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Public comment from Rubrik #22

Open OMBPublicComments opened 5 years ago

OMBPublicComments commented 5 years ago

Comments on Draft Cloud Smart Policy Submitted by Rubrik, Inc.

Thank you for the opportunity to provide comments on the proposed Cloud Smart strategy released for public comment by the Office of Management and Budget and its partners in the CIO community on September 24, 2018. We appreciate the OMB’s effort to update government’s cloud computing policies. The growth of cloud computing and data management tools over the last decade and the introduction of new technologies will significantly affect the implementation of this strategy and we encourage you to remain flexible so that government can fully take advantage of these new technologies. Based in Palo Alto California, Rubrik is changing the world of backup & restore with an automated, hyper-scale, and converged approach, delivered in the cloud. We simplify a 30-year-old technology design and allow government agencies and commercial customers alike to integrate immediately to the cloud and save 20-40% off the cost of legacy solutions. Rubrik delivers a single platform to manage and protect data in the cloud, at the edge, and on-premise. Enterprises choose Rubrik’s Cloud Data Management software to simplify backup and recovery, accelerate cloud adoption, and enable automation at scale. Rubrik’s run-anywhere, scale-out architecture is built to empower IT departments today, and in the future, reducing total cost of ownership while enabling infrastructure flexibility for a multi-cloud world. As organizations become more complex, data management and storage requirements become more vital to efficient operations. To scale across multiple infrastructures - public, private and hybrid cloud, as well as on premise - agencies need a new approach to data management that seeks to unify backup, recovery, replication, search, analytics, archival, compliance, and copy data management into one solution. This approach reduces the cost and complexity of data management, allows for the modernization of legacy on-premise technology, accelerates the federal government’s transition to cloud and improves security. We look forward to a new federal cloud strategy that recognizes the changes in technological innovation, many of which have occurred since the original Cloud First strategy was published. THE EVOLUTION OF CLOUD Seven years ago, when the Cloud First strategy was issued, government did not fully appreciate the opportunity brought forth by the cloud. Since that time, many technologies, including those provided by Rubrik, have entered the market. These technologies, allow agencies to do more and see more, while reducing the overall cost of government technology. With the expected growth of cloud computing in the federal market over the next five years, we expect this trend to continue. The proposed Cloud Smart strategy is rightly focused innovation and IT modernization, and as it develops, like the technology itself, government must ensure proper integration between competing policies such as Cloud Smart, the Federal Data Strategy, FedRAMP, as well as other mandates coming from policy makers. To be effective, the Cloud Smart strategy must embrace a strong focus on the understanding and management of data, not just from the perspective of data protection and awareness, but at a more basic blocking and tackling level. As OMB is well aware, in the federal government, data and applications are spread across multiple locations and services, each with its own set of governance rules and challenges, all disconnected from each other. Maintaining control, providing effective governance and meeting compliance requirement becomes nearly impossible in this fragmented environment. Agencies need technology solutions that help unify this fragmented environment by organizing all of your data and business information to make it discoverable and usable no matter where it is stored or what policies have been applied to it. Recognizing the benefit of these types of solutions is critical to developing and implementing an effective cloud strategy and will be critical to accelerating the growth of cloud computing in the federal government To that end, new cloud-based technologies can deliver centralized management to a fragmented government data environment, helping provide a more comprehensive view of an agency’s physical, virtual and cloud environments, while making data management tasks simple and intuitive. Public sector organizations need centralized management in today’s distributed global environments. Data management tools which provide a comprehensive view of an agency’s physical, virtual, and cloud topologies while making management tasks elegantly simple and intuitive are critical. These new tools, which can determine SLA compliant applications at-a-glance (a key focus area of the strategy), help to optimize cost and performance and provide on-demand insights are new entrants to the federal market and must be accounted for by the proposed Cloud Smart strategy as they can dramatically change how agencies use and manage data in the cloud The proposed Cloud Smart strategy is broken down into four critical areas – redefining cloud, security, procurement, and workforce. Security and procurement are of the most direct interest to our organization. From the standpoint of security, we have discussed above and the strategy rightly points out, migrating to cloudbased environments changes the dynamic of the network, creating needs for visibility and data protection that did not exist before. An agency is a steward of the data it holds and must commit to a security framework that allows it to understand in real time, where the data resides and how it is being used, regardless of whether the data is onpremise or in a commercial cloud. While protecting high value assets is critical, so too is ensuring a robust cloudbased data management environment that provides actionable insights and real time information on threats and related cyber-incidents. We support a more robust view of data management in the context of Cloud Smart. We also support acceleration of the CDM program, along with updated CDM guidance that will allow agencies to take advantage of new and innovative cloud technologies that did not exist when CDM was conceived. In addition, we encourage OMB to make it easier for agencies to acquire cloud technologies. We support the proposed cloud information center -- a one-stop shop for all things cloud to be housed at GSA (as described in CIO Action Item 1), as this will make it easier and more efficient for agencies to fin d the cloud solutions that meet their needs and conduct effective cost-benefit analysis. We encourage the new data center consolidation policy to better reflect today’s current technologies and buying habits, as well as new contract vehicles to make buying cloud easier, while increasing the federal government’s purchasing power. We are greatly encouraged by what OMB has proposed in the draft Cloud Smart strategy and look forward to working with you as this process moves forward. Government has an opportunity now to take advantage of new and emerging technologies that it did not have seven years ago and we believe this proposal is a strong move in the right direction. Thank you for your efforts on the proposed Cloud Smart strategy.