Welcome to the first posting to my new FileMaker Security blog. From time to time, I’ll be discussing issues of significance and importance related to FileMaker Pro and FileMaker Server security. In all these discussions I will keep foremost the concept that security is supposed to be focused on the preservation of the Confidentiality, Integrity, and Availability (CIA) of digital assets, and sometime of physical ones.
This first posting will focus on issues related to cloud computing security for FileMaker Pro. The cloud is all the rage these days. Yet despite that high level of interest, cloud computing, especially in the FileMaker world, is poorly understood and confused with other elements to which it has no real relationship.
Gartner has estimated that some 60% of organizations are currently actively considering cloud computing. These organizations are eager to take advantage of the elasticity, scalability, and cost benefits that cloud computing offers.
Despite these benefits and despite the interest in cloud computing that organizations express, there are some serious caveats and reservations about taking an organization’s information assets and putting them into the cloud. If a data owner wants to employ the cloud, it must make serious efforts to guarantee trust, security, and control in cloud environments. Otherwise, its digital assets are at serious risk for having their Confidentiality, Integrity, and Availability breached.
At the 2010 RSA Security Conference in San Francisco, Phil Dunkleberger, President of PGP Computing, a leading information security industry company, offered the prescient and discerning observation that despite all the advantages the cloud might be able to offer, people are not flocking to the cloud and likely will not be doing so. Why? They don’t trust the cloud, he said. And there is good reason for their not trusting it.
FileMaker Pro solution developers and IT personnel administering FileMaker servers hosting those solutions need to take special care to be aware of these items. First, and foremost, there is no real “cloud computing” to speak of in the FileMaker world. Merely having remote hosting of FileMaker Pro databases on virtual or physical servers offered by some service provider somewhere outside the organization’s work locations does not, by any means, constitute Software as a Service (SaaS), Hardware as a Service (HaaS), or Platform as a Service (PaaS). SaaS, HaaS, and PaaS are the core elements of cloud computing.
Notwithstanding this however, there are any number of lessons and strictures drawn from cloud computing that can be applied to remote hosting of FileMaker databases. There are a variety of core questions for the owners of FileMaker Pro databases to ask about remote hosting, starting with “Why do you want to do this?” Usual answers include such elements as lack of organization expertise about FileMaker Server administration and configuration and desire to provide 24/7 monitoring of the servers. Good answers perhaps, but organizations may want to ask what other reasons they have for wanting remote hosting. And then they also will want to ask whether the risks associated both with the cloud and with remote hosting outweigh the benefits provided.
So here are a few core questions owners and administrators of FileMaker Pro databases may want to ask. There has been a lot of information in recent months published in various White Papers and Podcasts and offered at the 2011 RSA Security Conference about these concerns. Interested readers may want to explore these resources further, inasmuch as this is by no means a comprehensive list.
1. How are data protected, isolated, and shared? Whether you have trade secrets or commercial processes, or confidential organizational information about finances, customers/clients, or your own personnel information stored in your database, how are you going to protect these data once they go to a remote location. Not only that, but how are you going to assure data availability and integrity as well?
2. How will you address the loss of perimeter based controls present in the local enterprise? Remote sites likely will bypass organization security policies and procedures your organization has in place.
3. How will you address the challenges of multiple users’ sharing of common resources? These multi-tenancy issues can be especially difficult. How do you assure that some other organization that is also using the same provider or the same server hardware as you are isn’t able to access or to view your data? In other words, how safe is a multi-tenancy arrangement? How are the risks of using it going to be managed?
4. Who has responsibility for compliance with regulatory and statutory items related to any customer/client/member data that are stored in the database? Generally, such responsibility remains with organization that owns the data. It cannot for the most part be transferred to the provider. Significantly, if there is a breach, who bears responsibility and liability? Whose insurance covers this liability, partially or (not likely) fully?
5. What are the applicable laws governing access to the data housed at the remote site? These likely will vary according to the jurisdiction where the data actually are housed. Those laws in different jurisdictions will not be the same necessarily as are the laws where the organization itself operates or where it is legally registered and/or incorporated.
6. As the owner of the data, do you know what the scope of the protection is for the data that the provider is obligated to provide? What conditions govern the use and disclosure of data? And presuming such provider safeguards are identified or promised (even contractually), how does the owner of the data monitor the provider’s safeguards? And if shortcomings are detected, what is the responsibility of the provider to undertake any remedial action identified through such an audit process?
7. Who bears the cost of dealing with any breaches currently estimated at $204 per record?
8. Finally, if the arrangement with the remote provider collapses (for any number of reasons), how does the owner of the data terminate its relationship with provider and recover all its data and all its backups, and leave no copies of the data behind at the remote hosting site?
As a practical matter most providers will not have protections in place, and that increases the liability of the owners of the data. And so, despite the benefits of both cloud computing and remote hosting, data owners need to ask themselves whether a variety of risks associated both with the cloud and with remote hosting outweigh the benefits provided. They will want to ask how to guarantee and maintain trust, security, and control in these environments. I look forward to further discussion of these items in the FileMaker community.
Steven H. Blackwell