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Cloud Computing
Consumer Protocol
ACS Cloud Discussion Paper
Roland Padilla – ACS convenor of the cloud
computing special interest group
13 August 2013
8/F DMD Bldg, The University of Melbourne
“It is the small organisations which stand
to benefit the most from the cloud
revolution. Cloud computing will
fundamentally change the ability of small
organisations to acquire new ICT
capabilities that can increase
productivity and foster innovation.”
-DBCDE
DBCDE 2013, The National Cloud Computing Strategy, accessed 13 August 2013, from
< http://www.dbcde.gov.au/__data/assets/pdf_file/0008/163844/National_Cloud_Computing_Strategy.PDF> .
Expectations
1. Introduction and Purpose
2. Timelines
3. Background
4. Benefits of Cloud for SMEs
5. Barriers to Uptake
6. Protocol Disclosures by Cloud Suppliers
7. Complaints Guidelines
8. Open forum
1. Introduction and Purpose
• Aims to elicit suggestions and information
from cloud computing vendors and users
• Develop a Protocol
• Intends to provide current and potential users
relevant information about the providers
2. Timelines
• 19 AUG 2013 Protocol submissions close
(send to: policy@acs.org.au)
• JAN 2014 Intended operation of the Protocol
3. Background
• SMEs and NFPs appear to have a lack of understanding
& confidence in using cloud services.
• Barriers to uptake
• Needed engagement among stakeholders
• “First best” option for users
• Provide consumers with a clear and straighforward
guidance
• Cloud Security Alliance promoting best practice
• ACS view is that the cloud protocol must avoid
regulatory complexity, anti-competitive outcomes, and
overly prescriptive disclosure requirements.
• ACS agrees with the Cloud Strategy and its
aims for a Protocol, namely:
– Adequate protection for cloud consumers
– Clear and relevant information about services
– Open, honest and fair dealings between cloud
service providers and consumers
– Adequate privacy protection
– Responsiveness to market and technology
developments
4. Benefits of Cloud for SMEs
• Cost savings
• Productivity
• Lower time to market, increased scalability
• Overcome barriers to capital and expertise
• Improved reliability and security
• Mobility, flexibility and a platform for growth
Extract from the National Cloud Computing Strategy, www.dbcde.gov.au. Page 20
5. Barriers to Uptake
• Absence of a one-stop shop resource for consumers
• ACMA has disclosed that 52% of respondents lack
confidence in privacy settings for online service
providers
• Recent publicity about access by the US government’s
mass data collection program
• Personally Controlled Health Records ACT 2012
• The Protocol intends to complement existing
legislations (e.g., AGIMO, DSD, OECD and EC).
• Data sovereignty – ACMA has shown that 35% of
respondents would withhold personal information.
ACMA Digital Footprints and Digital Identities – Community Research 2013 (unpublished)
6. Protocol Disclosures by Cloud
Suppliers
• Corporate identity
• Ownership of data and information
• Security
• Data location
• Data access and use
• Backup and maintenance
• Service Level Agreement
• Vendor Lock-in
• Data portability
• Business continuity
• Data formats
• Data breaches
• Law enforcement
7. Complaints Guidelines
• A voluntary, industry-supported activity
• Raise concerns and lodge complaints (send to:
www.accc.gov.au/consumers)
8. Open Forum
Q1: Do you believe a voluntary protocol in
which cloud suppliers provide undertakings
and information about their services would
improve confidence in the market and
increase the adoption and take-up of cloud
computing services?
Q2: If you are a potential user of cloud services,
do you now have a better understanding of
cloud computing and its benefits for your
business or operations? What further
information do you need to feel confident in
deciding to adopt cloud services in your
business?
Q3: If you are a potential or current user of
cloud services, do you have other concerns
about cloud computing that have not been
outlined in this section? What are they?
Q4: Are there other disclosures from cloud
vendors that have not been outlined in the
Protocol Disclosures? What are they?
Q5: Can you outline any experiences you have
had with cloud computing which illustrate
issues such as data security, data location,
privacy or vendor lock-in?
Q6: If you are a provider of cloud services and
products, what is the current state of market
confidence in cloud computing, and are there
any outstanding transparency issues that
concern users? If so, what is the best method
of addressing these concerns?
Q7: If a voluntary protocol is introduced, do you
have any comments on potential compliance
costs, jurisdictional complexities and the
interaction between the Protocol and other
cloud standards currently being developed
globally?
Thank you
DBCDE 2013, The National Cloud Computing Strategy, accessed 13 August 2013, from
< http://www.dbcde.gov.au/__data/assets/pdf_file/0008/163844/National_Cloud_Computing_Strategy.PDF> .
“Australian small businesses, not-for-
profit organisations and consumers
will have the protection and tools
they need to acquire cloud services
with confidence.”
-Representative from the
Commonwealth Government
References
1. ACS 2013, Cloud Computing Consumer Protocol, accessed 13 August 2013, from
<http://www.acs.org.au/__data/assets/pdf_file/0011/19928/ACS-Cloud-Discussion-Paper.pdf>.
2. DBCDE 2013, The National Cloud Computing Strategy, accessed 13 August 2013, from <
http://www.dbcde.gov.au/__data/assets/pdf_file/0008/163844/National_Cloud_Computing_Strategy.PDF> .
3. Cloud Code 2013, New Zealand Code Code: Cloud Computing Code of Practice, accessed 13 August 2013,
from < http://www.thecloudcode.org/upload/files/NZCloudCode.pdf>.

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ACS cloud discussion paper

  • 1. Cloud Computing Consumer Protocol ACS Cloud Discussion Paper Roland Padilla – ACS convenor of the cloud computing special interest group 13 August 2013 8/F DMD Bldg, The University of Melbourne
  • 2. “It is the small organisations which stand to benefit the most from the cloud revolution. Cloud computing will fundamentally change the ability of small organisations to acquire new ICT capabilities that can increase productivity and foster innovation.” -DBCDE DBCDE 2013, The National Cloud Computing Strategy, accessed 13 August 2013, from < http://www.dbcde.gov.au/__data/assets/pdf_file/0008/163844/National_Cloud_Computing_Strategy.PDF> .
  • 3. Expectations 1. Introduction and Purpose 2. Timelines 3. Background 4. Benefits of Cloud for SMEs 5. Barriers to Uptake 6. Protocol Disclosures by Cloud Suppliers 7. Complaints Guidelines 8. Open forum
  • 4. 1. Introduction and Purpose • Aims to elicit suggestions and information from cloud computing vendors and users • Develop a Protocol • Intends to provide current and potential users relevant information about the providers
  • 5. 2. Timelines • 19 AUG 2013 Protocol submissions close (send to: policy@acs.org.au) • JAN 2014 Intended operation of the Protocol
  • 6. 3. Background • SMEs and NFPs appear to have a lack of understanding & confidence in using cloud services. • Barriers to uptake • Needed engagement among stakeholders • “First best” option for users • Provide consumers with a clear and straighforward guidance • Cloud Security Alliance promoting best practice • ACS view is that the cloud protocol must avoid regulatory complexity, anti-competitive outcomes, and overly prescriptive disclosure requirements.
  • 7. • ACS agrees with the Cloud Strategy and its aims for a Protocol, namely: – Adequate protection for cloud consumers – Clear and relevant information about services – Open, honest and fair dealings between cloud service providers and consumers – Adequate privacy protection – Responsiveness to market and technology developments
  • 8. 4. Benefits of Cloud for SMEs • Cost savings • Productivity • Lower time to market, increased scalability • Overcome barriers to capital and expertise • Improved reliability and security • Mobility, flexibility and a platform for growth Extract from the National Cloud Computing Strategy, www.dbcde.gov.au. Page 20
  • 9. 5. Barriers to Uptake • Absence of a one-stop shop resource for consumers • ACMA has disclosed that 52% of respondents lack confidence in privacy settings for online service providers • Recent publicity about access by the US government’s mass data collection program • Personally Controlled Health Records ACT 2012 • The Protocol intends to complement existing legislations (e.g., AGIMO, DSD, OECD and EC). • Data sovereignty – ACMA has shown that 35% of respondents would withhold personal information. ACMA Digital Footprints and Digital Identities – Community Research 2013 (unpublished)
  • 10. 6. Protocol Disclosures by Cloud Suppliers • Corporate identity • Ownership of data and information • Security • Data location • Data access and use • Backup and maintenance • Service Level Agreement • Vendor Lock-in • Data portability • Business continuity • Data formats • Data breaches • Law enforcement
  • 11. 7. Complaints Guidelines • A voluntary, industry-supported activity • Raise concerns and lodge complaints (send to: www.accc.gov.au/consumers)
  • 12. 8. Open Forum Q1: Do you believe a voluntary protocol in which cloud suppliers provide undertakings and information about their services would improve confidence in the market and increase the adoption and take-up of cloud computing services?
  • 13. Q2: If you are a potential user of cloud services, do you now have a better understanding of cloud computing and its benefits for your business or operations? What further information do you need to feel confident in deciding to adopt cloud services in your business?
  • 14. Q3: If you are a potential or current user of cloud services, do you have other concerns about cloud computing that have not been outlined in this section? What are they?
  • 15. Q4: Are there other disclosures from cloud vendors that have not been outlined in the Protocol Disclosures? What are they?
  • 16. Q5: Can you outline any experiences you have had with cloud computing which illustrate issues such as data security, data location, privacy or vendor lock-in?
  • 17. Q6: If you are a provider of cloud services and products, what is the current state of market confidence in cloud computing, and are there any outstanding transparency issues that concern users? If so, what is the best method of addressing these concerns?
  • 18. Q7: If a voluntary protocol is introduced, do you have any comments on potential compliance costs, jurisdictional complexities and the interaction between the Protocol and other cloud standards currently being developed globally?
  • 19. Thank you DBCDE 2013, The National Cloud Computing Strategy, accessed 13 August 2013, from < http://www.dbcde.gov.au/__data/assets/pdf_file/0008/163844/National_Cloud_Computing_Strategy.PDF> . “Australian small businesses, not-for- profit organisations and consumers will have the protection and tools they need to acquire cloud services with confidence.” -Representative from the Commonwealth Government
  • 20. References 1. ACS 2013, Cloud Computing Consumer Protocol, accessed 13 August 2013, from <http://www.acs.org.au/__data/assets/pdf_file/0011/19928/ACS-Cloud-Discussion-Paper.pdf>. 2. DBCDE 2013, The National Cloud Computing Strategy, accessed 13 August 2013, from < http://www.dbcde.gov.au/__data/assets/pdf_file/0008/163844/National_Cloud_Computing_Strategy.PDF> . 3. Cloud Code 2013, New Zealand Code Code: Cloud Computing Code of Practice, accessed 13 August 2013, from < http://www.thecloudcode.org/upload/files/NZCloudCode.pdf>.

Editor's Notes

  1. -Gov’t announced a national cloud computing strategy ..coordinated by the ACS -
  2. -gov’t to ensure that small businesses will have the protection and tools they need to acquire cloud services. -stakeholders such as government, industry, community, consumers. -issues such as security, privacy, accessibility, competition, exclusion, jurisdiction and assurance. -”first best” meant to provide users with basic safeguards -minimum level of service from providers, marketers, brokers /resellers without adding unnecessary regulatory burdens to either cloud supplier or the consumer. -protocol to guard against excluding market entry, limiting competition or stifling innovation. -CSA is a broad coalition of industry practitioners, corporations, assocations and other key stakeholders.
  3. -before, during and after point-of-sale for consumers
  4. -25-50 -sub