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Higher ed: GLBA is the new
four-letter
word, but it's not as bad as you think

09.10.19

Editor’s note: If you are a higher education CFO, CIO, CTO or other C-suite leader, this blog is for you.

The Gramm-Leach-Bliley Act (GLBA) has been in the news recently as the Federal Trade Commission (FTC) has agreed to extend a deadline for public comment regarding proposed changes to the Safeguards Rule. Here’s what you need to know.

GLBA, also known as the Financial Modernization Act, is a 1999 federal law providing rules to financial institutions for protecting consumer information. Colleges and universities fall under this act because they conduct financial activities (e.g., administration of financial aid, loans, and other financial services).

Under the Safeguards Rule financial Institutions must develop, implement, and maintain a comprehensive information security program that consists of safeguards to handle customer information.

Proposed changes

The FTC is proposing five modifications to the Safeguards Rule. The new act will:

  • Provide more detailed guidance to impacted institutions regarding how to develop and implement specific aspects of an overall information security program.
  • Improve the accountability of an institution’s information security programs.
  • Exempt small business from certain requirements.
  • Expand the definition of “financial institutions” to include entities engaged in activities that the Federal Reserve Board determines to be incidental to financial activities.
  • Propose to include the definition of “financial institutions” and related examples in the rule itself rather than cross-reference them from a related FTC rule (Privacy of Consumer Financial Information Rule).

Potential impacts for your institution

The Federal Register, Volume 84, Number 65, published the notice of proposed changes that once approved by the FTC would add more prescriptive rules that could have significant impact on your institution. For example, these rules would require institutions to:

  1. Expand existing security programs with additional resources.
  2. Produce additional documentation.
  3. Create and implement additional policies and procedures.
  4. Offer various forms of training and education for security personnel.

The proposed rules could require institutions to increase their commitment in time and staffing, and may create hardships for institutions with limited or challenging resources.

Prepare now

While these changes are not final and the FTC is requesting public comment, here are some things you can do to prepare for these potential changes:

  • Evaluate whether your institution is compliant to the current Safeguards Rule.
  • Identify gaps between current status and proposed changes.
  • Perform a risk assessment.
  • Ensure there is an employee designated to lead the information security program.
  • Monitor the FTC site for final Safeguard Rules updates.

In the meantime, reach out to us if you would like to discuss the impact GLBA will have on your institution or if you would like assistance with any of the recommendations above. You can view a comprehensive list of potential changes here.

Source: Federal Trade Commission. Safeguards Rule. Federal Register, Vol. 84, No. 65. FTC.gov. April 4, 2019. https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/safeguards-rule

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“We have engaged BerryDunn for the performance of two NIST/GLBA risk assessments over the last two years. Each time the consultants were professional, knowledgeable, and provided great insight with specific knowledge to the higher education industry.”  

- Alicia Porter, Ohio University

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Cloud services are becoming more and more omnipresent, and rapidly changing how companies and organizations conduct their day-to-day business.

Many higher education institutions currently utilize cloud services for learning management systems (LMS) and student email systems. Yet there are some common misunderstandings and assumptions about cloud services, especially among higher education administrative leaders who may lack IT knowledge. The following information will provide these leaders with a better understanding of cloud services and how to develop a cloud services strategy.

What are cloud services?

Cloud services are internet-based technology services provided and/or hosted by offsite vendors. Cloud services can include a variety of applications, resources, and services, and are designed to be easily scalable, cost effective, and fully managed by the cloud services vendor.

What are the different types?

Cloud services are generally categorized by what they provide. Today, there are four primary types of cloud services:

Cloud Service Types 

Cloud services can be further categorized by how they are provided:

  1. Private cloud services are dedicated to only one client. Security and control is the biggest value for using a private cloud service.
  2. Public cloud services are shared across multiple clients. Cost effectiveness is the best value of public cloud services because resources are shared among a large number of clients.
  3. Hybrid cloud services are combinations of on-premise software and cloud services. The value of hybrid cloud services is the ability to adopt new cloud services (private or public) slowly while maintaining on-premise services that continue to provide value.

How do cloud services benefit higher education institutions?

Higher education administrative leaders should understand that cloud services provide multiple benefits.
Some examples:

Cloud-Services-for-Higher-Education


What possible problems do cloud services present to higher education institutions?

At the dawn of the cloud era, many of the problems were technical or operational in nature. As cloud services have become more sophisticated, the problems have become more security and business related. Today, higher education institutions have to tackle challenges such as cybersecurity/disaster recovery, data ownership, data governance, data compliance, and integration complexities.

While these problems and questions may be daunting, they can be overcome with strong leadership and best-practice policies, processes, and controls.

How can higher education administrative leaders develop a cloud services strategy?

You should work closely with IT leadership to complete this five-step planning checklist to develop a cloud services strategy: 

1. 

Identify new services to be added or consolidated; build a business case and identify the return on investment (ROI) for moving to the cloud, in order to answer:

• 

What cloud services does your institution already have?

• 

What cloud services does your institution already have?

• 

What services should you consider replacing with cloud services, and why?

• 

How are data decisions being made?

2. 

Identify design, technical, network, and security requirements (e.g., private or public; are there cloud services already in place that can be expanded upon, such as a private cloud service), in order to answer:

• 

Is your IT staff ready to migrate, manage, and support cloud services?

• 

Do your business processes align with using cloud services?

• 

Do cloud service-provided policies align with your institution’s security policies?

• 

Do you have the in-house expertise to integrate cloud services with existing on-premise services?

3. 

Decide where data will be stored; data governance (e.g., on-premise, off-premise data center, cloud), in order to answer:

• 

Who owns the data in the institution’s cloud, and where?

• 

Who is accountable for data decisions?

4. 

Integrate with current infrastructure; ensure cloud strategy easily allows scalability for expansion and additional services, in order to answer:

• 

What integration points will you have between on-premise and cloud applications or services, and can the institution easily implement, manage, and support them?

5. 

Identify business requirements — budget, timing, practices, policies, and controls required for cloud services and compliance, in order to answer:

• 

Will your business model need to change in order to support a different cost model for cloud services (i.e., less capital for equipment purchases every three to five years versus a steady monthly/yearly operating cost model for cloud services)?

• 

Does your institution understand the current state and federal compliance and privacy regulations as they relate to data?

• 

Do you have a contingency plan if its primary cloud services provider goes out of business?

• 

Do your contracts align with institutional, state, and federal guidelines?

Need assistance?

BerryDunn’s higher education team focuses on advising colleges and universities in improving services, reducing costs, and adding value. Our team is well qualified to assist in understanding the cloud “skyscape.” If your institution seeks to maximize the value of cloud services or develop a cloud services strategy, please contact me.

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Cloud services 101: An almanac for higher education leaders

We’ve all heard stories about organizations spending thousands on software projects, such as Enterprise Resource Planning (ERP), Electronic Health Record (EHR), or Student Information Systems (SIS) that take longer than expected to implement and exceed original budgets. One of the reasons this occurs is that organizations often don’t realize that purchasing a large, Commercial Off-The-Shelf (COTS) enterprise system is a significant undertaking. If the needs aren’t sufficiently defined, there can be many roadblocks, including implementation delays, increased cost, scope creep, and ultimately, unsatisfactory results (delayed or unfinished projects and cost overruns).

These systems are complex, and implementation efforts impact both internal and external stakeholders. Procurement often requires participation from different departments, each with unique goals and perspectives. Ignore these perspectives at your own peril. Here are key questions to consider for making the best buying decision:

  1. Should we purchase software that similar organizations have purchased?
    As vendor consolidation has diminished the number of distinct COTS systems available, this question is increasingly common. Following this approach is similar to deciding to buy the car that your neighbor did, because they seem satisfied. How can you be sure that the systems purchased by similar organizations will meet your needs, particularly if your needs are undefined? One way to identify your organization’s needs—and to avoid costly mistakes down the road—is to identify requirements during the procurement process.

  2. What are the functional and technical requirements of the system?Requirements are details that help describe a software system. There are two types of requirements and you need to understand and review both:

    Functional requirements. These define specific functions of a system to meet day-to-day needs of an organization or department. They describe the necessary system capabilities that allow users to perform their jobs. For example, “The vendor file must provide a minimum of four (4) remit-to addresses.” Functional requirements may also define the mandated state or federal capabilities required of a system, such as the ability to produce W-2 or 1099 forms.

    Technical requirements. These requirements identify criteria used to judge the operation of a system, rather than specific behaviors. They can be requirements that define what database the system must support. For example, “The system must support use of the client preferred database.” They may also describe security capabilities of the system, the ability to import or export data, or the ease of use and overall end-user interface.

  3. Who should help define and document requirements for the new enterprise system?

    When it comes to documenting and revising requirements, work with your IT staff; incorporating technology standards into a set of requirements is a best practice. Yet it is also necessary to seek input from non-IT individuals, or business process owners from multiple departments, those who will use and/or be affected by the new software system.

    Help these individuals or groups understand the capabilities of modern software systems by having them visit the sites of other organizations, or attend software industry conferences. You should also have them document the current system’s deficiencies. As for those in your organization who want to keep the current system, encourage their buy-in by asking them to highlight the system’s most valuable capabilities. Perspectives from both new system supporters and those not so eager to change will help build the best system.
     
  4. When do you revise enterprise system requirements?
    It is always important to begin the software procurement process with a documented set of requirements; you need them to identify the best solution. The same goes for the implementation process where vendors use the requirements to guide the setup and configuration of the new system. But be prepared to revise and enhance requirements when a vendor solution offers an improved capability or a better method to achieve the results. The best way to approach it is to plan to revise requirements constantly. This enables the software to better meet current needs, and often delivers enhanced capabilities.

Be sure to document system requirements for an efficient process

There may be thousands of requirements for an enterprise system. To make the procurement process as efficient as possible, continually define and refine requirements. While this takes time and resources, there are clear benefits:

  • Having requirements defined in an RFP helps vendors match the capabilities of their software systems to your organization’s needs and functional expectations. Without requirements, the software procurement and selection process has little framework, and from a vendor perspective becomes a subjective process — making it hard to get consistent information from all vendors.
  • Requirements help determine specific tasks and activities to address during the implementation process. While applications can’t always meet 100% of the requested functionalities, it’s important to emphasize the requirements that are most important to users, to help find the system that best meets the needs of your organization.
  • Requirements prove valuable even after implementation has begun, as they can help you test your system to make sure the software meets your organization’s particular needs before production use of the new system.

Our experienced consultants have led many software procurement projects and have firsthand knowledge about the challenges and opportunities associated with purchasing and implementing systems large and small. BerryDunn maintains an active database of requirements that we continually enhance, based on work performed for various clients and on technological advancements in the marketplace. Please contact us and we can help you define your requirements for large software system purchases.

Article
Four questions to ask before purchasing an enterprise software system

Read this if your organization is planning on upgrading or replacing an enterprise technology system.

It can be challenging and stressful to plan for technology initiatives, especially those that involve and impact every area of your organization. Common initiatives include software upgrades or replacements for:

  • Financial management, such as Enterprise Resource Planning (ERP) systems
  • Asset management systems
  • Electronic health records (EHR) systems
  • Permitting and inspections systems

Though the number of considerations when planning enterprise technology projects can be daunting, the greatest mistake you can make is not planning at all. By addressing just a few key areas, you can avoid some of the most common pitfalls, such as exceeding budget and schedule targets, experiencing scope creep, and losing buy-in among stakeholders. Here are some tips to help you navigate your next project:

Identify your IT project roles and resources

While most organizations understand the importance of identifying project stakeholder groups, it is often an afterthought. Defining these roles at the outset of your project helps you accurately estimate the work effort.

Your stakeholder groups may include:

  • An executive sponsor
  • A steering committee
  • A project manager
  • Functional leads
  • A technical team

Once you’ve established the necessary roles, you can begin reviewing your organization’s resources to determine the people who will be available to fill them. Planning for resource availability will help you avoid delays, minimize impact to regular business processes, and reduce the likelihood of burnout. But this plan won’t remain static—you can expect to make updates throughout the project.

Establish clear goals and objectives to keep your technology project on track

It’s important that an enterprise technology project has established goals and objectives statements. These statements will help inform decision-making, provide benchmarks for progress, and measure your project’s success. They can then be referenced when key stakeholders have differing perspectives on the direction to take with a pending decision. For example, if the objective of your project is to reduce paper-based processes, you may plan for additional computer workstations and focus technical resources on provisioning them. You’ll also be able to measure your success in the reduction of paper-based tasks.

Estimate your IT project budget accurately

Project funding is hardly ever overlooked, but can be complex with project budgets that are either underestimated or estimated without sufficient rationale to withstand approval processes and subsequent budget analysis. You may find that breaking down estimates to a lower level of detail helps address these challenges. Most technology projects incur costs in three key areas:

  • Vendor cost: This could include both one-time software implementation costs as well as recurring costs for maintenance and ongoing support.
  • Infrastructure cost: Consider the cost of any investments needed to support your project, such as data center hardware, networking components, or computing devices.
  • Supplemental resource cost: Don’t forget to include the cost of any additional resources needed for their specialized knowledge or to simply backfill project staff. This could include contracted resources or the additional cost of existing resources (i.e., overtime).

A good technology project budget also includes a contingency amount. This amount will depend on your organization’s standards, the relative level of confidence in your estimates, and the relative risk.

Anticipate the need for change management

Depending on the project, staff in many areas of your organization will be impacted by some level of change during a technology implementation. External stakeholders, such as vendors and the public, may also be affected. You can effectively manage this change by proactively identifying areas of likely change resistance and creating strategies to address them.

In any technology implementation, you will encounter change resistance you did not predict. Having strategies in place will help you react quickly and effectively. Some proven change management strategies include communicating throughout your project, involving stakeholders to get their buy-in, and helping ensure management has the right amount of information to share with their employees.

Maintain focus and stay flexible as you manage your IT project

Even with the most thought-out planning, unforeseen events and external factors may impact your technology project. Establish mechanisms to regularly and proactively monitor project status so that you can address material risks and issues before their impact to the project grows. Reacting to these items as they arise requires key project stakeholders to be flexible. Key stakeholders must recognize that new information does not necessarily mean previous decisions were made in error, and that it is better to adapt than to stick to the initial direction.

Whether you’re implementing an ERP, an EHR, or enterprise human resources or asset management systems, any enterprise technology project is a massive undertaking, involving significant investment and a coordinated effort with individuals across multiple areas of an organization. Common mistakes can be costly, but having a structured approach to your planning can help avoid pitfalls. Our experienced, objective advisors have worked with public and private organizations across the country to oversee large enterprise projects from inception to successful completion.

Contact our software consulting team with any questions.

Article
Planning for a successful enterprise technology project

“The world is one big data problem,” says MIT scientist and visionary Andrew McAfee.

That’s a daunting (though hardly surprising) quote for many in data-rich sectors, including higher education. Yet blaming data is like blaming air for a malfunctioning wind turbine. Data is a valuable asset that can make your institution move.

To many of us, however, data remains a four-letter word. The real culprit behind the perceived data problem is our handling and perception of data and the role it can play in our success—that is, the relegating of data to a select, responsible few, who are usually separated into hardened silos. For example, a common assumption in higher education is that the IT team can handle it. Not so. Data needs to be viewed as an institutional asset, consumed by many and used by the institution for the strategic purposes of student success, scholarship, and more.

The first step in addressing your “big” data problem? Data governance.

What is data governance?

There are various definitions, but the one we use with our clients is “the ongoing and evolutionary process driven by leaders to establish principles, policies, business rules, and metrics for data sharing.”

Please note that the phrase “IT” does not appear anywhere in this definition.

Why is data governance necessary? For many reasons, including:

  1. Data governance enables analytics. Without data governance, it’s difficult to gain value from analytics initiatives which will produce inconsistent results. A critical first step in any data analytics initiative is to make sure that definitions are widely accepted and standards have been established. This step allows decision makers to have confidence in the data being analyzed to describe, predict, and improve operations.
     
  2. Data governance strengthens privacy, security, and compliance. Compliance requirements for both public and private institutions constantly evolve. The more data-reliant your world becomes, the more protected your data needs to be. If an organization does not implement security practices as part of its data governance framework, it becomes easier to fall out of compliance. 
     
  3. Data governance supports agility. How many times have reports for basic information (part-time faculty or student FTEs per semester, for example) been requested, reviewed, and returned for further clarification or correction? And that’s just within your department! Now add multiple requests from the perspective of different departments, and you’re surely going through multiple iterations to create that report. That takes time and effort. By strengthening your data governance framework, you can streamline reporting processes by increasing the level of trust you have in the information you are seeking. Understanding the value of data governance is the easy part/ The real trick is implementing a sustainable data governance framework that recognizes that data is an institutional asset and not just a four-letter word.

Stay tuned for part two of this blog series: The how of data governance in higher education. In the meantime, reach out to me if you would like to discuss additional data governance benefits for your institution.

Article
Data is a four-letter word. Governance is not.

As a new year is upon us, many people think about “out with the old and in with the new”. For those of us who think about technology, and in particular, blockchain technology, the new year brings with it the realization that blockchain is here to stay (at least in some form). Therefore, higher education leaders need to familiarize themselves with some of the technology’s possible uses, even if they don’t need to grasp the day-to-day operational requirements. Here’s a high-level perspective of blockchain to help you answer some basic questions.

Are blockchain and bitcoin interchangeable terms?

No they aren’t. Bitcoin is an electronic currency that uses blockchain technology, (first developed circa 2008 to record bitcoin transactions). Since 2008, many companies and organizations utilize blockchain technology for a multitude of purposes.

What is a blockchain?

In its simplest terms, a blockchain is a decentralized, digital list (“chain”) of timestamped records (“blocks”) that are connected, secured by cryptography, and updated by participant consensus.

What is cryptography?

Cryptography refers to converting unencrypted information into encrypted information—and vice versa—to both protect data and authenticate users.

What are the pros of using blockchain?

Because blockchain technology is inherently decentralized, you can reduce the need for “middleman” entities (e.g., financial institutions or student clearinghouses). This, in turn, can lower transactional costs and other expenses, and cybersecurity risks—as hackers often like to target large, info-rich, centralized databases.

Decentralization removes central points of failure. In addition, blockchain transactions are generally more secure than other types of transactions, irreversible, and verifiable by the participants. These transaction qualities help prevent fraud, malware attacks, and other risks and issues prevalent today.

What are the cons of using blockchain technology?

Each blockchain transaction requires signature verification and processing, which can be resource-intensive. Furthermore, blockchain technology currently faces strong opposition from certain financial institutions for a variety of reasons. Finally, although blockchains offer a secure platform, they are not impervious to cyberattacks. Blockchain does not guarantee a hacker-proof environment.

How can blockchain benefit higher education institutions?

Blockchain technology can provide higher education institutions with a more secure way of making and recording financial transactions. You can use blockchains to verify and transfer academic credits and certifications, protect student personal identifiable information (PII) while simultaneously allowing students to access and transport their PII, decentralize academic content, and customize learning experiences. At its core, blockchain provides a fresh alternative to traditional methods of identity verification, an ongoing challenge for higher education administration.

As blockchain becomes less of a buzzword and begins to expand beyond the realm of digital currency, colleges and universities need to consider it for common challenges such as identity management, application processing, and student credentialing. If you’d like to discuss the potential benefits blockchain technology provides, please contact me.

Article
Higher education and blockchain 101: It's not just for bitcoin anymore

The late science fiction writer (and college professor) Isaac Asimov once said: “I do not fear computers. I fear the lack of them.” Had Asimov worked in higher ed IT management, he might have added: “but above all else, I fear the lack of computer staff.”

Indeed, it can be a challenge for higher education institutions to recruit and retain IT professionals. Private companies often pay more in a good economy, and in certain areas of the nation, open IT positions at colleges and universities outnumber available, qualified IT workers. According to one study from 2016, almost half of higher education IT workers are at risk of leaving the institutions they serve, largely for better opportunities and more supportive workplaces. Understandably, IT leadership fears an uncertain future of vacant roles—yet there are simple tactics that can help you improve the chances of filling open positions.

Emphasize the whole package

You need to leverage your institution’s strengths when recruiting IT talent. A focus on innovation, project leadership, and responsibility for supporting the mission of the institution are important attributes to promote when recruiting. Your institution should sell quality of life, which can be much more attractive than corporate culture. Many candidates are attracted to the energy and activity of college campuses, in addition to the numerous social and recreational outlets colleges provide.

Benefit packages are another strong asset for recruiting top talent. Schools need to ensure potential candidates know the amount of paid leave, retirement, and educational assistance for employees and employee family members. These added perks will pique the interest of many candidates who might otherwise have only looked at salary during the process.

Use the right job title

Some current school vacancies have very specific job titles, such as “Portal Administrator” or “Learning Multimedia Developer.” However, this specificity can limit visibility on popular job posting sites, reducing the number of qualified applicants. Job titles, such as “Web Developer” and “Java Developer,” can yield better search results. Furthermore, some current vacancies include a number or level after the job title (e.g., “System Administrator 2”), which also limits visibility on these sites. By removing these indicators, you can significantly increase the applicant pool.

Focus on service, not just technology

Each year, institutions deploy an increasing number of Software as a Service (SaaS) and hosted applications. As higher education institutions invest more in these applications, they need fewer personnel for day-to-day technology maintenance support. In turn, this allows IT organizations to focus limited resources on services that identify and analyze technology solutions, provide guidance to optimize technology investments, and manage vendor relationships. IT staff with soft skills will become even more valuable to your institution as they engage in more people- and process-centric efforts.

Fill in the future

It may seem like science fiction, but by revising your recruiting and retention tactics, your higher education institution can improve its chances of filling IT positions in a competitive job market. In a future blog, I’ll provide ideas for cultivating staff from your institution via student workers and upcoming graduates. If you’d like to discuss additional staffing tactics, send me an email.

Article
No science fiction: Tactics for recruiting and retaining higher education IT positions

While new software applications help you speed up processes and operations, deciding which ones will work best for your organization can quickly evolve into analysis paralysis, as there are so many considerations.

Case in point: Software as a Service (SaaS) model
The benefits of the SaaS model, in which a vendor remotely hosts an organization’s applications, are fairly well known: your organization doesn’t have to shell out for costly hardware, the vendor tackles upgrades, backups, data recovery, and security, and you have more time and money to focus on your business goals.

There are multiple factors to look at when determining whether a SaaS solution is right for you. We’ve compiled a list of the top three SaaS considerations:

1. Infrastructure and capacity
Your organization should consider your own people, processes, and tools when determining whether SaaS makes sense. While an on-site solution may require purchasing new technologies, hiring new staff, and realigning current roles and responsibilities to maintain the system, maintaining a SaaS solution may also require infrastructure updates, such as increased bandwidth to sufficiently connect to the vendor's hosting site.

Needless to say, it’s one thing to maintain a solution; it’s an entirely different thing to keep it secure. An on-site hosting solution requires constant security upgrades, internal audits, and a backup system—all of which takes time and money. A SaaS model requires trust in your vendor to provide security. Make sure your potential vendor uses the latest security measures and standards to keep your critical business data safe and secure.

2. Expense
When you purchase major assets—for example, hardware to host its applications—it incurs capital expenses. Conversely, when you spend money on day-to-day operations (SaaS subscriptions), it incurs operating expenses.

You should weigh the pros and cons of each type of expense when considering a SaaS model. On-site upfront capital expenses for hosting hardware are generally high, and expenses can spike overtime when you update the technology, which can be difficult to predict. And don’t forget about ongoing costs for maintenance, software upgrades, and security patches.

In the SaaS model, you spread out operating costs over time and can predict costs because you are paying via subscription—which generally includes costs for maintenance, software upgrades, and security patches. However, remember you can depreciate capital expenses over time, whereas the deductibility of operating expenses are generally for the year you use them.

3. Vendor viability
Finally, you need to conduct due diligence and vet SaaS vendors before closing the deal. Because SaaS vendors assume the responsibility for vital processes, such as data recovery and security, you need to make sure the potential vendor is financially stable and has a sustainable business model. To help ensure you receive the best possible service, select a vendor considered a leader in its market sector. Prepare a viable exit strategy beforehand so you can migrate your business processes and data easily in case you have any issues with the SaaS provider.

You must read—and understand—the fine print. This is especially important when it comes to the vendor’s policies toward data ownership and future migrations to other service providers, should that become necessary. In other words: Make sure you have final say and control over your data.

Every organization has different aspects of their situation to consider when making a SaaS determination. Want to learn more? It’s a snap! Contact the authors: Clark Lathrum and Matthew Tremblay

Article
SaaS: Is it right for you? Making SaaS determinations a snap.