Access Alert | Introducing Iraq’s Cloud Computing Policy

On 20 June 2022, the Iraqi Communications and Media Commission (CMC) published its Draft Cloud Computing Policy. The Policy aims to accelerate digital transformation across Iraq, boost the uptake of cloud services and ensure the protection of government and personal data.

According to the policy, Cloud Service Providers (CSPs) are now required to register their services and obtain a service providers licence from CMC prior to offering cloud services to users within the Iraqi market, including for both the private and public sectors. Moreover, the Policy highlights the costs of obtaining such a licence and the various types of applicable licences depending on the scope of the services provided.

Furthermore, the Policy highlights various obligations on CSPs, including requirements to:

• Protect personal data,
• Report regularly to the CMC;
• Comply with international standards (such as ISO 27001/17/18, PCI DSS, CSA, SOC Type 1 and Type2, COBIT, and NIST CCD); and
• Enable interoperability.

Finally, the Cloud Computing Policy echoes the data classification framework contained in the CMC’s Data Classification Policy, specifying 4 data-classification levels:

• General data and information available to the public.
• Non-sensitive personal data such as, but not limited to, a person’s names, gender age, and job title.
• Sensitive personal data such as, but not limited to, criminal records, court decisions, and contact information.
• Highly sensitive data such as, but not limited to, political documents or sensitive information from military or security entities.

The Draft Cloud Computing Policy represents a significant development in Iraq’s regulatory ecosystem, which still is rather nascent, with little to no regulations guiding CSPs activity in place.  With this policy, however, it is clear that the Iraqi regulator is currently working to expand its regulatory framework to keep pace with digital transformation development.

If you are interested in learning more about Iraq’s Draft Data Classification Policy, require support with submitting comments to the public consultation or engage the CMC, please contact Hussein Abul-Enein, or Anja Engen.