New Standard Brings Certainty to the Process of Proper Eradication of Data

A wide variety of data types are recorded on a range of data storage technologies, and businesses need to ensure data residing on data storage devices and media are disposed of in a way that ensures compliance through verification of data eradication.

When media are repurposed or retired from use, the stored data often must be eliminated (sanitized) to avoid potential data breaches. Depending on the storage technology, specific methods must be employed to ensure that the data is eradicated on the logical/virtual storage and media-aligned storage in a verifiable manner.

Existing published standards such as NIST SP 800-88 Revision 1 (Media Sanitization) and ISO/IEC 27040:2015 (Information technology – Security techniques – Storage security) provide guidance on sanitization, covering storage technologies from the last decade but have not kept pace with current technology or legislative requirements.  

New standard makes conformance clearer

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Podcasts Bring the Sounds of SNIA’s Storage Developer Conference to Your Car, Boat, Train, or Plane!

SNIA’s Storage Developer Conference (SDC) offers exactly what a developer of cloud, solid state, security, analytics, or big data applications is looking  for – rich technical content delivered in a no-vendor bias manner by today’s leading technologists.  The 2016 SDC agenda is being compiled, but now yousdc podcast pic can get a “sound bite” of what to expect by downloading  SDC podcasts via iTunes, or visiting the SDC Podcast site at http://www.snia.org/podcasts to download the accompanying slides and/or listen to the MP3 version.

Each podcast has been selected by the SNIA Technical Council from the 2015 SDC event, and include topics like:

  • Preparing Applications for Persistent Memory from Hewlett Packard Enterprise
  • Managing the Next Generation Memory Subsystem from Intel Corporation
  • NVDIMM Cookbook – a Soup to Nuts Primer on Using NVDIMMs to Improve Your Storage Performance from AgigA Tech and Smart Modular Systems
  • Standardizing Storage Intelligence and the Performance and Endurance Enhancements It Provides from Samsung Corporation
  • Object Drives, a New Architectural Partitioning from Toshiba Corporation
  • Shingled Magnetic Recording- the Next Generation of Storage Technology from HGST, a Western Digital Company
  • SMB 3.1.1 Update from Microsoft

Eight podcasts are now available, with new ones added each week all the way up to SDC 2016 which begins September 19 at the Hyatt Regency Santa Clara.  Keep checking the SDC Podcast website, and remember that registration is now open for the 2016 event at http://www.snia.org/events/storage-developer/registration.  The SDC conference agenda will be up soon at the home page of http://www.storagedeveloper.org.

Enjoy these great technical sessions, no matter where you may be!

Data Protection in the Cloud FAQ

SNIA recently hosted a multi-vendor discussion on leveraging the cloud for data protection. If you missed the Webcast, “Moving Data Protection to the Cloud: Trends, Challenges and Strategies”, it’s now available on-demand. As promised during the live event, we’ve compiled answers to some of the most frequently asked questions on this timely topic. Answers from SNIA as well as our vendor panelists are included. If you have additional questions, please comment on this blog and we’ll get back to you as soon as possible

Q. What is the significance of NIST FIPS 140-2 Certification?

Acronis: FIPS 140-2 Certification is can be a requirement by certain entities to use cloud-based solutions. It is important to understand the customer you are going after and whether this will be a requirement. Many small businesses do not require FIPS but certain do.

Asigra: Organizations that are looking to move to a cloud-based data protection solution should strongly consider solutions that have been validated by the National Institute of Standards and Technology (NIST), an agency of the U.S. Department of Commerce, as this certification represents that the solution has been tested and maintains the most current security requirement for cryptographic modules, or encryption. It is important to validate that the data is encrypted at rest and in flight for security and compliance purposes. NIST issues numbered certificates to solution providers as the validation that their solution was tested and approved.

SolidFire: FIPS 140-2 has 4 levels of security, 1- 4 depending on what the application requires.  FIPS stands for Federal Information Processing Standard and is required by some non-military federal agencies for hardware/software to be allowed in their datacenter.  This standard describes the requirements for how sensitive but unclassified information is stored.  This standard is focused on how the cryptographic modules secure information for these systems.

Q. How do you ensure you have real time data protection as well as protection from human error?  If the data is replicated, but the state of the data is incorrect (corrupt / deleted)… then the DR plan has not succeeded.

SNIA: The best way to guard against human error or corruption is with regular point-in-time snapshots; some snapshots can be retained for a limited length of time while others are kept for as long as the data needs to be retained.  Snapshots can be done in the cloud as well as in local storage.

Acronis: Each business needs to think through their retention plan to mitigate such cases. For example, they would run 7 daily backups, 4 weekly backups, 12 monthly backups and one yearly backup. In addition it is good to have a system that allows one to test the backup with a simulated recovery to guarantee that data has not been corrupted.

Asigra: One way for organizations that are migrating to SaaS based applications like Google Apps, Microsoft Office 365 and Salesforce.com to protect their data created and stored in these applications is to consider a cloud-based data protection solution to back up the data from these applications to a third party cloud to meet the unique data protection requirements of your organization. You need to take the responsibility to protect your data born in the cloud much like you protect data created in traditional on premise applications and databases. The responsibility for data protection does not move to the SaaS application provider, it remains with you.

For example user error is one of the top ways that data is lost in the cloud. With Microsoft Office 365 by default, deleted emails and mailboxes are unrecoverable after 30 days; if you cancel your subscription, Microsoft deletes all your data after 90 days; and Microsoft’s maximum liability is $5000 US or what a customer paid during the last 12 months on subscription fees – assuming you can prove it was Microsoft’s fault. All the more reason you need to have a data protection strategy in place for data born in the cloud.

SolidFire: You need to have a technology that provides a real-time asynchronous replication technology achieving a low RPO that does not rely on snapshots.  Application consistent snapshots must be used concurrently with a real-time replication technology to achieve real time and point in time protection.  For the scenario of performing a successful failover, but then you have corrupted data.  With application consistent snapshots at the DR site you would be able to roll back instantly to a point in time when the data and app was in a known good state.

Q. What’s the easiest and most effective way for companies to take advantage of cloud data protection solutions today? Where should we start?

SNIA: The easiest way to ease into using cloud storage is to either (1) use the direct cloud interface of your backup software if it has one to set up an offsite backup, or (2) use a cloud storage gateway that allows public or private cloud storage to appear as another local NAS resource.

Acronis: The easiest way is to use a solution that supports both cloud and on premises data protection. Then they can start by backing up certain workloads to the cloud and adding more over time. Today, we see that many workloads are protected with both a cloud and on premise copy.

Asigra: Organizations should start with non-production, non-critical workloads to test the cloud-based data protection solution to ensure that it meets their needs before moving to critical workloads. Identifying and understanding their corporate requirements for a public, private and/or hybrid cloud architecture is important as well as identifying the workloads that will be moved to the cloud and the timing of this transition. Also, organizations may want to consult with a third party IT Solutions Provider who has the expertise and experience with cloud-based data protection solutions to explore how others are leveraging cloud-based solutions, as well as conduct a data classification exercise to understand which young data needs to be readily available versus older data that needs to be retained for longer periods of time for compliance purposes. It is important that organizations identify their required Recovery Time Objectives and Recovery Point Objectives when setting up their new solution to ensure that in the event of a disaster they are able to meet these requirements. Tip: Retain the services of a trusted IT Solution Provider and run a proof of concept or test drive the solution before moving to full production.

SolidFire: Find a simple and automated solution that fits into your budget.  Work with your local value added reseller of data protection services.  The best thing to do is NOT wait.  Even if it’s something like carbonite… it’s better than nothing.  Don’t get caught off guard.  No one plans for a disaster.

Q. Is it sensible to move to a pay-as-you-go service for data that may be retained for 7, 10, 30, or even 100 years?

SNIA: Long term retention does demand low cost storage of course, and although the major public cloud storage vendors offer low pay-as-you-go costs, those costs can add up to significant amounts over a long period of time, especially if there is any regular need to access the data.  An organization can keep control over the costs of long term storage by setting up an in-house object storage system (“private cloud”) using “white box” hardware and appropriate software such a what is offered by Cloudian, Scality, or Caringo.  Another way to control the costs of long-term storage is via the use of tape.  Note that any of these methods — public cloud, private cloud, or tape — require an IT organization, or their service provider to regularly monitor the state of the storage and periodically refresh it; there is always potential over time for hardware to fail, or for the storage media to deteriorate resulting in what is called bit rot.

Acronis: The cost of storage is dropping dramatically and will continue to do so. The best strategy is to go with a pay as you go model with the ability to adjust pricing (downward) at least once a year. Buying your own storage will lock you into pricing over too long of a period.

SolidFire: The risk of moving to a pay-as-you-go service for that long is that you lock your self in for as long as you need to keep the data.  Make sure that contractually you can migrate or move the data from them, even if it’s for a fee.  The sensible part is that you can contract that portion of your IT needs out and focus on your business and advancing it…. Not worrying about completing backups on your own.

Q. Is it possible to set up a backup so that one copy is with one cloud provider and another with a second cloud provider (replicated between them, not just doing the backup twice) in case one cloud provider goes out of business?

SNIA: Standards like the SNIA’s CDMI (Cloud Data Management Interface) make replication between different cloud vendors pretty straightforward, since CDMI provides a data and metadata neutral way of transferring data; and provides both standard and extensible metadata to control policy too.

Acronis: Yes this possible but this is not a good strategy to mitigate a provider going out of business. If that is a concern then pick a provider you trust and one where you control where the data is stored. Then you can easily switch provider if needed.

SolidFire: Yes setting up a DR site and a tertiary site is very doable.  Many data protection software companies available do this for you with integrations at the cloud providers.  When looking at data protection technology make sure their policy engine is capable of being aware of multiple targets and moving data seamlessly between them.  If you’re worried about cloud service providers going out of business make sure you bet on the big ones with proven success and revenue flow.

 

Q&A – The Impact of International Data Protection Laws on the Cloud

The impact of international data protection legislation on the cloud is complicated and constantly changing. In our recent SNIA Cloud Storage Webcast on this topic we did our best to cover some of the recent global data privacy and data protection regulations being enacted. If you missed the Webcast, I encourage you to watch it on-demand at your convenience. We answered questions during the live event, but as promised we’re providing more complete answers in this blog. If you have additional questions, please comment here and we’ll reply as soon as we can.

The law is complex, and neither SNIA, the authors nor the presenters of this presentation are lawyers. Nothing here or in the presentation should be construed as legal advice. For that you need the services of a qualified professional.

Q. What are your thoughts on Safe Harbour being considered invalid, and the potential for a Safe Harbour 2

A. Since 6 October 2015 when the European Court of Justice invalidated the European Commission’s Safe Harbour Decision, there’s been a lot written about Safe Harbour 2 in the press. But it was clear that a renegotiation was essential two years before that, when discussions for a replacement were started. Many think (and many hope!) that a new and valid agreement in terms of Europe’s Human Rights legislation will be settled between the US and Europe sometime in March 2016.

Q. Are EU Model Clauses still available to use instead of BCRs (Binding Corporate Rules)?

A. EU-US data transfers facilitated by the use of model clauses probably today fail to comply with EU law. But as there appears to be no substitute available, the advice appears to be – use them for now until the problem is fixed. Full guidance can be found on the EC website.

Q. What does imbalance mean relative to consent?

A. An example might help. You might be an employee and agree (the “consent”) to your data being used by your employer in ways that you might not have agreed to normally – perhaps because you feel you can’t refuse because you might lose your job or a promotion for example. That’s an imbalanced relationship, and the consent needs to be seen in that light, and the employer needs to demonstrate that there has been, and will be, no coercion to give consent.

Upcoming Webcast: The Impact of International Data Protection Legislation on the Cloud

Data Privacy vs. data protection has become a heated debate in businesses around the world as governments across the globe are proposing and enacting strong data privacy and data protection regulations. Join us on November 18th for our next Cloud Storage live Webcast “Data Privacy vs. Data Protection: The Impact of International Data Protection Legislation on the Cloud.

Mandating frameworks that include noteworthy changes like defining a data breach to include data destruction, adding the right to be forgotten, mandating the practice of breach notifications, and many other new elements are literally changing the rules when it comes to data protection. The implications of this, and other proposed legislation, on how the cloud can be utilized for storing data are significant. Join this live Webcast to hear:

  • “Directives” vs. “regulation”
  • General data protection regulation summary
  • How personal data has been redefined
  • Substantial financial penalties for non-compliance
  • Impact on data protection in the cloud
  • How to prepare now for impending changes

Our experts, Bob Plumridge, SNIA Europe Board Member; Eric Hibbard, Chair SNIA Security TWG, and I will all be available to answer your questions during the event. I encourage you to register today for this timely discussion. We hope to see you on November 18th!