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CFPB Report: 2014-IT-C-016 September 30, 2014

Audit of the CFPB’s Acquisition and Contract Management of Select Cloud Computing Services

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Summary of Recommendations

OIG Report No. 2014-IT-C-016

Rec. no. Report page no. Recommendation Responsible office
1 5 Ensure that an alternatives and cost analysis is conducted to inform the selection of cloud computing service providers and models. Office of the Chief Information Officer
2 7 Assess the costs and benefits of negotiating post-award agreements with Amazon.com and Deloitte to include clauses for Inspector General information access, the conduct of forensic investigations and electronic discovery, and penalties for noncompliance with contract and service-level agreement terms, as appropriate. Office of the Chief Information Officer
3 7 Ensure that the guidance used to develop contracts and service-level agreements with cloud service providers references Federal Acquisition Regulation requirements and best practice contract clauses for information access, conduct of forensic investigations and electronic discovery, and penalties for noncompliance, as appropriate. Office of the Chief Information Officer
4 7 Ensure that future CFPB contracts for cloud computing services include Federal Acquisition Regulation requirements and best practice clauses for information access, the conduct of forensic investigations and electronic discovery, and the assessment of penalties for noncompliance with contract and service-level agreement terms. Office of the Chief Information Officer