Is it ok to store everything on the cloud?

[abillybob]

Hey Guys,

 

We are moving to Google Apps for education very soon. I was just wondering if lawfully it's ok for the school to store sensitive data on Google drive as we have unlimited storage. It would make sense and save the school a ton of money so would this be ok to do?

 

Thanks

[fairm010]

Google Apps for Education hosts its data within the EU so should be ok. What if you internet link goes down is the main thing?

 

*Cringed at thread title. I hate that buzzword*

[SHimmer45]

I believe there are changes coming which in affect mean that schools are responsible for data stored in the cloud.

 

local storage still has its place in schools and imo is still relevant and important, decent storage depending on your needs doesnt always mean £££ need to be spent

as others have said your internet connection will need to be rock solid if everything is stored in "the cloud"

Edited January 15, 2015 by SHimmer45

[Joanne]

Just make staff aware that passwords must be complex and secure. If you have a reliable internet connection then go for it. I wouldn't be able to do that on account of having piss poor radio internet.

[abillybob]

Google Apps for Education hosts its data within the EU so should be ok. What if you internet link goes down is the main thing?

 

*Cringed at thread title. I hate that buzzword*

 

That's happened once every year on average and normally for no longer than 3 hours. I'm sure we'll be ok RE the internet going down.

But if and when it does go down the teachers will need a backup plan until it comes back up. For the sake of not having to buy another server, no backups needed, we're going into Google's eco system anyway etc.... it all seems the right thing to do.

 

Ultimately it'll make my job a lot easier and will save ££££ for the school.

[IrritableTech]

Unless things have changed (I'd love to please see a link if it has) I don't think Google guarantee where your data will be held. They do however encypt everything now, are on the Safe Harbor list and have completed an exercise to show adequate data safeguards - enough so the DFE have published the self assessment. If your school is happy with all of that, and you ensure your ICO entry states that data may be kept outside of the EEA, then it should be ok. Your school must go through the risk assessment, and shouldn't just take all of the above as approval.

 

After the legal side - bandwidth and resilience would be the main stumbling block. Then you need to think about the usability of using such a service over local file management.

 

Google self assessment regarding Data Protection - https://www.gov.uk/government/publications/cloud-software-services-and-the-data-protection-act

Edited January 15, 2015 by IrritableTech

[Harry_Small_]

Are you using their email solution as well?

[abillybob]

Thank you everyone for your help. I have contacted Google direct and asked them these three questions:

1. Would THEY deem it ok for us to store sensitive information on their Google Drive services and can they ensure the integrity and security of their own systems?

2. Where is the data stored when storing files to Google drive? Is it stored within the EU?

3. Do they abide by all EU laws and regulation when hosting data for educational establishments?

 

Are you using their email solution as well?

We will soon be moving away from county and using their email services as well. Why you ask?

 

After the legal side - bandwidth and resilience would be the main stumbling block. Then you need to think about the usability of using such a service over local file management.

 

Thankyou for your post it was really helpful. The only worry for me at the moment is our bandwidth we only have a 20mbps connection (which was a lot better than before) although when uploading media such as Music and Videos to Google drive it may provide a struggle. Has anyone else used Google Drive in this way and can tell me about their experiences when streaming a lot of media store on there?

 

We seems to always be able to stream music from things like spotify and videos from youtube ok so I would have thought doing the same from Google drive should be ok?

Edited January 15, 2015 by abillybob

[JRowley]

20Mbps? You would max out your connection with a handful of 1080p YouTube videos, I would definitely not be considering moving away from local storage on your connection, a minimum of 50Mbps(if not 100Mbps) at least before even thinking about it. You would need to implement some serious QoS and bandwidth limits/balancing to ensure file availability at all times.

 

I personally haven't done this with Google Drive, or any other forms of cloud storage.

 

Edit: To be fair I don't know how big your school is, so perhaps I'm being abit overly critical, certainly at my school this would be the situation (1200 students, 150 staff)

Edited January 15, 2015 by JRowley

[abillybob]

20Mbps? You would max out your connection with a handful of 1080p YouTube videos, I would definitely not be considering moving away from local storage on your connection, a minimum of 50Mbps(if not 100Mbps) at least before even thinking about it. You would need to implement some serious QoS and bandwidth limits to ensure file availability at all times.

 

I personally haven't done this with Google Drive, or any other forms of cloud storage.

 

But my point is we are a primary school with around 50 members of staff and YouTube is only accessed every so often. The videos stored locally on our internal servers are also only ever accessed ever so often so the odd one or two videos (and remember we don't record at 1080p everytime) being streamed on rare occasions shouldn't really effect us.

 

The main files in use are mainly notebook files and office documents which when looking at Notebook files could be downloaded from Google drive onto their 1GB home drives to load up from and then deleted again.

We'd obviously still need some local storage, but backups and mass storage wouldn't have to be a problem anymore and we could get rid of our remote access applications as everything anyone would need would be on Google drive.

 

Hmm I just can't make this go wrong in my head provided Google take the right steps in ensuring their systems are secure.

[mjk]

Hello,

 

The DFE guidance for cloud storage is here:

https://www.gov.uk/government/publications/cloud-software-services-and-the-data-protection-act

 

and Googles response is here:

https://drive.google.com/a/uctc.org.uk/folderview?id=0B4froD7RGVqtaFlKc3VnTHF0THc&usp=sharing#

 

The point about storing data is addressed by Google "In accordance with ICO guidance (goo.gl/ppoe4H) regarding the transfer of personal data outside of the EEA, Google offers both 1) participation in the US-EU (and Switzerland) Safe Harbor framework and 2) model contract clauses as means of meeting the adequacy and security requirements of the European Commission’s Data Protection Directive, thus negating the need to limit the transfer of personal data outside the EEA. As such, Google does not limit the transfer of personal data outside the EEA."

 

 

With respect to bandwidth: The bandwidth usage is not typically that high for Google apps - Storing traditional documents on local storage usually uses more bandwidth but Google apps is quite bandwidth low as you are only making changes to documents on the cloud. Copying full documents both ways would use more bandwidth. Our school currently has 2000 staff/students using Google Apps storage (almost, but not entirely exclusively) and typically uses 80Mb/s. A redundant line is more important.

[LeMarchand]

Hmm I just can't make this go wrong in my head provided Google take the right steps in ensuring their systems are secure.

 

Bait and switch. I just can't believe that when enough people have switched over to Cloud storage that the various providers aren't going to start charging heavily. Plus, I wouldn't trust Google not to data mine the stored documents - maybe not for direct use, but certainly for behavioural study.

[pcstru]

We are moving to Google Apps for education very soon. I was just wondering if lawfully it's ok for the school to store sensitive data on Google drive as we have unlimited storage.

As well as the safe harbour issue, you need to consider :

 

1. Data access & control. DPA says access to personal data should be controlled. People should not have access to data they do not need. Google essentially delegates access control to those who have access (i.e. you have a document, you control the sharing of that). Is that an appropriate mechanism for sensitive personal data?

2. Data retention. When staff leave what happens to data stored on their Google Drive, how does the organisation retain access to it? Is such data well managed? When you end up with 10 "Year 7 results" spreadsheets, which one is definitive?

3. Subject access requests. When data is spread over many user accounts, how can you comply with subject access requests?

 

That's probably not an exhaustive list either!

[JRowley]

Sorry, as in my edit I didn't know what size your school was, you might be able to get away with it on a 20Mbps connection at your school, but it's still a bit risky in my view. The curriculum may change to focus more on videos for example, going forward file sizes are likely to increase as will bandwidth demands. It would only take one member of staff to decide that they really need to download X big file to cripple you.

 

In my view cloud storage (due in part to our infrastructure) is still at the stage where it is a supplement, not a large scale replacement.

[Meldrew]

Without trying to hijack the thread, what backup facilities are in place when using the cloud. We (not using the cloud currently) have regular occasions of 'I deleted some/all of my files' and 'I accidentally overwrote my 100 page document with a blank word document'. Does google allow you to restore data back in this fashion?

 

Meldrew

[abillybob]

Thank you again all. Wow really pleased with all these reply's there helping me gain a better understanding on the whole subject.

 

So RE @LeMarchand @pcstru would it be a better plan then to have our own lets say 20GB share that's mapped to all clients as normal but is there to only hold all sensitive data such as pupil reports, SEN stuffs etc... and have everything else sitting on Google's cloud. Would this be a better and easier way of making sure we are in compliance with EU laws and guidelines? Or would it still be a problem as photo's of the children, children work etc... would be on Google Drive? But then if the case is it will still be a problem then surely it means that whenever your emailing people data it would have the same implications?

@JRowley Your input is most appreciated, it is a risk I do understand that but at the moment when storing files, having on-site and off site backups of everything, buying a remote software package so staff can access files, not to mention the electricity bill of having an additional 2 file storing servers... blah blah. It would be saving the school around £6000 a year in the IT budget if we could move mainly to cloud storage. Hmmm is it a risk worth having that the bandwidth could drop once in a blue moon. I'm not sure yet.

[pcstru]

So RE @LeMarchand @pcstru would it be a better plan then to have our own lets say 20GB share that's mapped to all clients as normal but is there to only hold all sensitive data such as pupil reports, SEN stuffs etc... and have everything else sitting on Google's cloud. Would this be a better and easier way of making sure we are in compliance with EU laws and guidelines? Or would it still be a problem as photo's of the children, children work etc... would be on Google Drive? But then if the case is it will still be a problem then surely it means that whenever your emailing people data it would have the same implications?

My personal view is that Google should be used for delivery of curriculum materials to/from students and communication/collaboration with/between students. Personal and Sensitive Personal data should be controlled and managed within the confines of the school network and access permissions to sensitive data should be controlled by a central authority not widely delegated.

 

However, a big part of the problem is human, not technical and when you open up a facility like Goggle, teachers tend to start using it as it suits them. Even with good policy/procedure, regular communications, training etc, the boundaries tend to slip. I'm not sure there is a good answer to this. If I wasn't losing sleep over other matters, it would probably niggle at my nightly slumbers, somewhat.

[LeMarchand]

So RE @LeMarchand @pcstru would it be a better plan then to have our own lets say 20GB share that's mapped to all clients as normal but is there to only hold all sensitive data such as pupil reports, SEN stuffs etc... and have everything else sitting on Google's cloud. Would this be a better and easier way of making sure we are in compliance with EU laws and guidelines? Or would it still be a problem as photo's of the children, children work etc... would be on Google Drive? But then if the case is it will still be a problem then surely it means that whenever your emailing people data it would have the same implications?

 

Re the legal side, I don't know: my head teachers have yet to show any interest in cloud storage beyond document sharing so never looked into it. I know that our LEA has a secure channel set up for emailing confidential data and that we at least make an effort when sending data outside the LEA (e.g. to school photographers) to use some sort of password protection. (When I say "we" I mean the admin staff who ask me for advice - it wouldn't surprise me if all sorts of confidential data is shared willy-nilly by staff who should know better).

[edutech4schools]

We use Google and it seems a few poster have not.

 

1. Data access & control. DPA says access to personal data should be controlled. People should not have access to data they do not need. Google essentially delegates access control to those who have access (i.e. you have a document, you control the sharing of that). Is that an appropriate mechanism for sensitive personal data?2. Data retention. When staff leave what happens to data stored on their Google Drive, how does the organisation retain access to it? Is such data well managed? When you end up with 10 "Year 7 results" spreadsheets, which one is definitive?

3. Subject access requests. When data is spread over many user accounts, how can you comply with subject access requests?

 

If you had used Google Apps you would not be posting these questions as they do not make sense. It's possible to block files being shared outside the domain, Data retention is not an issue for a Google Apps Admin user etc.

 

Lots of schools and even local authorities are using Google Apps and have been for many years. Not saying do not plan etc but nobody would be using a system if these issues had not already been sorted.

[edutech4schools]

Sorry if my post above was a bit out of character. been one of those days.

[pcstru]

We use Google and it seems a few poster have not.

Lots of schools and even local authorities are using Google Apps and have been for many years. Not saying do not plan etc but nobody would be using a system if these issues had not already been sorted.

Sorry, but that is just not true. We do use Google. I have raised the issues and no one had satisfactory answers to them, we were simply instructed to carry on with heads firmly in the sand. In fact you statement was pretty much trotted out - "other's wouldn't be doing it if it wasn't OK" (which is lemming like behaviour). There was even a thing done by (ISTR) the OU which was a kind of indemnity you could buy into (where they had apparently done due-dilligence), after which Google quietly admitted to mining education gmail as part of their advertising (something else everyone, including people here denied was happening).

 

Google have introduced features to alleviate some of the concerns but not all and as I said, many of the remaining issues are human ones, not specifically technical.

[mjk]

Sorry, but that is just not true. We do use Google. I have raised the issues and no one had satisfactory answers to them, we were simply instructed to carry on with heads firmly in the sand. In fact you statement was pretty much trotted out - "other's wouldn't be doing it if it wasn't OK" (which is lemming like behaviour). There was even a thing done by (ISTR) the OU which was a kind of indemnity you could buy into (where they had apparently done due-dilligence), after which Google quietly admitted to mining education gmail as part of their advertising (something else everyone, including people here denied was happening).

 

Google have introduced features to alleviate some of the concerns but not all and as I said, many of the remaining issues are human ones, not specifically technical.

 

Google satisfied the cabinet office who are now using Google apps for education and they also have the OK from the Department of Education for use in schools and they meet all of their checklists.

I think if the advice from the Government is that it is ok we can pretty much agree that it isn't just "lemming behaviour"

[jmak]

As well as the safe harbour issue, you need to consider :

 

1. Data access & control. DPA says access to personal data should be controlled. People should not have access to data they do not need. Google essentially delegates access control to those who have access (i.e. you have a document, you control the sharing of that). Is that an appropriate mechanism for sensitive personal data?

2. Data retention. When staff leave what happens to data stored on their Google Drive, how does the organisation retain access to it? Is such data well managed? When you end up with 10 "Year 7 results" spreadsheets, which one is definitive?

3. Subject access requests. When data is spread over many user accounts, how can you comply with subject access requests?

 

That's probably not an exhaustive list either!

 

There are answers to all of the questions raised in the thread - whether you trust the source is a different matter. A proper risk assessment for your organisation is essential. You would also need to think about how to use it - seeing it as a direct replacement for an onsite fileserver would both open you up to risks and miss some of the potential benefits.

 

Fwiw, my answers to the above:

 

1. IIRC the ICO guidance is that anything IL3 and above should have access controlled by 2 factor authentication. GAFE does support that, but personally I won't be encouraging storing our documents classified as confidential personal on Google drive. The admin console allows you to prevent users from making documents public, so they could share inappropriately internally - just like now. Or download it and email it - just like now.

 

2. When you delete a user in the admin console, it asks you whether you want to keep a copy and delegate authority to someone else. You can include files that the user didn't share with anyone. And does your current system prevent the creation of multiple versions of what should be a definitive document?

 

3. I don't know! Although the search facility is quite good...

 

pcstru is right - there is a host of questions to ask. I'm trying to move towards making more use of GAFE and I hope it can save us cash and at the same time offer significant benefits to users, it but it won't be a leap with both feet.

 

WRT bandwidth use and resilience, if you use the desktop app, you can sync files locally, so you're not totally dependent on internet connectivity to work.

 

And the question of whether Google trawl your data? My hunch is that it's not very likely after they held their hands up when US students took out a class action against them. Their T&Cs are pretty clear now.

 

Just my thoughts....

[Stuclark]

Saying "Google have the OK from the Department for Education for use in schools" is not the same as saying "it's perfectly safe, secure, and a good idea to put all your sensitive data on someone else's servers, under their control, with no control over where that data is stored or what is done to it".

 

OK, so that second statement may be a little over the top, but that's the consideration - as soon as your data is on a cloud, if that cloud is not one you own / have built, then you ultimately don't have full control over that data.

 

As has been said above, this may well be absolutely fine for curriculum data as the chances are that data is not going to be confidential and the same content may well be publicly available elsewhere (i.e. online textbooks), but it certainly *isn't* fine to put sensitive, security dependent data on what is essentially a public cloud.

 

We have looked at cloud storage for some of our data, and while we are going to use it, it is going to be only for students' data and for non-sensitive data that the teachers wish to access at the same time (a-la Sharepoint). The rest of our data is remaining in-house; and our sensitive data isn't even going on a system such as Firefly which would allow authorised access from outside our building.

 

... Also, don't under-estimate your backup / restore requirements - Microsoft (via Office 365) were able to offer us only a 90 day data retention period - for staff emails this is simply not good enough (by our estimates we'd need 15 years to be fully compliant with the letter of UK law), and what are you going to do when x or y student says "can you get that document back I deleted last year?" ... its simply not possible...

[abillybob]

Saying "Google have the OK from the Department for Education for use in schools" is not the same as saying "it's perfectly safe, secure, and a good idea to put all your sensitive data on someone else's servers, under their control, with no control over where that data is stored or what is done to it".

 

OK, so that second statement may be a little over the top, but that's the consideration - as soon as your data is on a cloud, if that cloud is not one you own / have built, then you ultimately don't have full control over that data.

 

From a business perspective it would make no sense for Google to do any wrongs with our files such as passing them on or deleting them. Reasons being is because this is self suicide when it comes to business. Schools would turn away from their services and use something else and after speaking with Google the whole reason it seems to be free is so that you use their eco-system with all of your staff and students.

 

This allows people to get used to it and in effect are more likely to use Google services than any other so it's a win, win. But I acknowledge there is always a risk, but isn't there a risk with every service you use even one that's on your internal servers.... it could all still be hacked. Where would you rather files be stored on Google Drive or on a USB pen to be lost as staff do so no matter what you tell them.

 

There's a lot of for's and a lot of against, if it comes down to it ill make a 10GB share where all confidential and sensitive info gets stored on our internal servers and the rest is on Google Drive.

 

Have to get the idea past the head and governors first though which may be a challenge trying to convince them.