Pharmaceutical companies have long been familiar with the pros and cons of cloud vs. non-cloud environments. The same discussions took place when companies in other industries began transitioning from on-premises to outsourced providers.
However, the pharmaceutical industry, and the data they manage, is within the scope of the Federal Drug Administration (FDA). With the FDA’s purview increasing over the years, and the globalization of their compliance oversight (now including over 150 countries exporting FDA‑regulated products to the United States), they have put more of the onus of following regulations on the pharmaceutical companies.
Enhancing Security Through Strategy and Architecture
In response to the FDA asking questions regarding the Code of Federal Regulations Title 21, Part 11 (CFR 21 Part 11), companies complying with GxP regulations have to ask themselves: “What risk level is acceptable for my business?” Often, this becomes a paralyzing exercise fraught with an unwillingness to change or, at best, test runs of cloud technology in safe areas like dev/test that are ultimately never implemented. This inaction leaves them behind more agile competitors who have clear, well-documented policies around adopting cloud technologies without adding significant risk. Lacking a defined cloud initiative does something that many companies may find surprising – it increases their risk and vulnerability as bad actors, security attacks, and attempts at gaining access to sensitive data become more sophisticated.
“What risk level is acceptable for my business?”
This often becomes a paralyzing exercise fraught with unwillingness to change.
Well-architected cloud environments are the best solution to keep up with those security challenges. According to Gartner, “…through 2020, public cloud infrastructure as a service (IaaS) workloads will suffer at least 60 percent fewer security incidents than those in traditional data centers.” This additional security is the result of the major cloud platform providers (AWS, Azure, Google, and Alibaba) having a virtually unlimited budget and tight controls of the underlying platform. While they do provide a secure platform, it is still up to the users to architect secure environments. Gartner also states: “through 2022, at least 95 percent of cloud security failures will be the customer’s fault.”
The Way Forward
So, what can you do to ensure that your FDA-regulated business remains competitive and secure in a world where change is constant, and breaches happen daily? The first step is also one of the most important: Secure the understanding and sponsorship of the entire executive team.
There should be unanimous and clear support from the executive team, and a realistic understanding of the benefits of a cloud solution. Without their support, any adoption challenges may cause the project to stall, create doubt, or even lead to abandoning your cloud initiatives altogether.
Once you have the executive team’s support, a company-wide policy for cloud initiatives needs to be developed. This policy should be created by those with a deep knowledge of cloud computing to take full advantage of the appropriate cloud services for your business requirements. At this point, engaging with a managed service provider or consultant can be highly beneficial and ensure that your cloud initiatives are realistic and follow best practices for cost, security, and compliance requirements.
Developing Effective Adoption Policies
At minimum, a cloud adoption policy should address security and compliance requirements, workload elasticity and scaling demands, departmental ownership and responsibilities, risk assessment and remediation methodologies, and critical dependencies. In addition, you should also consider addressing storage retention, disaster recovery, or business continuity. The process of developing these comprehensive adoption policies allows your organization to gain a better understanding of how the cloud fits into each aspect of your business, while providing clear goals for your teams to pursue.
Having a clearly defined objective is best practice for implementing a cloud solution, but being too focused on the minutiae can lead to tunnel vision and increases the likelihood of creating an inflexible adoption plan. Designing a plan that functions more as a framework or a set of guidelines than a codified set of instructions, in a sense mirroring the flexible nature of the cloud, will help prevent your teams from losing sight of the advantages of cloud services or hindering innovation.
Another common pitfall to cloud adoption is the tendency to apply current, non-cloud policy to your cloud adoption initiatives. Adherence to legacy IT policies will prove challenging to cloud adoption and could make it impossible to fully realize the advantages of moving to a cloud solution. And outdated approaches could even result in greater costs, poor performance, and poorly secured environments. These risks can all be addressed with appropriate cloud-based policies that foster cloud-first approaches to new initiatives.
Becoming a secure, cloud-enabled organization requires consistent diligence from your internal teams and continuous adherence to the company cloud policy. In the end, the most significant risks to the security of your infrastructure are tied to your own policies and oversight, and the continued security of your cloud and data will require the involvement and cooperation of your entire organization. Clear communication and targeted training will help your teams understand their role in organizational security.
An Outsider’s Expertise
If you’re not sure about the effectiveness of your approach to cloud adoption, bringing in a third party to assist with policy creation or implementation can help save time and money while ensuring that best practice security is built into your approach. Outside organizations can also provide valuable assistance if you’ve already implemented cloud solutions, so it’s never too late to get guidance and insight from experts who can point out where processes or solutions can be improved, corrected, or optimized to meet your specific business requirements.
These third-party engagements have proven to be so useful that AWS has created the Well-Architected Framework and an associated Well-Architected Review program that gives their clients an incentive to have a certified third party review and then optimize their AWS solution (learn more about Effectual’s Well-Architected Review offering). Organizations such as the Society of Quality Assurance and the Computer Validation & Information technology Compliance (CVIC) (disclosure: I am a member of the CVIC) are also discussing these issues to provide guidance and best practices for Quality Assurance professionals.
Outside professional and managed services can provide an immense level of assistance through an objective assessment of your organization’s needs. Their focused expertise on all things cloud will lighten the load on your internal IT teams, help ease any fears you may have about cloud adoption, discover potential savings, and provide guidance to fortify the security of your cloud solution.
Mark Kallback is a Senior Account Executive at Effectual, Inc.