• The importance of standards development and adoption to ensure interoperability and common implementation of cloud solutions globally. 

I will also make some recommendations on the role Congress can play in fostering 

the secure uptake and adoption of cloud computing solutions. 

THE ‘‘NEW NORMAL’’ OF CLOUD COMPUTING

A theme that CA Technologies keeps hearing from our customers is that they 

want to use cloud computing as a real game-changer. The layers and layers of complexity in IT have made it increasingly more challenging to deliver new services to 

the business in a rapid manner. The global downturn in markets across the globe 

has resulted in flat and/or declining IT budgets in both the commercial and public 

sectors. But the demand for new technology-based services inside large organizations has not slowed, so IT organizations are constantly challenged to provide more 

business technologies faster with reduced resources. 

These factors have all contributed to the perfect storm that has emerged for cloud 

uptake across the globe. 
47 

It is important to note that while many would have you believe that cloud technologies will replace all on-premise IT, in reality the transition to cloud technologies 

will be gradual and the need to develop and support on-premise solutions will remain for the foreseeable future. The introduction of cloud technologies will create 

greater complexities for IT organizations to manage and support. With cloud solutions, a single business service may include a combination of physical, virtual, and 

cloud components that all must work together to deliver the functionality that users 

expect. 

Consumers of cloud technologies will find themselves in a hybrid technology environment for a long time. Existing solutions and technologies will still need to be 

maintained, and cloud technologies will most often serve as a natural extension of 

existing IT environments. As such, the cloud introduce a new heterogeneity to IT 

environments, one that will require coordinated and orchestrated management, 

transition plans, and risk-based security evaluations. 

This can be a real boon to IT organizations that can harness the enthusiasm and 

momentum of the cloud to drive changes that have been needed in the management 

process for technology generally. One of the most promising aspects of cloud computing is its ability to fill the gap between technology supply and demand and help 

organizations focus less on commodity IT services and more on what is unique to 

their particular business or Government program. Off-loading standard services and 

functions to the cloud can save money and resources that can be better utilized to 

drive change and tackle problems that are more foundational and transformative to 

businesses and governments. At CA Technologies, we call this opportunity the innovation dividend. 

To gain this dividend, however, IT organizations must take a very focused and 

methodical approach to evaluating what should or should not be moved to the cloud. 

The means that organizations need to evaluate people, processes, technology, and 

perhaps most importantly, risk involved with each potential opportunity move to the 

cloud. Organizations may determine that certain services, applications and data are 

too critical or sensitive to be moved to the cloud, which can be an appropriate risk 

management decision. The cloud is not a panacea, and may not be appropriate for 

all workloads. Organizations must take a measured approach that is driven by substantive analysis of the risks and opportunities associated with each opportunity to 

migrate services to the cloud. 

Once decisions have been made to move a particular service or application to the 

cloud, organizations must evaluate what providers and what services will meet their 

needs. All of these analyses have impacts on and contribute to the security posture 

of the organization. Some of the considerations that CA Technologies advises our 

customers to use in evaluating providers include the following, which have been developed through the Cloud Service Measurement Initiative Consortium (CSMIC) 

that I provide additional details on later in my testimony: 

• Accountability.—Can we count on the provider to deliver the promised service? 

• Agility.—Can the service be changed, and how quickly? 

• Assurance.—How likely is it that the service will work as expected? 

• Cost.—How much is it, including both start-up and on-going costs? 

• Performance.—Does the service do what we need? 

• Usability.—Is it easy to learn and use? 

• Portability.—Can I move my data and application from one provider to another? 

• Security and Privacy.—Is the service safe and privacy-protected? 

SECURITY ISSUES IN THE CLOUD

Just like when you buy a car, an appliance, or any other service, the reputation 

of cloud providers and their ability to deliver on the service promised is a key consideration when making a purchase of cloud solutions. The Cloud Service Provider 

ecosystem is just as diverse as any other industry. Responsible providers want to 

do all they can to demonstrate trust and accountability to their customers and that 

security services are built in and not bolted onto their solutions. These providers 

will be in the cloud marketplace for the long run and will continue to drive innovation and excellence in the industry. But it is important to keep in mind that new 

and innovative cloud service providers are emerging daily. We are in the midst of 

a significant expansion period in the cloud market, and the ever-expanding number 

of providers who want to move into the cloud market may not have long-term interest or commitment to the technology, which in turn may create risks for customers 

who want to embrace the cloud. Customers must have assurance their provider of 

choice will be there when they need service modifications or need to move their data 

and applications elsewhere, and that they take the responsibility of securing their 

data as seriously as they do as the owner of that data. 
48 

1The 14 focus areas identified by the Cloud Security Alliance are the following: Governance 

and enterprise risk management; legal and contracting issues; procedures for electronic discovery; compliance and audit; information life-cycle management; portability and interoperability; business continuity and disaster recovery; data center operations; incident response, notification, and remediation; application security; encryption and key management; identity and 

access management; storage operations; and virtualization operations. 

The Cloud Security Alliance (CSA), a major industry consortium focused on cloud 

security issues, has identified 14 critical focus areas for organizations deploying 

cloud computing resources.1 CA Technologies/Ponemon Institute survey of the cloud 

service provider community made use of these 14 areas in a report released earlier 

this year. The survey data uncovered a wide range of viewpoints on the role that 

cloud service providers have in providing security for their solutions. With lower 

costs and faster deployment being the main drivers for moving to cloud services, 

some providers feel that security is more the responsibility of cloud customers than 

it is of providers. 

In reality, not all cloud services require the same level of security. It will be appropriate for certain workloads to be deployed in the cloud with different security 

levels than others. But the goal of cost savings that is so often identified as the 

main driver for cloud adoption sometimes masks the importance of security risk 

management. Security must remain at the forefront of all cloud strategy discussions 

to ensure the right sets of security controls are applied to the right services. What 

is important is that security, performance, cost, and accountability decisions are 

clear and transparent to the users of cloud services. 

CA Technologies believes that the responsibility for securing the cloud lies with 

both the providers and the consumers of cloud solutions. The cloud is neither inherently more nor less secure than other IT services and solutions. Generalized concerns over cloud security on the one hand, and arguments that the security risks 

in the cloud are overblown on the other hand, have muddied the waters to the point 

that policymakers and practitioners are experiencing security schizophrenia. Should 

I overlook legitimate security concerns and plunge head-first into the cloud, or 

should fear and uncertainty of these risks stop me from doing anything that even 

remotely resembles cloud computing? Like most responsible decisions, the answer 

lies somewhere in the middle of these two extremes. 

Cyber criminals, state and non-state actors, and other cyber adversaries move 

rapidly and adeptly to exploit weaknesses and vulnerabilities in systems, networks, 

applications, and practices. They are successful at taking control of machines and 

stealing data. But done right, the movement to the cloud is an opportunity for organizations to enhance operational security. 

As such, potential consumers of cloud solutions must be mindful of the wide range 

of providers and the security risk management controls they have implemented for 

the solutions they host or provide in the cloud. A key for cloud customers will be 

to evaluate both the sensitivities of the services and data they hope to deploy to the 

cloud, and a long-term viability, references, and the depth of their solutions. 

Cloud customers must insist on built-in security and transparency from the providers they select. They need to create compliance plans and closely scrutinize their 

contracts, Service Level Agreements (SLAs), and the security and disaster recovery 

plans of their providers to ensure they are making sound choices on who to partner 

with in moving services to the cloud. A key consideration here is to trust, but verify. 

CA Technologies recommends that cloud customers meet their responsibility to 

audit and monitor their providers, including the use of inspection programs, testing 

and monitoring compliance with SLAs, and assessing the security of critical systems. 

IDENTITY AND ACCESS MANAGEMENT AS A FOUNDATION OF CLOUD SECURITY

While there are certainly myriad operational issues to consider when architecting 

cloud solutions to deliver strong and robust security, CA Technologies believes that 

identity and access management (IAM) issues deserve particular attention. Our surveys of cloud providers and the views from leading industry analysts and organizations find that identity and access management is the most important issue that 

companies considering moving to the cloud face today. A strong trusted identity system that enables the right people to have the right access to the right information 

is critical to the protection and enablement of the cloud. 

Cloud service providers and customers generally feel comfortable that they have 

highly qualified IT personnel and tools which can prevent or curtail viruses from 

infecting their services, and that they can effectively secure data flowing in and out 

of cloud services. They are less comfortable with the process of identifying and au-
49 

thenticating the users, systems, and devices that need access to their services and 

managing access to specific information or data when using cloud services. 

One of the greatest challenges facing the IT sector today is fostering on-line trust, 

including the important trust components of security and privacy. The fact is that 

most on-line threats and successful data breaches of late have been based on and 

exploit access control and identity management failures in systems. The Government Accountability Office has written to Congress about unauthorized access 

issues as recently as Monday of this week (October 3, 2011). Identity management 

and access management controls are central to the secure adoption of cloud services. 

Identity and access management practices within the cloud provide the foundation 

for effective security by ensuring that all users have only the appropriate level of 

access rights to protected resources, and that those rights are effectively enforced. 

IT organizations generally as well as cloud service providers, both public and private, struggle to keep up with the explosion in the number of users from multiple 

systems, applications, and user communities that are consuming their services and 

the complexity of managing access rights for these users. 

With the transition to cloud solutions, employees and applications will continue 

to move outside the walls of the customer enterprise. This introduces new risks for 

unauthorized access and the loss of information. Cloud applications are new services 

that users must have access to, and managing that access without creating new 

vulnerabilities or new silos of identity are incredibly daunting challenges. Managing 

the on-boarding and off-boarding of users to cloud services and integrating those access rights with the overall IAM strategy for on-premise solutions requires that 

cloud providers and customers answer the following questions: • Who has and needs access to what? • What can they do with that access? • What can they do with the information they obtain? • What did they do with that information? 

These questions reinforce that managing access and authorization is but one part 

of the challenge. To be successful, identity security strategies must also focus on the 

specific data being accessed and what individual users can do with it. CA Technologies refers to this process and approach as content-aware identity and access 

management. 

Cloud computing creates opportunities for Government agencies and commercial 

organizations alike to make certain that new silos of identity don’t emerge that increase vulnerabilities and complexities for users. For Government programs and 

systems, we recommend that Federal agencies enhance their IAM capabilities to 

provide for risk-based authentication, the use of multi-factor authentication solutions, and leverage the investments they have already made in Personal Identity 

Verification (PIV) cards. 

An example of how many of these integrated identity controls are used today can 

be found in the financial services sector. CA Technologies counts the majority of the 

world’s major financial services organizations as customers, and we have worked 

closely with these organizations to implement strong and flexible IAM solutions that 

provide their customers with ease of use in the most secure fashion possible. Financial services firms have taken a security-first approach because of the economic 

risks of the transactions they conduct. Enhancing the security of those transactions 

helps meet regulatory requirements, but first and foremost focuses on providing Defense in Depth in ways that enhance security and provide ease of use for consumers 

that include IAM solutions as a core component. Financial institutions are doing a 

great job of analyzing not only the risk of individuals and their access rights, but 

also the unique risks of individual transactions. This is a trend that we believe the 

overall cloud security market must and will embrace. 

Most of us are already comfortable with the concept of signing onto the website 

of our bank to access our account information. This usually requires that users provide an account number, username, and password. If you want to move money 

around from one bank account to another at the same financial institution, the bank 

may require you to provide a secondary identifier, like a PIN, because that transaction involves more risk. If you want to use your bank’s bill pay service and authorize the movement of money from your bank to your credit card company or your 

local utility, the transaction becomes more complicated and introduces additional 

risk to both parties involved. 

In many cases, when you initiate a transaction like this from your bank, the experience to the user will be seamless. But behind the scenes a complex transaction 

whereby the user is redirected to a bill pay website and has their identity credentials passed to the bill pay provider without needing to sign on or provide their credentials again has taken place securely and transparently. The identity authentication taking place in this scenario is being accomplished via a cloud service. This 
50 

type of transaction is an illustration of how user experience and sound security can 

be implemented across the very diverse technology environments present today. We 

believe that this represents the direction future secure transactions across public, 

private, and hybrid cloud environments will progress. 

THE ROLE AND NEED FOR STANDARDS IN FOSTERING CLOUD SECURITY

I believe this example also highlights the importance of standards development 

and the valuable contributions of industry-led, recognized standards development 

organizations (SDOs) and consortia. The adoption of standards and their integration 

into the innovative security solutions offered by the vendor community make possible predictable, interoperable, secure implementations in enterprise and cloudbased services. Such standards are vital to the management of cloud security risks. 

As I noted earlier, existing security technologies implemented in the enterprise are 

the building blocks of cloud security. And to a huge extent those technologies, and 

the practices and controls which they support, are standards-based. 

Such building block standards are now foundational for cloud computing environments, and where gaps exist, new standards are under development. CA Technologies and other major IT companies contribute actively to these efforts. For example, the Organization for the Advancement of Structured Information Standards 

(OASIS) has developed important security standards such as Extensible Access Control Markup Language (XACML), Security Assertion Markup Language (SAML), 

and web services security standards such as WS–Trust. OASIS also has technical 

committees in place addressing new security challenges applicable to the cloud, such 

as cloud identity, identity trust elevation, privacy management, and reputation 

management. Its committees are also working to create profiles which are used to 

apply existing standards suchas XACML directly in support of cloud computing requirements. 

Other standards bodies, including the Internet Engineering Task Force (IETF) 

and the World Wide Web Consortium (W3C), de jure bodies such as the International Organization for Standardization/International Electrotechnical Commission Joint Technical Committee 1 (ISO/IEC JTC 1), key industry consortia such as 

the Open Identity Exchange and the Kantara Initiative and other standards organizations are all key contributors to enabling trust in the cloud. In combination with 

best practices organizations such as the Cloud Security Alliance, the resources contributed by industry, academia, governments, and independent technical experts together represents a huge and on-going investment to support security risk management in the cloud environment. I would like to note the important role that the National Institute for Standards and Technology (NIST) plays by its active participation in industry standards development and as a convener of industry efforts and 

focus. NIST recently issued a Special Publication 500–291, the Cloud Computing 

Standards Roadmap, which examines the applicability of standards for the cloud 

and areas where gaps need to be filled. 

The NIST publication looks well beyond security alone, and SDOs and consortia 

have certainly recognized the importance of standards-based cloud interoperability 

at the data level, and through the development of relevant application, operational 

management, license management, audit, virtualization, and other standards that 

are needed to enable interoperability of applications and services across clouds. CA 

Technologies is a major participant and leader at many levels of the cloud standardization process. And we believe that all of these categories of standardization, and 

more, are relevant to the development of interoperable clouds and cloud computing 

trust. 

There are several specific efforts I want to highlight as examples of emerging 

standards in the cloud security arena. The first and perhaps most important in the 

Federal space is the Federal Risk and Authorization Management Program 

(FedRAMP). While still in its draft form, FedRAMP will provide Federal agencies 

with a baseline, common approach for assessing and authorizing cloud services for 

use in Federal agencies. This will provide Federal agencies with a common set of 

controls against which to evaluate cloud services, and will give cloud providers certainty of Federal specifications that must be built into their products. FedRAMP is 

built on the premise that solutions should be certified once and used many times 

across Federal agencies. Federal agencies, however, have shown a tendency historically to ignore previous certifications and re-certify technologies for use in their own 

departments based on special requirements. Reciprocity of authorizations will be a 

critical gauge of the success of FedRAMP. 

FedRAMP will also require the transmittal of more frequent operational security 

information by providers to the Government, a process that is most-often termed 

‘‘continuous monitoring.’’ Continuous monitoring offers the potential to dramatically 
51 

improve the situational security posture of Federal information systems that rely on 

the cloud if implemented correctly. 

While we await the final draft of the FedRAMP specifications, several questions 

about its scope and implementation remain, however. Will agencies be required to 

honor authorizations made by other agencies and avoid re-evaluating solutions that 

are implemented similarly at another agency? How often and how will the security 

data envisioned under continuous monitoring be transmitted? How will the Government evaluate this data once received? The answers to these and other questions 

will be critical to ensuring FedRAMP is both implemented correctly and receives the 

buy-in needed from Government and the private sector to ensure its success. 

A second area I feel is important is the need to develop common service measurement frameworks to help enable data-driven decisions on the relative effectiveness 

of cloud solutions based on variables like cost, availability, security, and scalability. 

Right now, there is no standard mechanism to evaluate common services from different providers against one other. The Cloud Service Measurement Initiative Consortium (CSMIC), under the direction of Carnegie Mellon University and with participation from government agencies like the State of Colorado Office of the CIO, 

and corporations like CA Technologies and Accenture, has begun developing a service measurement index (SMI), which can be used to measure and compare a business service using a common language and evaluation process. A high-level representation of the characteristics and questions the CSMIC seeks to address is included as an attachment to my testimony today. In conjunction with standard recognition of cloud services authorized under the FedRAMP program, the use of a 

framework like SMI in Government procurements will enhance the analysis of competing cloud services and lead to greater standardization of solutions. As such, CA 

Technologies encourages the U.S. Government to investigate using the SMI to encourage data-driven decision-making on cloud acquisitions. 

Third, in the area of identity and access management, the National Strategy for 

Trusted Identities in Cyberspace (NSTIC) is a critical initiative that will make it 

easier for citizens and consumers to securely and confidently navigate cyberspace 

and will enhance trust among different consumers of identity through the sharing 

and reciprocation of identity credentials. NSTIC is aimed at enhancing on-line trust 

by strengthening industry-based identity management practices and minimizing the 

constant proliferation of username and password combinations that individuals 

must remember to conduct business on-line. The standards and governance rules 

that will be developed under NSTIC are a critical component of implementing robust IAM solutions that can enhance trust of and the use of cloud computing services. As the NSTIC program gets up and running at the Department of Commerce, 

CA Technologies recommends that Congress fully fund this important effort and 

that Federal agencies become active participants in both the development of the 

NSTIC standards, and ultimately, accept private sector-issued credentials as a 

means of authentication for citizens who wish to interact with Government agencies 

securely. 

Standards development, then, is an on-going and vital area of industry and Governmental focus. It is international in scope, and the standards are integral to key 

Government initiatives such as FedRAMP and NSTIC. It is important that the subcommittee recognize that it is only through support for industry-led, internationally 

supported standards will we have measurable, interoperable security risk management technologies, innovative technical solutions and practices that can ensure trust 

in cloud-based services, not only in the United States, but globally. 

RECOMMENDATIONS FOR CONGRESS

I was asked to address some of the security risks and opportunities associated 

with the transition to cloud computing. I hope that my testimony has highlighted 

that while there certainly are risks, the opportunities are extremely positive if a 

number of actions are carried out to ensure that the adoption of cloud technologies 

does not create new silos in IT security and new, unintended risks. We are in the 

nascent stage of cloud adoption. To ensure the promises of cloud computing can be 

delivered in concert with effective security risk management, we recommend that 

Congress: 

• Adopt policies that can accommodate future development and flexibility in the 

cloud market, specifically, and in IT more generally. Too often, Federal policy 

has imposed static frameworks that must constantly be updated based on new 

technology developments. We recommend that Congress focus on outcomes and 

not on specific technologies; 

• Avoid policies that create a fragmented, country-specific market for cloud services in the United States. As the cloud market continues to evolve, we see great 
52 

risk for market segmentation based on unique policies designed solely to address U.S. or other countries’ market demands. For U.S.-based businesses seeking to compete in markets all over the world, globally harmonized policies will 

enable industry to build solutions that can be delivered in multiple markets, enhances our competitiveness, and makes it easier to deliver innovative solutions 

around the world. Policies that acknowledge the global nature of cloud markets 

will enable the United States to maintain its leadership position in cloud computing and encourage innovation to support jobs and exports of U.S.-developed 

technologies; 

• Support standards developed by recognized standards development organizations in the areas of cloud security, interoperability, and transparency. These 

standards are vital to the management of cloud security risks and should be 

embraced by Congressional and Executive Branch policy makers; 

• Fund and support the continued development and rollout of FedRAMP and the 

NSTIC. To enhance operational cybersecurity at the Federal level, we recommend that Congress ensure that critical funding to develop and implement 

these programs be preserved, even in difficult Federal budget environments. We 

further recommend that Congress keep a watchful eye on FedRAMP implementation to ensure that the efficiencies hoped for are achieved; 

• Continue support for NIST and its unique role as both an internationally-respected body of security experts developing standards and practices for the Federal Government as well as for its important function as a contributor to industry-led standards development and as a convener for addressing emerging security issues; and 

• Encourage the Federal Government to leverage emerging efforts to develop 

service measurement indexes in Government cloud procurements. The CSMIC 

effort I described in my testimony can provide Federal agencies facing budget, 

performance, and transparency demands with tools that take data-driven approaches to evaluating competing offers of cloud technologies. I believe that 

frameworks like these can facilitate more robust decision-making about which 

specific cloud services and providers are right for Federal agencies. 

Mr. Chairman, Ranking Member Clarke, and Members of the subcommittee, this 

concludes my written statement. I appreciate the opportunity to appear before you 

to share some of our thoughts on cloud security. CA Technologies shares the subcommittee’s goal of increasing awareness of the cloud and the particular goal of enhancing cybersecurity, and we would be happy to work with you towards this goal 

however we can. 

I would be happy to answer any questions you may have for me. 

Thank you. 

Mr. LUNGREN. Thank you very much. 

Now, Mr. Bottum, you are recognized for 5 minutes. 

STATEMENT OF JAMES R. BOTTUM, VICE PROVOST FOR COMPUTING AND INFORMATION TECHNOLOGY AND CHIEF INFORMATION OFFICER, CLEMSON UNIVERSITY 

Mr. BOTTUM. Mr. Chairman, I would like to thank you and the 

Members of the subcommittee for the opportunity to present this 

testimony. Located in Clemson, South Carolina, Clemson University is a Nationally-ranked public land grant research university 

with an enrollment of 19,500 students. 

Mr. Chairman, many definitions explain what the cloud represents. A good working definition should reflect the distinctive 

characteristic of cloud computing, namely on-demand delivery of 

shared services over the internet. 

By allowing users to share resources, cloud computing enables 

infrastructure to be right-sized, balancing user requirements with 

the information technology services actually rendered. Cloud computing is both efficient and economical. However, we must ensure 

that our security tools, practices, and policies grow in proportion to 

our use of this evolving technology. 
53 

Clemson has, in some sense, been in the cloud business for over 

30 years, provisioning Medicaid applications and services to the 

State and citizens of South Carolina. Three years ago, as the recession intensified, we created a South Carolina Cloud experiment to 

see if several institutions could do things we could not do by ourselves, and/or do them in a more economical fashion. 

Today our cloud is operational and involves a collaboration of 

educational institutions and commercial organizations. Partner institutions include both public and private universities, technical 

colleges, and historically black colleges and universities. Many of 

these would not ordinarily have access to the resources as a standalone institution. 

Our team is working with a Fortune 500 company to build out 

a secure and comprehensive cloud computing environment. Considering our diverse set of users and the numerous organizations that 

connect into the environment, it is important to properly ensure 

identity and access management and address concerns over data 

theft or manipulation and vulnerabilities. 

Our goal is to apply policies, procedures, and controls that are 

seamless, transparent, and non-impeding to the end-user. It is my 

view that the benefits of cloud computing far outweigh the risks. 

A thoughtful strategy for prudently broadening adoption of cloud 

services can facilitate a smooth transition to this dynamic platform. 

The transition should be complemented with a thoughtful and comprehensive information security initiative to ensure the protection 

of our data and resources as our environments have evolved. 

To increase security within the cloud, R&D is needed in a number of areas. Six important areas are highlighted here. 

The first area involves the use of virtual machines. Cloud computing is enabled by virtualization. Further research is needed to 

better understand virtual machine operation and establish safeguards to effectively protect this evolving environment. 

Second is authentication, authorization, and accounting. Current 

security approaches leverage current best practices. Research is 

needed to counter the many threats, including eavesdropping and 

tampering, distributed denial of services, network infrastructure 

vulnerabilities, and insider threats. 

Third, R&D on security applications and tools should focus on 

the creation of applications that leverage the distributed nature of 

the cloud to provide a new level of security. This research would 

result in a more secure environment that is resistant to both infections of individual hosts and the current generation of networkbased attacks. 

Another area is encryption for programs and data processing. Recent work has produced an encryption system allowing computers 

to execute encrypted programs. 

Research on distributed denial of service detection and control is 

also needed. A DDOS attack is an attempt to make a computer resource unavailable to its intended users. Currently there is not a 

good mechanism for DDOS detection and control. 

Finally, research on network technologies is also important. Current protocols and tools in place today make it difficult to make 

networks available dynamically to match the elasticity in clouds. 
54 

1 Clemson University. <www.clemson.edu> 

Adaptive and intelligent networking research is an important area 

of study. 

It is also critical that we have a security-conscious workforce. 

There is a gap that exists between what universities teach and 

what industry needs. Universities teach theory and fundamentals, 

whereas industries desire practical experience. 

In addition, Mr. Chairman, I believe attention should be given to 

legal issues surrounding cloud computing—contractual and servicelevel agreement issues regarding physical data protection, incident 

response, confidentiality, privacy and security controls, and other 

matters, which are important aspects in developing a relationship 

with a provider. 

Mr. Chairman, on behalf of Clemson University, I would again 

like to thank you for your time. 

[The statement of Mr. Bottum follows:] 

PREPARED STATEMENT OF JAMES R. BOTTUM

OCTOBER 6, 2011 

Mr. Chairman, I would like to thank you and the Members of the subcommittee 

for this opportunity to present testimony before this committee. I would like to 

begin by taking a moment to briefly acquaint you with Clemson University. 

Located in Clemson, South Carolina, Clemson University 1 is a Nationally-ranked, 

science and technology-oriented land grant public research university founded in 

1889, known for its emphasis on collaboration, focus, and a culture that encourages 

faculty and students to embrace bold ideas. Clemson’s teaching, research, and outreach are driving economic development and improving quality of life in South Carolina and beyond. With an enrollment of 19,500, Clemson is a high-energy, studentcentered community dedicated to intellectual leadership, innovation, service, and a 

determination to excel. 

Regarding my own background, I have been the vice provost and chief information 

officer at Clemson University since July 2006. During my tenure, Clemson has 

transformed its network, storage, and computational infrastructure, including the 

data center, into a state-of-the-art set of services benefitting research, education, 

and public service. We have been recognized for transformative work in publications 

such as Network World, Computer World, and Storage Magazine. Before coming to 

Clemson, I was the first chief information officer at Purdue University beginning 

in 2001 where I forged a new model for partnering with research (recognized in a 

publication by the EDUCAUSE Center for Applied Research, July 2005). Prior to 

that, I was the executive director at the National Science Foundation’s National 

Center for Supercomputing Applications at the University of Illinois at UrbanaChampaign. I currently or previously have served on a number of National committees including the National Science Foundation’s Advisory Committee on 

Cyberinfrastructure and the Internet2 Board of Trustees. 

CLOUD DEFINITION

Mr. Chairman, many definitions exist to explain what ‘‘the cloud’’ actually represents. For purposes of my comments today, a good working definition should reflect what I believe to be the distinctive characteristic that defines cloud computing, 

namely the elastic, on-demand virtual delivery over the internet of shared services, 

including infrastructure and software. By allowing users to share access to software 

applications, computational power, networks, and data storage, cloud computing enables computing infrastructure to be right-sized while balancing user requirements 

with the information technology services actually rendered. Recognizing this shared 

component is fundamental to understanding the dynamic effects that are derived 

from the cloud. 

Also inherent in the cloud model is its flexibility. Multiple implementation regimes—private, community, public, and hybrid—permit organizations to select deployment schemes that best meet their needs and missions. Clouds are not one-sizefits-all. As defined in the draft National Institute of Standards and Technology Defi-
55 

2Mell, Peter and Timothy Grance. National Institute of Standards and Technology. ‘‘The NIST 

Definition of Cloud Computing (Draft).’’ National Institute of Standards and Technology Special 

Publication 800–145. January 2011. <http://csrc.nist.gov/publications/drafts/800-145/Draft-SP800-145lcloud-definition.pdf> 3South Carolina Cloud. <http://www.clemson.edu/ccit/rschlcomputing/CUCI/sclcloud.html> 

nition of Cloud Computing.2 Private clouds are environments where ‘‘the cloud infrastructure is operated solely for an organization.’’ Private clouds host and on-demand 

deliver resources, under the control of the organization, generally within a firewall. 

Community clouds are where ‘‘the cloud infrastructure is shared by several organizations and supports a specific community that has shared concerns (e.g., mission, 

security, requirements, policy, and compliance considerations).’’ This shared infrastructure enables the community to share in the cost, yet also offers a common set 

of security and privacy policies and procedures. In Public clouds ‘‘the cloud infrastructure is made available to the general public or a large industry group and is 

owned by an organization selling cloud services.’’ Public clouds may be free or payper-use and provide resources that are dynamically provisioned on a self-service 

basis. Hybrid clouds are environments where ‘‘The cloud infrastructure is a composition of two or more clouds (private, community, or public) that remain unique entities but are bound together by standardized or proprietary technology that enables 

data and application portability.’’ 

CLOUD EVOLUTION

Cloud computing may be characterized as evolutionary over time. Cloud computing should not be viewed as revolutionary, since some of the earliest concepts 

regarding computer time-sharing and utility computing came out as early as the 

1960s, but did not take hold in our society until decades later. Past models of computing focused on utilizing supercomputers, mainframes, and storage devices primarily owned and operated by a single organization. As the internet and broadband 

capabilities expanded, opportunities arose to connect, share, and leverage these resources by multiple organizations with a common purpose. Referred to as grids, or 

grid computing, this model provided multiple users and various sites access to a 

shared heterogeneous computational infrastructure utilized to solve computational 

problems. During the 2000s, the cloud concept further evolved as major companies 

such as IBM, Google, and Amazon as well as numerous universities and research 

organizations began to develop and grow environments. 

SOUTH CAROLINA CLOUD EXAMPLE

At Clemson University, our own cloud initiative has coalesced around what we 

refer to as the South Carolina Cloud 3 or ‘‘SC Cloud.’’ SC Cloud represents a collaboration of educational institutions, IT professionals, commercial entities, and others 

who drive cutting-edge research in the areas of computing and communication infrastructure, data storage and visualization, virtual collaboration, and education workforce training. In pursuing their research, participants access a cluster of ∼61,700 

PCs as well as other High Performance Computing resources and networks to virtually explore new concepts in a host of critical computing research fields, including: 

Data modeling, the hyper-growth in connected devices, surge in real-time data 

streams, on-line and mobile commerce, business use of service-oriented architecture, 

virtualization, and Web 2.0 applications. 

The SC Cloud initially began as a consolidation effort of Clemson’s on-campus distributed computing resources to improve computing efficiencies and advance capabilities in research and education. One of the unanticipated results of this effort was 

the partnerships that developed with other South Carolina universities. SC Cloud 

partners share a common set of computing and IT services, including networking, 

high performance computing, server administration, data storage, instructional and 

classroom technology support, monitoring, and security and privacy. Likewise, higher education also share a common set of issues and challenges related to these services, including the economics of supporting and maintaining a growing set of services during economically challenging times, ensuring an adequate workforce, and 

continually modifying the service offerings to meet ever-changing demands and expectations. Across South Carolina the value of working together in a shared resource environment was quickly recognized as an evolving ‘‘work-in-progress’’ model 

that enables institutions to more efficiently and effectively address computing and 

information technology collectively. 
56 

4Microsoft Corporation—Case Studies. 2009. <http://www.microsoft.com/casestudies/ 

CaselStudylDetail.aspx?CaseStudyID=4000005460> 5Kundra, Vivek, Federal Chief Information Officer. State of Public Sector Cloud Computing. 

2009. <http://www.info.apps.gov/sites/default/files/StateOfCloudComputingReportFINALv3l508.pdf> 

* [sic] 

6 IBM Corporation—Success Stories. 2011. <http://www-01.ibm.com/software/success/cssdb.nsf/ 

CS/LWIS-8KZPUW?OpenDocument&Site=corp&cty=enlus> 7 Verdantix Research. ‘‘Verdantix Cloud Computing Report For Carbon Disclosure Project 

Forecasts $12.3 Billion Financial Savings For US Firms.’’ 2011. <http://www.verdantix.com/ 

index.cfm/papers/Press.Details/presslid/58/verdantix-cloudcomputing-report-for-carbon-disclosure-project-forecasts-12-3-billion-financial-savings-for-usfirms/-> 8 Accenture Corporation. ‘‘Microsoft, Accenture and WSP Environment & Energy Study Shows 

Significant Energy and Carbon Emissions Reduction Potential from Cloud Computing.’’ 2010 

<http://newsroom.accenture.com/articleldisplay.cfm?articlelid=5089>. 

CLOUD BENEFITS

Our SC Cloud experience resonates and echoes many of the benefits found in 

cloud computing across the Nation, regardless of the cloud deployment model. Costs 

are reduced by sharing the overhead capacity required for peak loads. Large numbers of standardized hardware enables next-day parts replacement contacts in lieu 

of expensive rapid response time, on-site maintenance contracts. Advantageous 

hardware and software pricing is negotiated. Economies of scale allow investment 

in redundant cooling, backup power, and other facility infrastructure. Virtualization 

and infrastructure management solutions make it possible to rapidly deploy or remove resources incrementally based on demand. Researchers focus on research instead of administering systems. Reliability is improved by locating away from highrisk areas. Energy use is reduced by eliminating the need for powering and cooling 

unused capacity, and energy costs are reduced by locating where power is cheaper. 

There are numerous examples of both public and private entities that have realized sizable benefits from the adoption of cloud computing initiatives. 

GlaxoSmithKline, a leading pharmaceuticals company, recently deployed a Microsoft 

cloud solution through a Deskless Worker Suite to 15,000 of its employees, reducing 

IT operational costs by 30 percent while enhancing productivity and expanding external collaboration.4 The U.S. Air Force saved an estimated $4 million annually on 

its Personnel Services Delivery Transformation (PSDT) system by implementing a 

cloud solution from RightNow and customers can now find answers from over 15,000 

documents within 2 minutes, a drastic improvement from previous wait times of 20 

minutes.5 The Department of Energy estimates it will save $1.5 million over the 

next 5 years in hardware, software, and other labor costs from implementing a cloud 

solution at the Lawrence Berkeley National Lab for its e-mail accounts and from 

utilizing Google Sites and Google Docs for its scientific research teams.* 

Another benefit of cloud computing adoption is a company’s ability to better manage its power resources for its IT infrastructure. By deploying an IBM cloud-based 

endpoint management solution, Fiberlink—an innovator in voice, data, and IP networking solutions—achieved a 25% annual growth rate over the last 5 years and 

has saved an estimated $500,000 a year from improved power management alone.6

A study concluded this year by Verdantix and sponsored by AT&T estimates that 

cloud computing could enable companies to save $12.3 billion off their energy bills 

and results in a carbon emissions savings of 85.7 million metric tons by 2020.7 Another study from Microsoft and Accenture revealed that moving business applications to the cloud could cut per-user carbon footprints by 30 percent for large, already efficient companies and as much as 90 percent for the smaller and less efficient businesses.8 Cloud computing is not only beneficial to the companies themselves that use the technology, but its benefits can extend to the environment at 

large because of its decreased dependency on independent hardware sites distributed across a company. 

Our experience with SC Cloud has been that it is a collaborative mechanism for 

research, as well as the high-quality, innovative R&D it is delivering to advance our 

understanding about virtual environments in ways that are beneficial to both the 

public and private sectors. It is this type of environment that is instructive for framing some of the key considerations in cloud migration. I would like to share some 

of that experience with the committee today, particularly in the areas of security, 

scalability, and identity management. 

SECURITY—CLEMSON UNIVERSITY EXAMPLE

Concerns over data theft or manipulation and vulnerabilities to critical applications are real when contemplating the network security architecture of the cloud 
57 

9 Cloud Security Alliance. ‘‘Top Threats to Cloud Computing V1.0.’’ March 2010. <https:// 

cloudsecurityalliance.org/topthreats/csathreats.v1.0.pdf> 10 United States Department of Education—Historically Black Colleges and Universities 

<http://www2.ed.gov/about/inits/list/whhbcu/edlite-index.html> 11 Health Sciences South Carolina. <http://www.healthsciencessc.org> 

platform. Clemson’s Information Security and Privacy organization mission is to 

protect the confidentiality, integrity, and availability of information and informational resources. The goal is to apply policies, procedures, and controls that are 

seamless, transparent, and non-impeding to the organization. Controls match the 

risks that exist and ensure the protection of data, provide redundancy, and include 

the ability to monitor Clemson’s environment. Security and privacy at Clemson are 

a shared responsibility, meaning efforts have been made to educate and raise awareness among faculty, staff, students, alumni, etc. so that security and privacy become 

a natural part of the culture. 

The security challenges that Clemson faces are typical of other higher education 

institutions and similar to those mentioned in Cloud Security Alliance’s Top Threats 

to Cloud Computing’’.9 CSA is a ‘‘member-driven organization chartered with promoting the use of best practices for providing security assurance within cloud computing.’’ CSA’s research shows that the top security threats include such areas as 

insecure interfaces, malicious insiders, shared technology issues, account or service 

hijacking, and unknown risk profiles. We have implemented a series of policies, best 

practices, and controls that provide for increased protection, but know that nothing 

is 100% ‘‘bullet-proof.’’ Staying ahead of the curve of threats and vulnerabilities is 

a continual challenge, which Clemson addresses through a variety of best practices 

that should be part of any organization’s security strategy. 

First among these best practices are human resource procedures. A criminal background and E-verify check is conducted on all university personnel prior to their 

hire and employees are bound by confidentiality in their work. In addition, establishing a series of policies and procedures provides a foundation by which Clemson’s 

security strategy has been developed and lays the framework under which security 

operations function. Included topics among the policies are Acceptable Use, Userid 

and Password, Network Security, Server Administration, and Data Center access. 

Regarding security clearances, employees needing access either physically or virtually, must be requested and authorized by supervising personnel based on the employee’s job function requirement. Restricted or secure areas are protected by monitored and recorded video surveillance and key-card access. Additionally, the main 

data center facility has staff on-site 24/7/365. Technical controls are put in place 

based on the evaluated risk, a variety and matrix of controls would be deployed that 

might include physical or logical network segmentation, Firewall and Access Control 

List use, increased and elevated levels of monitoring, separated Virtual Private Network use, limited availability of access, and more stringent levels of credential use. 

SCALABILITY—SC CLOUD AND HEALTH SCIENCES SOUTH CAROLINA EXAMPLES

For most organizations, economics is the force multiplier driving them into cloud 

computing to realize enterprise efficiencies both in terms of IT spending and asset 

utilization. Clemson has been in the ‘‘cloud business’’ for over 30 years provisioning 

Medicaid applications services to the State and citizens of South Carolina. As previously mentioned, the SC Cloud evolved into a State-wide consortium of institutions who either could not afford to address the infrastructure needs on their own 

or did not have the expertise to deploy in-house resources. What once started as a 

Clemson private cloud need, evolved into a community cloud where the volume of 

computing and cloud services increased, but yet did not result in any service degradation at Clemson. These institutions realized the economic benefit of fully participating in the SC Cloud, especially in the context of high-performance computing, 

as it enables them access to a set of resources that are flexible, scalable, and reliable 

to meet current and future needs. Institutions participating in the SC Cloud include 

both public and private universities, including technical colleges and Historically 

Black Colleges and Universities,10 or HBCUs. 

Likewise, the SC Cloud further evolved and scaled to provide flexibility for the 

Health Sciences South Carolina referred to as HSSC.11 HSSC is composed of six of 

South Carolina’s largest health systems and the State’s largest research-intensive 

universities. This State-wide biomedical research collaborative has a vision of transforming the State’s public health and economic well-being through research as well 

as education and training of the health-care workforce. Given Clemson’s security 

strategies previously described as well as our experience being the primary provider 

of operational support to South Carolina’s Department of Health and Human Services for Medicaid transactional processing and eligibility determination, HSSC de-
58 

termined that the SC Cloud would be a natural fit not only for infrastructure, platform, and software cloud services, but also for security as a service. Clemson essentially serves as the Information Security Office for HSSC by providing the same 

suite of services afforded to Clemson, but also applying the same confidentiality, integrity, and availability philosophies, strategies, controls, policies, and procedures 

within a HSSC context. This environment shares much of the infrastructure utilized 

by Clemson, yet is segmented in such a way so as to provide a hybrid cloud that 

addresses both Clemson’s and HSSC’s needs. 

Building upon the previously-mentioned security best practices, Clemson’s experiences with scalability has demonstrated four additional areas of consideration when 

forging a cloud computing security strategy. First among these is ensuring a trust 

relationship is established between client and provider. Current cloud models are 

widely used because they provide economies of scale. They also, however, outsource 

data and resource management to third parties. Clients must rely on the ability of 

the provider to assure privacy, accuracy, and availability of information. Developing 

a trust relationship, as in the case of HSSC with Clemson, is an important consideration in ensuring the safety of data. Clemson’s experience with Medicaid data as 

well as the policies, procedures, and controls that are put in place enable an increased level of trust. Continual interaction and engagement has resulted in 

Clemson being at the table when HSSC is in the early stages of application development and the subsequent change management. This has resulted in security and 

privacy being an integrated, proactive part of HSSC’s planning and operations. 

Clemson University’s relationship with HSSC members has been strengthened 

with their deployment of previous investments in authentication research and development. Clemson University is a participating member of Internet2’s InCommon 

federated identity management supporting Shibboleth authentication. HSSC systems has utilized Shibboleth authentication to allow for multiple trusted participating members to leverage their own identity management vetting process and procedures for access to HSSC systems. This is a great example of how R&D has produced a viable, productive application and methodology to achieve greater efficiencies and ease of use without compromising the security of the system. 

Second, the level of cloud integration should be considered. Depending upon an 

organization’s mission and requirements, an organization may only take advantage 

of cloud infrastructure services. Some may pursue software as a service. Yet others 

may outsource the entire suite of cloud services, including security as a service. In 

the case of HSSC, the SC Cloud provides infrastructure, platform, and security. In 

other words, one size does not fit all and a cloud provider should be flexible. 

Third, natural disasters such as Hurricane Katrina, the recent earthquake in 

Japan, and the Midwest floods show the importance of disaster recovery and business continuity. Documenting a plan and implementing redundancy technologies are 

obvious components of this planning. Conducting test failovers and actual physical 

disaster drills on a periodic basis should also be included in any DR/BC strategy. 

Many lessons are learned when physically conducting a disaster exercise that enable 

an organization to be better prepared. 

Fourth, one of the reasons HSSC chose Clemson is because of its Medicaid provisioning experience with medical data, compliance, and audit response. Clemson has 

a proven track record of being able to address internal and external audit requests 

and quickly address any findings. A cloud service provider should be able to address 

their experience and capabilities in dealing with Federal compliance and audit 

needs. 

IDENTITY AND ACCESS MANAGEMENT

Considering the diverse set of users that the SC Cloud has and the numerous organizations that connect into the environment, it is important to properly ensure 

identity and access management (IaAM). Identity and access management concerns 

the need to permit access to enterprise resources only to authenticated users, with 

access to only the data they have permission to view or change. Without appropriate 

procedures in place to verify access, concerns over identity theft and the insider 

threat can arise. 

Authentication is performed when a computing session starts. In existing systems, 

a user is authenticated in one of three ways: Knowledge, which is something the 

user knows such as a password; possession, which is something the user has such 

as a smart card; or identity, which refers to biometrical aspects, such as a fingerprint. 

Clemson’s experience has been that identity and access each can be problematic. 

Passwords can be forgotten, sent over the network in clear-text, so that they are 

readable in transit or revealed inadvertently. Simple passwords are easy to guess. 
59 

12Global Environment for Network Innovations (GENI). <http://www.geni.net> 

Complex passwords are easily forgotten, or need to be written down. Taking IaAM 

issues a step further, smart cards, dongles, or other authentication tokens can be 

stolen. Voiceprints may have false negatives if the user has a cold. People are hesitant to use retina scans, since they seem invasive. Biometrics can also be spoofed. 

Clemson limits these challenges by requiring complex passwords, providing training 

to faculty, staff, and students, and using a single-sign-on service that forces password encryption in transit over the network. 

On a local machine, authentication is straightforward. If authentication uses 

knowledge, for example a password, the user is prompted directly for the information. If possession is used, the token (ex. smart card) can be interfaced directly to 

the computer. Some authentication systems give the user a device that displays a 

code value to enter into the system. For biometrics, a physical device has to interact 

with both the user and the computer system. Two-factor authentication uses more 

than one authentication technique. This helps minimize the damage caused by keyloggers and related tools. 

All these approaches assume the device used to access the internet is trustworthy. 

If the local hardware or software is not trustworthy (for example compromised by 

malicious software) this will compromise both knowledge and biometric authentication. 

Access control is at least as challenging as authentication. When all data and 

users were locally created and managed, it was relatively easy to provide controlled 

access. However, in the cloud, it is more difficult to provide controlled access. It is 

possible for there to be different levels of security for systems and different levels 

of assurances for users. The basic infrastructure security level within a public cloud 

should match the level of the highest security need, not be a mixed bag of approaches. Understanding the access control security practices as well as the results 

of the provider’s risk assessment efforts are essential considerations. As discussed 

later in my testimony, further study is needed in the area of identity and access 

management technologies and policy. 

CONSIDERATIONS

Mr. Chairman, the power of cloud computing offers tremendous advantages to 

both the commercial and public sectors. For our Government agencies in particular, 

cloud migration represents an achievable strategy for deriving the tangible cost savings that the current economic and fiscal environment demand. Furthermore, it enables both the smart, streamlined organizational construct that Government employees need to better perform their mission, and the more efficient services delivery 

model that taxpayers deserve. And, while I have enumerated some of the challenges 

that exist, it is my view that the benefits of cloud far outweigh the risks, and that 

a thoughtful strategy for prudently broadening adoption of cloud services can facilitate a smooth transition to this dynamic platform. Many of the security-oriented 

policies, procedures, controls, and best practices previously mentioned are key elements of any security strategy. Additional components that such a strategy might 

consider include current areas of research and development, education and workforce priorities, and economic implications. 

AREAS OF RESEARCH AND DEVELOPMENT

Many areas of research and development exist in the cyber-security field. It is my 

opinion as well as the opinion of other researchers in the field that Cybersecurity 

R&D is best conducted in an operational environment as opposed to a simulated environment. The SC Cloud was set up in an operational environment with this principle in mind. IT staff provisioners work side-by-side with researchers from academia and industry across the spectrum. Cybersecurity is critical to all communities. An exemplary Federal program that includes this program is the NSF funded 

Global Environment for Network Innovation or GENI.12 Core premises of GENI are 

that the internet architecture is over 25 years old and in need of strengthening and 

updating. A second premise is that network R&D should be conducted on the internet itself and the GENI approach is to use ‘‘slices’’. Analogous to the use of virtual 

machines to allow isolated computing on a shared computer, emerging technologies 

now allow virtual network slices to be created on shared network infrastructure to 

allowed isolated network operation. Network virtualization not only allows cyber 

R&D occur on production internet in protected ways, it also enables isolated and 

secure enterprise operations to take place on a shared network. 

My comments will highlight some research, which in my opinion are of importance and worthy of investment. 
60 

13 R.R. Brooks, ‘‘Mobile code paradigms and security issues,’’ IEEE Internet Computing, vol. 

8, no. 3, pp. 54–59, May/June 2004. R.R. Brooks, Disruptive Security Technologies with Mobile 

Code and Peer-to-Peer Networks, CRC Press, Boca Raton, FL, 2005. 14 C. Gentry, A Fully Homomorphic Encryption Scheme, Ph.D. Dissertation, Dept. of Computer 

Science, Stanford University, 2009. T. Rabin (ed.) Advances in Cryptology—Crypto 2010. LNCS 

vol. 6223, Springer Verlag, Berlin 2010. 15 Brooks, Richard and Kuang-Ching, Wang. EAGER-GENI Experiments on Network Security 

and Traffic Analysis. National Science Foundation Award No. 1049765. <http://www.nsf.gov/ 

awardsearch/showAward.do?AwardNumber=1049765> 16Dingankar, C. (MS) ‘‘Enterprise Security Analysis Including Denial of Service Countermeasures,’’ ECE Dept. Clemson University (August 2007). C. Dingankar, S. Karandikar, C. Griffin, and R.R. Brooks, ‘‘On Bandwidth Limited Sum of Games Problems,’’ IEEE Transactions on 

Systems, Man and Cybernetics, Part A: Systems and Humans, 41(2) 341–349, March 2011. 17OpenFlow. <www.openflow.org> 

The first area of R&D involves the use of virtual machines (VMs) in clouds. Cloud 

computing is enabled by virtualization. This has enabled servers to migrate from 

one host to another dynamically for load balancing as well as made easier dynamic 

recovery from hardware failures. Security can be enforced by executing programs on 

different virtual machines. Virtual machines, however, are subject to various 

vulnerabilities. Researchers at Clemson have shown how power and timing data can 

be used to extract information, including cryptographic keys, from running systems. 

Further research is needed to establish what hardware safeguards are required to 

effectively protect virtual machine environments. 

The second area of R&D is authentication, authorization, and accounting. Current 

security approaches leverage current best practices for authentication, authorization, and accounting relying on Public Key Infrastructure (PKI) and a certificate authority (CA) hierarchy to establish a chain of trust. Traditional approaches are designed to secure monolithic computing entities, but the distributed nature of the 

cloud could be leveraged to provide additional security.13 As cloud computing 

leverages distributed resources at different sites and potentially of different ownership—for example, an enterprise might dynamically purchase computing resources 

from multiple cloud providers for resilience, load balancing, and cost optimization, 

the cloud user needs ways to identify itself in consistent, unified, secure, and portable means to all resources. 

R&D on security applications and tools is another area of research that focuses 

on the creation of applications that leverage the distributed nature of the cloud to 

provide a new level of security that neutralizes security vulnerabilities and the various classes of attacks. This research would result in a cloud environment that is 

resistant to both infections of individual hosts and the current generation of network-based attacks. 

Another R&D area is encryption for programs and data for processing. Recent 

work 14 has produced a true homomorphic encryption system that allows computers 

to execute encrypted programs. In theory this should be free of side-channels, but 

the newness of this approach means that vulnerabilities may still be found. 

Research on Distributed Denial of Service (DDoS) detection and control is also 

needed. A Distributed Denial of Service attack is an attempt to make a computer 

resource unavailable to its intended users. A DDoS attack can shut down cloud service site or constantly affect cloud performance, thus increasing the costs. Currently 

there is not a good mechanism for DDoS detection and control. It is not possible 

to detect the source of the DDoS or control the traffic. DDoS is currently an intensive area of research. For example, the National Science Foundation’s GENI project 

funds researchers at Clemson to leverage OpenFlow, a software-defined networking 

technique, to flexibly analyze network traffic for DDoS threats and control different 

categorized traffic to ameliorate detected threats.15 Some suggestions have been 

made for ways to create DDoS-resilient clouds.16

Finally, research on network technologies is also important. Current protocols and 

tools in place today make it difficult to make networks available dynamically to 

match the elasticity in clouds. Networks tend to be static and specialized with data 

passing through hundreds of thousands of separate network devices that operate individually instead of as a unified system. A paradigm shift is needed to instill more 

dynamic control plane flexibility to match the growth of diverse applications and devices utilizing cloud services, including mobile, across entire networks in a cloud environment. 

Such a paradigm shift can be seen today through the implementation and use of 

Software Defined Networking (SDN) technology such as OpenFlow,17 which has 

been developed as the network layer of the GENI model. SDN moves the control 

plane from the individual network device to external controllers that can view and 

manage a network as a system instead of a vast network of individually-configured 
61 

18 Anderson, R. and T. Moore, 2008: Information security economics—and beyond. Lecture 

Notes in Artificial Intelligence, 5076, 49. 19 Institute of Electrical and Electronics Engineers Code of Ethics <http://www.ieee.org/about/ 

corporate/governance/p7-8.html> 20 Association for Computing Machinery Code of Ethics and Professional Conduct <http:// 

www.acm.org/about/code-of-ethics> 21Katz, M.L. and C. Shapiro, 1985: Network externalities, competition, and compatibility. The 

American Economic Review, 75, 424–440. 22 Besen, S.M. and J. Farrell, 1994: Choosing how to compete: Strategies and tactics in standardization. Journal of Economic Perspectives, 8, 117–131. 23Dekel, E. and S. Scotchmer, 1999: On the evolution of attitudes towards risk in winnertake-all games. Journal of Economic Theory, 87, 125–143. 24 Akerlof, G.A., 1970: The market for ‘‘lemons’’: quality uncertainty and the market mechanism. The Quarterly Journal of Economics, 84, 488–500. 

devices. Additionally, SDN makes it easy for new network protocols to be rapidly 

prototyped into production networks. 

In addition, adaptive and intelligent networking that does not rely only on the 

end-host or individuals for correct protocol application is an important area of study. 

One cannot rely on all providers having firewalls, consistent security standards, intrusion detection, etc. Distributed tools are needed to enable automated security 

through improved network monitoring to analyze traffic patterns and detect/isolate 

vulnerabilities as well as securing internet traffic in distributed and seamless ways. 

EDUCATION/WORKFORCE PRIORITIES

Mr. Chairman, in addition to R&D, it is also critical that we have a security-conscious workforce. There is a gap that exists between what universities teach and industry needs. Universities teach theories and fundamentals whereas industries desire practical experience from university graduates. This is difficult to incorporate 

into the curriculum. Programs are needed to facilitate bridging this gap and partnerships between universities and 2-year technical and community colleges should 

be encouraged. In addition programs that encourage students to major in science, 

technology, engineering, and mathematics (STEM), including an emphasis on cybersecurity, are needed. 

NSF GENI is an example of program that is filling this gap by creating an environment linking industry with university research thus providing experiences for 

students to receive training and education on core technologies that are applicable 

in the workforce. In addition, GENI also extends these opportunities to multiple disciplines ranging from computer software, computer system, networking, to hardware 

engineering thus giving a student a broader experience of conducting research and 

having regular interaction on a large scale with other fields of study. Federal facilitation of similar programs in cross-cutting areas may begin to close this gap over 

time. 

ECONOMIC IMPLICATIONS

There is a growing body of research involving interactions between information 

security and economics.18 Current market incentives reward behaviors that do not 

safeguard the well-being of the public. This is in direct conflict with the Institute 

of Electrical and Electronics Engineers (IEEE) 19 and Association for Computing Machinery (ACM) codes of ethics.20

Hardware and software markets have network externalities: The value of an investment depends in large part on whether or not other parties make the same purchase decision.21 These markets are ‘‘tippy,’’ i.e. miniscule differences in quality or 

perception result in major differences in profitability. In our industry, network 

externalities often result in markets where one product dominates the market. This 

explains the historically dominant market positions of the IBM PC, Microsoft Windows, and Intel processor architecture.22 The need to be the dominant player induces pressure to be ‘‘first to market’’ with new applications. Arriving early usually 

tips the market enough to dominate it. In this ‘‘winner take all’’23 context, actions 

that improve product quality and security, but delayed delivery can be fatal to an 

enterprise. 

This is exacerbated by software being a ‘‘lemon market’’24 with information asymmetry between buyer and seller. The buyer cannot reliably distinguish between 

quality goods and shoddy products. Under these conditions, buyers choose the lowerpriced product. Shoddy products are produced more cheaply, driving quality products from the market. 

These factors encourage the industry to quickly produce large quantities of poorly 

analyzed programs. There is little financial incentive to do otherwise and much to 
62 

25 Rice, D., 2008: Geekonomics. Addison-Wesley, Upper Saddle River, NJ, 2nd ed. 

gain. The consequences of poor software quality for consumers and the economy as 

a whole are immense. Dr. David Rice cites NIST studies showing the annual cost 

of insecure software to the United States as conservatively $180 billion.25 He also 

cites a market research survey, which finds 75 percent of computers connected to 

the internet have been infected and used to distribute spam. Computer and network 

security is likely to remain a difficult problem for the foreseeable future. Research 

and development of secure systems will be costly, but that cost is expected to be 

much less than current losses due to on-line system misuse. 

OTHER CONSIDERATIONS

In addition, Mr. Chairman, there is one other priority that I believe will receive 

attention as cloud services grow, namely the many legal issues surrounding cloud 

computing. Contractual and service-level agreement issues regarding physical data 

protection, incident response, confidentiality, access, availability, privacy, security 

controls, and other such critical matters are important aspects in developing a relationship with a provider. Likewise, intellectual property issues and export controls, 

meaning where is the data being stored, should also be discussed in a cloud computing strategy. It is conceivable that some cloud service providers could store data 

outside the United States for backup or archival purposes. Also, consideration 

should also be given to the portability of data and what happens to the data once 

a provider contract is terminated. Safeguards and assurances are important to ensure all data packaged for migration to a new provider and that all data is cleaned 

and removed from any provider asset. Finally, considering the level of hardware 

manufacturing that occurs overseas, assurances that personal computers, tablets, 

etc. do not contain viruses or other security compromising elements is needed. 

Mr. Chairman, on behalf of Clemson University I would again like to thank you 

for the opportunity to testify before the subcommittee and I look forward to your 

questions. 

Mr. LUNGREN. Thank you much, Mr. Bottum. I was just thinking 

that cloud computing is the only thing I have not heard being argued for the breakup of the Big East or ACC, and I suspect that 

maybe we will be hearing about that—— 

Mr. DUNCAN. Will the gentleman yield? 

Mr. LUNGREN. Sure. 

Mr. DUNCAN. Go Tigers against Boston College—— 

[Laughter.] 

Mr. LUNGREN. Well, I have got a neighbor who is a freshman at 

Clemson, so I will say okay. 

Mr. Curran. 

STATEMENT OF JOHN CURRAN, CHIEF EXECUTIVE OFFICER, 

AMERICAN REGISTRY OF INTERNET NUMBERS 

Mr. CURRAN. Thank you, Chairman Lungren, Ranking Member 

Clarke, Members of the subcommittee, for having me here today. 

You have my written testimony so I will keep my verbal comment 

brief. 

I am going to focus on areas related to using the cloud over the 

public internet, because that is truly what is new in what we are 

discussing. Dr. McClure, earlier today, indicated that the use of 

public clouds poses new areas of risk, and I would like to highlight 

four of those that this committee should consider when looking at 

this issue. 

First is, the relationship of public clouds to other initiatives within the Federal Government for cybersecurity needs to be carefully 

considered, because public clouds are using vendors outside the 

Federal Government, yet the Federal Government has several Government-wide security initiatives. These include HSPD–12 for vali-
63 

dation and authorization; this includes the Trusted Internet Connections program. 

When you make use of a public cloud and a public vendor they 

may not be familiar with how to actually use those initiatives, 

which are Government-wide cybersecurity initiatives. So the documentation and the approach to vendors so that they have everything they need when they design their public cloud to make use 

of Government-wide cybersecurity initiatives is essential. Otherwise, our public clouds won’t be participating in our Governmentwide initiatives. This is very important. 

Second is the issue of the physical location of the actual data and 

systems. The FISMA framework and the FISMA security control 

profile always had an assumption within it of Federal control of the 

facilities or systems. It is true about 10 percent of our Federal inventory is outsourced to contractors, but even then, it is outsourced 

in a way that puts it directly under agency control to the vast majority of cases. 

When we make use of public clouds we suddenly have the idea 

of using a FISMA profile that is 10 years old to secure public 

clouds that may actually be worldwide in nature. The problem, of 

course, is that the questions to be asked—where is the data, where 

is the systems—simply don’t exist in the original FISMA profile. 

Now, the proposed FedRAMP security profile does have enhancements, and one of the enhancements it includes is talking about 

the personnel that are making use of managing this data. In the 

current public drafts it does not include, however, controls for 

where is the data and the systems themselves? So we know, in 

many cases, that the systems are managed by U.S. citizens, but we 

don’t know necessarily that they are located within the United 

States. 

A given agency can implement SLAs to cover that if they know 

to do so. What might be a better approach is making that inherently part of the profile, so as GSA accredits organizations they say 

where there systems are, so a Federal agency CIO has the ability 

to say: Is that acceptable to me or not? 

The third matter is on migration, and I guess this is more important. The FISMA profile is very good about talking about recovering of systems; it has a whole contingency planning section which 

handles the failure of a given server or data center. That was perfect for when we were talking about Federal agencies. 

But the recovery now that is provided by the FISMA profile now 

works within the cloud. It is whether a cloud provider provides fail 

over one of their data centers to another one of their data centers. 

The problem is, we now need contingency planning at one level 

higher up. In fact, you need to worry about the case where the 

cloud provider themselves is no longer able to provide service securely and you need to move not to another one of their data centers but to an entirely different cloud provider. You might need to 

do that on very rapid notice to accommodate a cloud provider who 

is compromised in an irrecoverable manner. 

So the migration is not a question just of cost or being able— 

agencies being able to get their own data back. It is actually a security control. It is an inherent function that needs to be provided 

so that if a cloud provider is compromised the ability to migrate 
64 

isn’t a question that we are all asking; it is inherent and it is 

known to be able to quickly move up in a short number of days or 

hours and move to another provider. 

Finally, the internet itself: The internet itself is not static. It is 

changing rapidly, and there are several security protocols, such as 

DNSSEC, to secure the Domain Name System, and I.P. version 6, 

the new internet protocol that is coming out, that need to be considered. We need to make sure these are part of the profile for 

FedRAMP so we don’t build on the internet while the internet is 

changing out from under us. 

I would like to thank the committee for having me. I look forward to your questions. 

[The statement of Mr. Curran follows:] 

PREPARED STATEMENT OF JOHN CURRAN

OCTOBER 6, 2011 

I. INTRODUCTION

Good morning Chairman Lungren, Ranking Member Clarke, Ranking Member 

Thompson, and Members of the committee, and thank you for inviting me to testify 

before the Cybersecurity, Infrastructure Protection, and Security Technologies Subcommittee. 

I am the president and chief executive officer of the American Registry for Internet Numbers, Ltd. (‘‘ARIN’’), which issues Internet Protocol (IP) number resources 

for the United States, Canada, and Caribbean, but I am speaking here today in my 

personal capacity based on a long history of building and securing FISMA-compliant 

Federal Information Technology (IT) systems. 

I have first-hand knowledge of these matters from my experience in the internet 

industry since 1990, including serving as the chief technology officer for several Government contractors and Internet Service Providers (ISPs) including BBN, GTE 

Internetworking, and XO Communications, as well as internet standards work in 

the Internet Engineering Task Force (IETF). Most recently, I served for 5 years as 

executive vice president and chief technology officer for ServerVault, providing secure managed IT services for sensitive Federal Government applications. My duties 

included direct responsibility for securing and preparing the certification of FISMA 

Moderate impact level Federal information systems over shared internet-based infrastructure. I have prepared my remarks today out of a desire to see the advancement of responsible Cloud-based computing for the Federal Government. 

I would like to start by offering congratulations to the GSA for the development 

of its Federal Risk and Authorization Management Program (FedRAMP) program, 

as well as the recent Infrastructure as a Service (IaaS) Blanket Purchase Agreement (BPA) awards. By developing this program in cooperation with the Federal 

CIO council, the GSA has enabled agencies to leverage cloud-based storage, virtual 

machines, and web hosting services in a manner that should improve the cost and 

timeliness of Federal IT system deployments. 

II. MANAGING EMERGING RISKS FROM CLOUD COMPUTING

As a result of my experiences deploying Federal IT systems over the public internet, I was asked to present at cloud interoperability workshop in 2009, and to identify the most critical challenges that Federal CIO’s faced in making use of cloud 

computing under the existing FISMA security framework. Back then, the major difficulties that I identified were: 

• Agency pressure for deployment of timely, cost-effective IT systems; 

• Administration expectations for leveraging new IT technologies; 

• Compliance with IT policy mandates (Federal and agency-specific); 

• Lack of common IT infrastructure services between systems & Potential vendor 

lock-in with any sizable deployment; 

• Preparation of extensive FISMA control documentation for each system. 

It is remarkable to see the progress that has occurred since that time. As a result 

of the FedRAMP program (with its common security control baseline), agencies now 

have a clear roadmap that should address many of these challenges in making use 

of cloud computing for Federal IT applications. 
65 

I must note, however, that cloud computing does not eliminate all of the challenges, and in particular, cloud computing may actually heighten the difficulties 

that Federal CIO’s face in some areas if not carefully managed. The areas that are 

most likely to pose increased risks as a result of the introduction of cloud computing 

are: 1. Interaction of cloud computing services with Federal cybersecurity initiatives; 

2. Physical location of cloud computing facilities and data; 

3. Migration between vendors of cloud computing services; 

4. Evolution of cloud computing services with internet technologies. 

None of these risks precludes the use of cloud computing services by the Federal 

Government, but each does pose new challenges for Federal CIO’s to consider and 

may warrant consideration by the Federal CIO Council and its partners to determine if additional standards or coordination activities would help minimize these 

risks. I will outline each of these risk areas with recommendations for further consideration. 

III. INTERACTION OF CLOUD COMPUTING SERVICES WITH FEDERAL CYBERSECURITY

INITIATIVES

There are several Government-wide IT security initiatives that require consideration with respect to cloud computing because of their service nature: Specifically, 

there is the distributed issuance and recognition of user authentication credentials 

via the HSPD–12 initiative, as well as the provision of secure and monitored internet connectivity via the Trusted Internet Connections (TIC) initiative. These programs provide certain security-related services to Federal IT environments which 

result in increasing cybersecurity protection on a Government-wide basis as more 

agencies make use of the services. 

While specified in the FedRAMP security profile for Moderate risk environments, 

the actual mechanism and ability to participate in these Government-wide cybersecurity initiatives by private cloud computing vendors remains unclear, and any deployment of Federal IT systems via cloud computing services that do not leverage 

these common capabilities dilutes the value of these initiatives in supporting the 

overall cybersecurity stance of the Federal Government. 

The goal must be to have unequivocal documentation for cloud computing companies on how to appropriately secure their offerings, including how to make use of 

Government-wide cybersecurity initiatives, and thus encourage significant industrywide vendor participation in offering FedRAMP cloud services. The resulting competition will both drive down costs and improve service quality for all FedRAMP 

participants. 

IV. PHYSICAL LOCATION OF CLOUD COMPUTING FACILITIES AND DATA

One of the more unusual consequences that results from the use of the cloud computing is the potential loss of the ability to know at any given time the specific 

physical location for the systems and data which support a given Federal IT system. 

While it may be possible to know the set of data centers which support the service 

(and the FISMA-based FedRAMP security control profile does specify certain physical controls at such facilities for facility access, power redundancy, etc.), the question of actual physical location of the Federal IT system is highlighted when the 

cloud service provider has facilities which are outside of the United States. 

As a practical matter, there may not be a concern with incident services being 

provided for out of non-U.S. locations, and it may be desirable in some circumstances with Federal applications that must be accessed globally. However, the 

present FedRAMP profile does not directly address the question of location and it 

is not assured that use of facilities and storage of data outside the United States 

is universally desirable, particularly if the use of cloud computer for Federal IT applications is undertaken on a large scale. 

The FedRAMP program should include controls that address the physical location 

of cloud computing facilities and data storage used by the application, and allow (as 

is done with the corresponding personnel controls) for the consideration of exceptions once fully documented and reviewed. 

V. MIGRATION BETWEEN VENDORS OF CLOUD COMPUTING SERVICES

The ability to extract agency data in standard formats from cloud computing services (whether that be application data such as mail messages and mailing lists, or 

system data such as the virtual server, storage, and network configurations) is essential to be able to migrate between cloud vendors. Lack of this capability means 

vendor lock, eroding the financial benefits of cloud computing and preventing timely 

response if a vendor’s security is irrevocably compromised. 
66 

There are on-going efforts in the area of standards for cloud computing data, and 

this work should continue and be prioritized by the agencies supporting the 

FedRAMP program. Unlike an internal agency information system, cloud solutions 

are inherently subject to change by the cloud service provider, and this creates a 

new requirement (specifically, the ability to quickly and reliably migrate to another 

service provider) where it previously was not needed for agency systems. FedRAMP 

must facilitate migration capabilities to protect against any cloud computer vendors 

that fail to continuously deliver the necessary quality or security in their offerings. 

The FedRAMP security control profile includes standard FISMA contingency planning and recovery security controls, but these fundamentally only address recovery 

within a given service provider cloud. Specific mechanisms should be put in place 

to insure that Federal agencies can extract their data and configuration in generally 

accepted formats and that these mechanisms suffice for service migration to other 

cloud computing vendors. 

VI. EVOLUTION OF CLOUD COMPUTING SERVICES WITH INTERNET TECHNOLOGIES

The internet is constantly evolving with the introduction of new standards and 

technology, and in making use of the internet as a platform for cloud computing, 

FedRAMP must be equally prepared as these changes occur. This is particularly 

true when it comes to internet technology improvements in the area of cybersecurity. 

In many cases, the Federal Government has taken an active interest in the technologies and standards that could improve the overall security of the internet, and 

this includes DNSSEC initiative in securing the Domain Name System (DNS), the 

next version of the underlying network protocol for the internet—Internet Protocol 

version 6 (IPv6) and on-going work in internet routing security. These technologies 

are now being deployed in the public internet, and are also covered by specific directives in the FISMA security control baseline and/or guidance from OMB. 

These new standards are quite important in protecting the global internet from 

cybercrime, in that they insure that internet users reach the actual website that 

they intended to, and that their communication is protected in the process. When 

it comes to agency use of cloud computing services, these protections are equally important, since these services are reached over the public internet. 

It is crucial that the FedRAMP program clearly and unambiguously incorporates 

DNSSEC and IPv6 into the FedRAMP baseline, and that on-going developments in 

internet-wide security technologies are promptly incorporated as they reach maturity. 

Furthermore, the on-going need to adopt and maintain state-of-the-art security 

technologies and practices for cloud computing services does not appear to be given 

sufficient priority in the FedRAMP approach. While traditional Federal IT systems 

have been built and certified one at a time in predominantly closed environments, 

the rapid pace of evolution of internet threats requires equally dynamic and responsive security responses. Vendors should be given the flexibility to propose additional 

or alternative security mechanisms, as there are security lessons learned from running large-scale internet services that are not readily available to the Federal IT 

community, and the benefits of such experience should not be lost in the process 

of structuring cloud services into the FISMA framework. 

VII. CONCLUSION

The FedRAMP program is a remarkable achievement; by providing agencies with 

ready access to additional computing resources that have already undergone a joint 

authorization process, the program offers the potential to significantly improve cost 

and timeliness of Federal IT deployments. 

While not detracting from the importance of this achievement, the use of public 

and shared cloud computing services does introduce new areas of risk to be considered, and this is particularly true with respect to the interaction of cloud computing 

services with Federal cybersecurity initiatives, the geographic location of Federal 

data, the migration between vendors of cloud computing services, and the evolution 

of cloud computing services with the internet. 

The risks should not preclude use of cloud computing services by the Federal Government, but the model should be closely examined, and appropriate efforts inserted 

into the FedRAMP program so that it can deliver its full benefits in an efficient and 

secure manner. 

Mr. Chairman, Ranking Member Thompson and Members of the subcommittee, 

this concludes my written statement. 

Thank you again for this opportunity to speak before you today on this important 

topic, and I would be happy to answer your questions. 
67 

Mr. LUNGREN. I thank you, Mr. Curran. 

I thank all of you for your testimony, and I will yield myself 5 

minutes for first questions. 

Mr. Sheaffer, one of the things that struck me as you spoke was 

the idea that in the past, with the internet and so forth, we didn’t 

build in security at the outset and we have had to play catch-up. 

Mr. Curran has just outlined a number of things that deal with 

building security into our advances in computer technology, including the cloud. Could you comment on the comments that he made? 

Mr. SHEAFFER. Certainly, sir. I agree that we are in a position 

where we are using a technology and infrastructure that was not 

originally intended to be with the security issues in mind, and I 

agree that there are a number of initiatives underway to address 

a number of those vulnerabilities and issues. 

I think there has been a—there is good examples that exist in— 

within our intelligence community and in the secure side of Government operations that point the direction that we are able to 

build architectures that can secure data and applications adequately in a private cloud environment. I think some of the comments were addressed to how are we going to do that in the public 

environment, and I would go back, I think, to some comments in 

the earlier panel that suggest that until we can do that we have 

to be careful about what we put out into the public domain. 

But the interest of the commercial sector is to, as quickly as possible, get to a point where they can provide those adequate protections and the innovation that is going on in the commercial world, 

I think, will solve those problems in time. 

I think in the mean time I would agree, we have to be aware of 

what they are, do what we can from a standards perspective to 

build in standards and approaches that will guarantee to the maximum extent possible that those vulnerabilities can—and risks can 

be managed. But we will, as a—from a technological perspective, 

solve those problems. 

Mr. LUNGREN. Mr. Brown, it appears one of the messages from 

this panel is that the dynamism of the I.T. world—— 

Mr. BROWN. Yes. 

Mr. LUNGREN [continuing]. That we make a mistake when we 

take a static view of things and that cloud computing is one evolutionary point in this utilization of advanced information systems. 

So therefore, we have got to try and, from our standpoint, make decisions that reflect that. 

At the same time, there is this sort of fundamental issue or concern that reflected in both constituencies and Members of Congress 

that there is something about possessing a system, there is something about possessing your own information, there is something 

about fencing off your information from everything else, which is 

perversely at odds with using the internet. 

Mr. BROWN. Right. 

Mr. LUNGREN. Yet, people seek both the ease of access and the 

multiplication of recipients of their information that the internet 

offers with a heightened sense of privacy. So I think one of the 

great concerns we have to deal with—both legitimate aspects of it 

and, let’s say, hyped aspects of it—are that as you surrender your 

possession of the system and move more to a cloud system, which, 
68 

as I get your various definitions, essentially means you are cooperating with other systems in a way that your information is not totally under your control, how do we both overcome the fear that 

people have a loss of security because of a loss of possession, but 

at the same time assure them that we do have technology fixes so 

long as we understand that that requires a sufficiency of information that the users have and a persistence in the use of what I will 

just call generally good cyber hygiene? 

Mr. BROWN. So, one of the things that we have to understand is 

that from an economic standpoint, cloud is coming, okay? The reason why is that in cloud computing we can do many more releases, 

put together more software that is better more quickly, we can test 

it in one environment, we can get higher quality software out of 

the, you know, out of our building and into the hands of the consumers quicker. 

If we don’t, as vendors, embrace cloud we will be out of business, 

okay? 

Mr. LUNGREN. That is a pretty strong imperative. 

Mr. BROWN. Yes. So it is a very strong imperative. If we don’t 

embrace cloud we will be out of business. 

So I think the same goes for governments in the same way, that 

if you want to keep up, if you want to move quickly, embracing the 

cloud for the same efficiency reasons needs to occur. Now, anytime 

we have these types of changes, right, we have opportunities to become better or become worse, right? We believe that cloud gives us 

an opportunity to become more secure. 

Now, the things that need to happen there is you need to have 

trust in the providers, like as what we said, but you need to be able 

to verify, right? So you need to be able to have things like 

FedRAMP that allow you to monitor those providers to make sure 

they are not only doing what the contract says, but actually doing 

what they say, right? 

You need to be able to be cautious as you go in—enter into these 

environments to make sure that—you know, in some cases we are 

going to see huge expansions of cloud providers and only a certain 

portion of them will survive, so you need to have contingency plans 

set up to be able to move from one cloud provider to another. 

So it is not a question of if it is going to happen. It is going to 

happen; we are going to move there. 

So it is a question of how we get enough trust in that environment that we can effectively move forward. Trust ends up being 

transparency; it ends up being, you know, acceptance of this is 

what a—this is what a cloud provider is going to do; and the ability 

to consistently monitor what they are doing to ensure that, you 

know, what they—they are doing what they say they need to do. 

Mr. LUNGREN. I have got a whole bunch of other questions, but 

I am going to yield to Ms. Clarke now for 5 minutes. 

Ms. CLARKE. Thank you very much, Mr. Chairman. 

I want to thank the panelists for lending their expertise to this 

discussion today. 

My first question is, many potential agency users of the cloud believe it is not yet secure enough for their needs. From your perspectives, are they right? 
69 

Mr. BOTTUM. Well—excuse me—I am a provisioner, and so I say 

amen to everything Mr. Brown just said, and it is a question of 

building up trust. I think with the relationships we have, you 

know, that is essentially how we got there, was through building 

the trust of the end-user and the community that we are provisioning for. 

The first thing I did 5 years ago when I went to Clemson was 

consolidate 43 I.T. departments into one, and that is essentially 

building a cloud for 43 people who used to do their own—departments that used to do their own computing. So over time you have 

to, you know, build that trust and that true performance. 

I think, you know, directly answering your question is it secure 

enough, we get tested in a number of ways. I think the end-user 

has to figure out how they, you know, trust but verify, I think. 

I mentioned that we run the Medicaid system for the State of 

South Carolina. We get both planned visits, audits, and we get unplanned visits and audits. So you have to be ready at all times. 

It is a matter of communication, policies, people working together. I think, you know, the—to me, you know, the cloud is—you 

know, we just call it something different every decade. It was timesharing in the 1980s; it was the grid in the 1990s. We did a project 

with Notre Dame, the Northwest Indiana Computation Grid. 

But basically it is, you know, that is essentially what it is, is a 

matter of people working together and creating a trusted environment, so—— 

Mr. CURRAN. Let me address this a little bit, and I will pick up 

on the comments of the earlier panel from DHS CIO Spires. At the 

end of the day, the question of whether or not secure enough is the 

agency CIO’s determination. That is truly his job. 

What we need to do is make sure that the mechanisms we have 

put in place give that agency CIO enough information to make that 

determination. The FedRAMP program is a start at a profile of controls that would make public clouds useful to CIOs. 

However, right now there are a number of pieces that a CIO has 

to fill in on their own. If you want your data within the United 

States that is not in the profile; that is your SLA. If you are worried about migration, that is not in the profile; that is something 

you are going to worry about. 

So the answer is: Is it suitable today? For an ambitious, highenergy agency that decides it is going to take this on, yes, where 

they fill in those pieces. So the question is whether or not we can 

make a FedRAMP program where those functions are already provided for, already clearly documented. 

That doesn’t mean all the data, for example, needs to be in the 

United States. An agency whose workers are around the globe 

doing aid might want data centers that are close to where those 

people are for performance reasons. Someone else doing sensitive 

work might want to know that the cloud that he is using has said 

all of its servers are located in the continental United States. 

It is making sure that information is in the profile and in the 

documentation so the agency CIO has the work he has, has the information he needs to do the job of answering that question. I 

think it is possible to use it today; I think it could be much easier 

to use with work. 
70 

Mr. BROWN. One of the other important points here is that there 

will be specialized cloud services that are developed for specialized 

purposes, okay? So, you know, if there is enough money available 

for someone to produce a cloud service that is ultra-secure, you 

know, ultra—you know, ultra-secure and ultra-resilient, right, 

somebody will produce that cloud service from—as long as the economic model fits. 

You are going to see other economic models that take less security, and less security less resilience. All of those types of models 

are okay as long as they transparently tell you what their models 

are and what they can provide. 

Ms. CLARKE. Let me thank you all for your answers. So many 

questions come to mind once you raise that question and then you 

get the answers, right? So it is a totally new space. That is a lot 

of pressure on a CIO. 

Then you start thinking about, well, does this become an issue 

for litigation as, you know, we begin to build those areas of trust, 

all right? So does that become a whole ’nother practice within the 

legal field and an understanding of that world that we have created? 

So, my time is elapsed and I want to just thank you once again 

for raising the consciousness here in the Congress of what we need 

to do. Thank you. 

Mr. LUNGREN. There are so many questions, but you have been 

very good about—let me just ask one general question. When we 

look at all the positives of cloud computing, however we want to 

define it, and as the new evolutionary point, is it a canard to suggest, though, that with cloud computing you do create some more 

target-rich environments? That is, if I could go after a larger bit 

of information or a larger universe of data points that involve a 

number of different players it might be worth my while to put more 

capital investment and time to go after it, or is that just—— 

Mr. BROWN. Same idea as Fort Knox, right? So can we protect 

the gold, right? That is the question, right, is: Can we have appropriate safeguards to protect that information? 

If you look at what some systems have done, you know, your 

data actually isn’t stored in one central location; little pieces of 

your data are stored all over, in many different servers all over the, 

you know, world, therefore they can’t be reconstituted into one 

piece. So, you know, because the data just happens to be stored in 

the cloud it takes advantage of technology that makes it harder to 

compromise one data center. It won’t help you. You have to compromise the whole system. 

So there are technology advantages to, you know, moving to the 

cloud. But you are right about a target, right? As you have more 

data in one place it is more of a target, but it is also one of the 

things that you can centrally protect. 

Mr. LUNGREN. Well, I want to thank all four of you for testifying, 

and the previous panel. This is an issue that we are just scratching 

the surface on here. I think there is a lot of confusion about it, I 

guess even, I would say, fear, just because this is a new notion to 

the larger public, computer—cloud computing. 
71 

I think one of our obligations is not only to help clear up that 

confusion as best we can, but understand the reality as best we 

can. 

I think what you suggest, Mr. Curran, is make sure that all the 

moving parts are related, that if we do something on the Government side where we think we have certain protections that that is 

not only communicated with but is operational with public clouds 

as we work with them, and that we sort of anticipate these things 

instead of doing patchwork approaches later on. 

So I want to thank you. I thank you for your valuable testimony. 

Members of the committee may have some additional questions 

for you and, we would ask you if you would please respond to those 

in writing upon your receipt. The hearing record for Members will 

be held open for 10 days, and the subcommittee stands adjourned. 

[Whereupon, at 12:56 p.m., the subcommittee was adjourned.] 

(73) 

A P P E N D I X 

QUESTIONS FROM HONORABLE WILLIAM KEATING FOR RICHARD SPIRES

Question 1a. I’m concerned about maintaining the security of Government data 

maintained and transmitted through mobile data storage devices, particularly USB 

flash drive products. While I appreciate the obvious day-to-day benefits of flashdrive technology, flash drives infected with malware, as well as lost and stolen 

drives, present a clear threat to our Government’s information systems. I understand that some flash drives use hardware—instead of software—authentication, 

which protects the devide from malware and hacking. 

Are you familiar with hardware-authenticated drives? 

Answer. Response was not received at the time of publication. 

Question 1b. If so, to what extent have you tested and evaluated them? 

Answer. Response was not received at the time of publication. 

Æ