1. Cloud Computing for Wireless Networks
Data Privacy & New Media
Wireless Telecommunications Symposium
Michael R. Dover – Kelley Drye & Warren LLP

2. Topics About the Cloud Benefits Key Considerations
Regulatory Implications

3. What is “The Cloud”?
Cloud computing is the delivery of on-demand computing resources, over the Internet, typically on a pay-for-use basis.

4. Cloud Service Models
Cloud Software as a Service (SaaS) – involves access to a provider’s software as a Service (e.g. G-mail, SalesForce)
Cloud Infrastructure as a Service (IaaS) – involves the provisioning of fundamental computer resources (e.g. processing, storage)
Cloud Platform as a Service (PaaS) – involves the provision to users of the capability to deploy onto cloud infrastructure applications created by the user with provider supported programming languages and tools (e.g. Azure)

5. Cloud Infrastructure Models
Private Cloud – maintain all technology components, servers and software for a single organization. May be managed by a 3rd party.
Public Cloud – available to anyone, from individuals to large organizations and is owned and controlled by the provider of the service. Offers the greatest potential flexibility and cost savings.
Community Cloud – cloud infrastructure shared by several organizations that supports a specific community with shared concerns.
Hybrid Cloud – involves a mix of two or more of these models

6. Leading Cloud Infrastructure Providers
Microsoft
Cisco
IBM
Amazon Web Services
Google
Salesforce

7. Why Should Businesses Move to the Cloud?
Pay just for what you need – cloud technologies make it easy to scale up and scale down depending on demand for storage, bandwidth, processing etc.
Flexible Pricing – pay for what you use, and quickly increase or decrease usage with minimal involvement by the service provider.
Agility – cloud technologies allow companies to move quickly. New business ideas and services can be brought to market much more quickly.

8. Why Should Businesses Move to the Cloud?
Improved Focus on Business Value – instead of maintaining current systems, your IT Department can spend more time solving new business problems.
Increased Insight – cloud computing helps derive insights from “big data” and can help businesses target customers more effectively.
Collaboration – work can be accessed from various devices, from almost anywhere.

9. Key Considerations Contractual Trust Security Privacy Threats
Compliance

10. Contractual Considerations
Clear fees for services and modifications
Well-defined performance metrics/remedies for service failures
Security, privacy and audit commitments that satisfy regulatory concerns and understanding where data resides
Business continuity, disaster recovery and force majeure events
Clear restrictions on use/ownership of customer data and IP
Provisions for termination

11. Trust Considerations Is cloud computing secure?
Where is my data and do I have access?
How do you support my compliance needs?
What does privacy mean?
Is my data used for advertising?

12. Security Considerations
Security best practices like penetration testing, Defense-in-depth to protect against cyber-threats.
Physical and data security with access control, encryption and strong authentication.
Unique customer controls with Rights Management Services to empower customers to protect information.

13. Safeguarding Services
Security Management
Threat and vulnerability management, monitoring, and response
Data
Access control and monitoring, file/data integrity
User
Account management, training and awareness, screening
Application
Secure engineering (SDL), access control and monitoring, anti-malware
Host
Access control and monitoring, anti-malware, patch and configuration management
Internal network
Dual-factor authentication, intrusion detection, vulnerability scanning
Network perimeter
Edge routers, intrusion detection, vulnerability scanning
Facility
Physical controls, video surveillance, access control

14. Encryption Data on the move Data at rest Client to Server
Server to Server
Data center to Data center
SSL/TLS Encryption
Data at rest
Encrypted disks
Encrypted shredded storage
User

15. Privacy Do not advertise products based on customer data.
Do not scan or documents to build analytics or mine data.
Be mindful of who has access to information about geographical location of data.
Notify customers about changes in security, privacy and audit information.

16. Government Compliance
Do not provide any government with direct, unfettered access to your data.
Do not assist any government’s efforts to break your encryption or provide any government with encryption keys.
Do not engineer back doors into your products and take steps to ensure governments can independently verify this.

17. Regulatory Implications
On-demand cloud computing services will play an important role in the delivery of new media content.
Using cloud computing to distribute new media raises a number of legal concerns such as compliance, trademark, and copyright issues.
The Court’s decision in Aereo did not quite reach the remote storage of online content but it could have future implications for cloud computing services as they deliver new media.