Public vs private cloud for regulated entities
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- Lionel Lewis
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1 Public vs private cloud for regulated entities
2 DC2: Restricted use The cloud is for everyone but not for everything 2
3 Opportunity enabler DC2: Restricted use Flexibility SAAS Public Accessibility Agility Private PAAS Cohosting Dynamic Low Maintenance Colocation IAAS Hybrid Low/No CAPEX 3
4 Rights concerns challenges DC2: Restricted use Stability? SAAS Public Seizure? Confidentiality? Ownership? Private PAAS Cohosting Location? Auditability? Colocation IAAS Hybrid Access? 4
5 Is regulation slowing you down? DC2: Restricted use 5
6 Many regulated sectors, Many Authorities Common principles DC2: Restricted use Banking Investment services Insurance Remote Gaming Health Pharmaceuticals Telecommunications MFSA MGA The professions (Legal; Engineering; Accounting and Audit; ) 6
7 Many regulated sectors, Many Authorities Common principles DC2: Restricted use Does not impair the supervision of the authority Compliance with the regulations must not be undermined None of the conditions to which the Licensed Entity is subject must be removed or modified Senior management does not delegate its responsibility The relationship and obligations towards clients must not be altered Capability to resume direct control over an outsourced activity, in extremis 7
8 Today, cloud is not a novelty DC2: Restricted use improved disaster recovery better performance for global users superior infrastructure manageability and flexibility Public Cloud Private Cloud Hybrid Cloud Percentages of US enterprises using public, private and hybrid clouds. (Source: Evaluator Group Cloud Trends Analysis based on publicly available survey data. 8
9 DC2: Restricted use Private hosted cloud for better control? Main resistance to cloud computing: Security Regulation Data protection Generally security is shared: host and tenant are responsible for different parts of the stack Actually, cloud service providers often enhance overall security TENANT Application Platform Infrastructure Operating System Hypervisor Hardware + network HOST 9
10 Security An improvement or a concern? DC2: Restricted use 67% Hosted private cloud adopters listed improved security or ability to meet compliance as its top driver but also as its top concern 10
11 DC2: Restricted use Safeguards Recognise that no form of outsourcing is risk free and that risk is carried by the outsourcing entity Due diligence in choosing cloud provider Certifications Location Monitor performance and stability Implement and test contingency plans Consultation with the authority what alternative measures could adequately mitigate the risks involved 11
12 DC2: Restricted use Contractual tips Exit management (planned + unplanned) Data portability Performance measures/service levels Confidentiality/secrecy/data protection Chain-outsourcing obligations Data breach notification obligations Supervisory authority and auditor rights [data + premises] Change in structure/ownership triggers 12
13 DC2: Restricted use Branded Trust 13
14 Forecast: Mostly cloudy This presentation has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. Copyright 2017 PricewaterhouseCoopers. All rights reserved. refers to the Malta member firm, and may sometimes refer to the network. Each member firm is a separate legal entity. Please see for further details.
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