Cloud computing has become ubiquitous in how we operate our businesses day to day. The benefits are overwhelming; virtually no capex is required to stand up enterprise-quality back-office services or customer-facing products and services. This low barrier to entry has been a boon to R&D organizations, encouraging experimentation and development from businesses of all sizes. Many companies use services like Office365 or Google’s GSuite for email, productivity, and collaboration, Dropbox for file sharing, Carbonite for backup, and on and on. These are all fantastic products that have helped all of us ramp up our productivity.
However, if you are a defense contractor subject to DFARS 252.204-7012, you must be very careful in your use of cloud services.
DFARS clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, provides specifics on how to handle cloud service organizations. In section (b)(2)(D), it is stated that: “*If the Contractor intends to use an external cloud service provider to store, process, or transmit any covered defense information in performance of this contract, the Contractor shall require and ensure that the cloud service provider meets security requirements equivalent to those established by the Government for the Federal Risk and Authorization Management Program (FedRAMP) Moderate baseline*”
Many companies have interpreted this to mean they can casually assess the security of their prospective vendor and make the judgment themselves. However, the FedRAMP Moderate baseline is a very stringent standard which contains 325 security control requirements. How can you, as a defense contractor, assess Dropbox against this standard? In addition, companies like Dropbox have the freedom to pursue FedRAMP authorization themselves.
The safest way to ensure your cloud service provider meets the FedRAMP Moderate baseline is to select your vendor from the FedRAMP-authorized list at FedRAMP.gov.
Don’t jeopardize your contract by trusting your cloud service provider with CDI when their security might not be up to par.
OCD Tech, a Division of O’Connor & Drew, P.C., is a leading provider of DFARS cybersecurity services. Please contact us with any questions you might have with your compliance needs.
