Cloudy But Warm: What You Need to Know About Cloud Before You Take the Plunge – Part 1

DevOps trends 2016 CSC Blogs

As life sciences companies come under pressure to cut costs and simplify how data is shared, they are seeing the cloud as an opportunity to manage enterprise-wide information. The industry however, has been reluctant to move to the cloud for both IT and business reasons.

By Dawn Waite, Manager, Life Sciences in the Cloud

There are benefits to both sides of the enterprise in moving to the cloud. The business case is well understood: having clear, consistent information available in a way that simplifies data exchange. For IT, it means removing day-to-day management of solution tool sets, allowing IT to focus on other valuable tasks, such as delivering desktop consistency to the users.

That’s not to say companies should rush blindly into the cloud, because there are some considerations before adopting a cloud solution.

Over the next few months, I will be writing a series of blogs aimed at exploring key considerations for adopting a cloud solution.

Risk Management – How will validation and compliance be handled?

Let’s start with an issue that’s almost always one of the top concerns for life sciences companies: compliance.

Invariably, life sciences business and IT leaders want to know how, given the regulated nature of the industry, they can move to the cloud comfortably and ensure they are compliant. This is a very valid question. While there are no formal guidelines from FDA on cloud, companies should adhere to 21 CFR Part 11 requirements and ensure that both qualification and validation is of the highest standards, such as a GAMP 5 approach.

You need to qualify your infrastructure to ensure it’s doing what it says it is. So the question is: Does your vendor have a process in place to be able to handle that whole compliance? Are there clear documented processes and deliverables for system validation and infrastructure qualification? While most people are aware of this, companies are often nervous about handing off responsibility for the infrastructure piece to a cloud vendor. And it’s fair to say that not all cloud vendors understand it.

You might be attracted to what appear to be quick and easy cloud solutions. However, if there aren’t the necessary processes and documentation to support the whole qualification and validation process, this puts you at risk, since your regulatory solutions will be sitting on infrastructure that could potentially fail an audit.

Other considerations include processes surrounding change management. While the system might be set up in a compliant solution to begin with, if you’re in the cloud you need that to be maintained throughout its life, and if anything changes you need to ensure those changes meet compliance requirements. My advice to clients is that whenever there is a formal change control, a process should be followed with an assessment of whether that change needs to go through any sort of validation. That way if an audit takes place you’re assured of being completely compliant.

When entering a cloud contract, it is the client that needs to ensure that the vendor can demonstrate they have an effective process and hence, regular audits will be required. It will also need to be established whether this will require additional costs to the service itself or that an audit process is included. What I recommend to clients is to determine what your vendor offers in terms of handling annual audits, as well as whether they engage independent auditors to assess their data centers.

Disentanglement – What happens if I want to move my system?

One issue I consider to be crucial, but that people don’t always think about, is disentanglement. Let’s face it, in today’s businesses, things change and you should be prepared for all eventualities. The problem is, if this isn’t part of an agreement with your vendor, you could end up unable to extricate yourself, or you might be unable to get your data out. In that case, you might be forced to undertake a manual process to get your data out, which is extremely costly.

It’s important to understand that when you are looking to go into the cloud or an IT managed service environment, things can change. To use a specific example, recently a client went through an acquisition, and the decision was made to go to an on-premise solution. As it so happened, both the companies were CSC clients, but one had been on-premise and one in a cloud solution. Because we have agile systems and processes in place, the job of moving data to an on-premise solution was quick and straightforward. But that wouldn’t necessarily always be the case with every cloud vendor.

The approach we recommend is inclusion of a Provisions of Disentanglement. That’s a framework of “what happens if …”, and it defines where the responsibilities lie, what the vendor would need to do to extract a client’s data, who needs to be involved, and what timescale you are likely looking at. While this can’t be definitively stated, simply because you don’t have that information in advance, find out what the options are, the types of personnel that would be needed, and the likely daily rate involved. It’s really about having an understanding of what needs to happen to get your data out, and most importantly, that you can!

Seeing the Full Picture

Over the coming months, I’ll explore other areas companies need to consider before entering into a cloud agreement.

I will also be presenting on this topic at our Transform Conference, which is aimed at users of our Life Sciences software products and business process services. Transform takes place September 27 – October 1, 2015 in Orlando, Florida. More information on the Transform Conference can be found at http://www.csc.com/client_conference.

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