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SUBJECT: Guidance on managing records in cloud computing environments EXPIRATION DATE: ? 1. What is the purpose of this Bulletin? This Bulletin addresses records management considerations in cloud computing environments and is a formal articulation of NARA’s view of agencies’ records responsibilities. As agencies are increasingly piloting and investigating this technology, they must comply with all records management laws, regulations, and policies. 2. How does this Bulletin differ from Frequently Asked Questions About Managing Federal Records In Cloud Computing Environments? NARA issued this FAQ in February 2010 to provide agencies with a basic overview of cloud computing. This Bulletin further expands on that discussion by including more detailed definitions, use of cloud computing in Federal agencies, records management guidelines, and contract language to consider when procuring cloud computing services. 3. What is cloud computing? Simply defined, cloud computing is a technology that allows users to access and use shared data and computing services via the Internet or a Virtual Private Network. It gives users access to resources without having to build infrastructure to support these resources within their own environments or networks. The most authoritative definition is from the National Institute of Standards and Technology (NIST). However, some people have interpreted cloud computing as ―renting‖ storage space on someone else’s servers or hosting a suite of services. Other interpretations include social media, e-mail, and other applications. Social media and cloud-based e-mail services are beyond the scope of this Bulletin. NIST defines cloud computing as ―a model for enabling convenient, on-demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction.‖ (NIST Definition of Cloud Computing, Version 15, 10-07-2009) NIST has identified five essential characteristics of cloud computing:
Draft Bulletin-Cloud Computing On-demand self-service. A consumer can unilaterally provision computing capabilities, such as server time and network storage, as needed automatically without requiring human interaction with each service’s provider. Broad network access. Capabilities are available over the network and accessed through standard mechanisms that promote use by heterogeneous thin or thick client platforms (e.g., mobile phones, laptops, and PDAs). Resource pooling. The provider’s computing resources are pooled to serve multiple consumers using a multi-tenant model, with different physical and virtual resources dynamically assigned and reassigned according to consumer demand. There is a sense of location independence in that the customer generally has no control or knowledge over the exact location of the provided resources but may be able to specify location at a higher level of abstraction (e.g., country, state, or datacenter). Examples of resources include storage, processing, memory, network bandwidth, and virtual machines. Rapid elasticity. Capabilities can be rapidly and elastically provisioned, in some cases automatically, to quickly scale out and rapidly released to quickly scale in. To the consumer, the capabilities available for provisioning often appear to be unlimited and can be purchased in any quantity at any time. Measured Service. Cloud systems automatically control and optimize resource use by leveraging a metering capability at some level of abstraction appropriate to the type of service (e.g., storage, processing, bandwidth, and active user accounts). Resource usage can be monitored, controlled, and reported providing transparency for both the provider and consumer of the utilized service. 4. What are cloud computing service and deployment models? Cloud computing service models refer to how an agency can adopt cloud computing. NIST describes the models as follows: Infrastructure-As-A-Service (IaaS) – Provides computing hardware such as servers, network equipment, and data storage on a scalable basis in the cloud. A common use of IaaS is cloud-based backup and recovery. Platform-As-A-Service (PaaS) – Provides an application development environment that allows users to collaborate, develop, test, deploy, host and maintain applications in the cloud. A common use of PaaS is cloud-based environments for the development of enterprise-level software. Applications-As-A-Service (AaaS)/Software-As-A-Service (SaaS): Provides access to software. Users can log-on from anywhere and have full access to their specific software in the cloud. A common use of SaaS is cloud-based e-mail. Depending upon the users’ needs, and other considerations, cloud computing services are typically deployed using one of the following four models as defined by NIST: Private cloud. A private cloud is operated for a specific organization. It may be managed by the organization or a third party and may exist on premises or off premises. Public cloud. A public cloud is made available to the general public or a large industry group and is owned by an organization selling cloud services.
Draft Bulletin-Cloud Computing Community cloud. A community cloud is an infrastructure shared by several organizations and supports a specific community that has shared concerns (e.g., mission, security requirements, policy, and compliance considerations). It may be managed by the organizations or a third party and may exist on premises or off premises. Hybrid cloud. A hybrid cloud is a composition of two or more clouds (private, community, or public) that remain unique entities but are bound together by standardized or proprietary technology that enables data and application portability.
5. What are Federal agencies doing with cloud computing? Agencies are using cloud computing services in order to achieve benefits such as cost savings, accessibility, scalability, collaboration, and flexibility. For example, an agency dealing with globallydispersed employees needed a rapid solution and deployed a private cloud to share financial data, capture reports, and solve security challenges. Another agency…. While these agencies recognize the commonly understood of data governance and privacy, they are not addressing records management. Concerns that NARA has recognized then lead into next question; Common concerns include: Security and privacy of information in a shared environment that resides outside of agency firewalls Ownership and control of data/infrastructure that does not reside within the agency Difficulty moving data in and out of cloud environments into other systems Guarantee of availability and performance of services when 24/7 access is required Data protection especially for sensitive information Compliance with Federal regulations 6. What are agencies doing to address some of these concerns? Many of the cloud computing concerns deal with privacy and security issues. Vendors might store records on servers located anywhere on Earth as a necessary part of their infrastructure. Because of this, some agencies with security classified documents are creating private clouds that they administer and maintain on agency-owned hardware. Privacy Act, law enforcement needs, HIPAA, and other issues may lead other agencies to create private or community clouds between several agencies. This will obviate some cost savings, but may solve security problems. Other issues deal with portability of the records and long-term accessibility. These can only be resolved through good records management or other data governance practices. If your agency does not have records management policies in place that will address records that are stored in a cloud, your agency must develop data governance policies. At the very least, data governance should address interoperability of computing systems, portability of data (able to move records from one system to another), and information security and access. However, such policies will not address your agency’s compliance with the Federal Records Act and NARA regulations. Cloud computing is evolving; therefore, some of the listed benefits and concerns may change. 3
Draft Bulletin-Cloud Computing
7. What are some of the records management implications associated with cloud computing? Agencies using cloud computing services should be aware of the following records management implications: Many applications do not include record functions or considerations, therefore specific service and deployment models may not meet all of the records management requirements of 36 CFR 1236.1ff (formerly 1234.1) Examples of these requirements include: o Maintaining records in a way that maintains their functionality and integrity throughout the record’s full life cycle o Maintaining links between the records and their metadata o Transfer of archival records to NARA or deletion of temporary records according to NARA-approved retention schedules Depending on the application, vendors of a public cloud or managers of a private cloud may not be able to ensure the complete deletion of records. Records are often stored in more than one cloud location for access and backup. When an agency orders that records be deleted, not every location may take that action. This will complicate an agency’s responsiveness to discovery or FOIA requests. Various cloud architectures lack formal technical standards governing how data is stored and manipulated in cloud environments. This threatens the long-term trustworthiness and sustainability of the data. A lack of portability standards may result in difficulty removing records for recordkeeping requirements or complicates the transition to another environment. Vendors’ terms of services may not sufficiently address requirements in ―Records Management Language for Contracts.‖ Some vendors are beginning to produce records management applications that can be integrated with cloud computing services. These applications may alleviate some of the problems listed above. 8. What records management standards are in place? At this time, there are no records management standards for a cloud computing environment that have been formally adopted. Some agencies are working to fill this void. One agency reported on writing acquisition and transition standards. Other agencies report Information Technology procedures to govern how data is used. In all events, you remain responsible for managing your records in accordance with the Federal Records Act and NARA regulations. Here are some guidelines to help create your agency standards for managing records created, used, or stored in cloud computing environments: Define which copy of the records is your record copy, if the records in the cloud are copies and you are maintaining an identical set elsewhere, then you have no records management responsibilities for the copies. However, the value of records in the cloud may be greater than the other set because of indexing or other reasons. This added value must be included in your agency’s determination of record status; Determine if the records in the cloud are covered under an existing schedule item. If so you will need to establish polices on how those records will be managed, retained, 4
Draft Bulletin-Cloud Computing made available to those authorized to use them, and to either properly delete them at the end of their retention or transfer to NARA if permanent; Schedule any unscheduled records including system documentation, metadata, and related records; Include in your procedures instructions to periodically test transfers of records to other environments, including agency servers, to ensure the records remain portable; Include instructions on how data will be migrated to new formats, operating systems, etc., so that records are readable through their entire life cycles; Maintain knowledge of this rapidly evolving technology, you may learn that a better solution has been developed and that it will fit your needs better; …..
9. What is an agency’s responsibility when dealing with contractors? An agency is always responsible for managing its records whether they reside in a contracted environment or in agency-owned filing cabinets (see 36 CFR 1222.32(4)(b)). If you are dealing with a vendor, your agency must include a records management clause in any contract or similar agreement. Such a clause will explain how the records will be managed or at the very least put a contractor on notice that they must work with you to provide records management and to transfer permanent records to NARA in a manner according to the laws and regulations in place at the time of transfer. The following is a general clause that your agency will need to expand to fit the type of service you plan to use and your specific records management needs: Insert final TOS clause If your agency decides to create or join a private or community cloud, you will need to ensure records management tools are built into the system or include them in agreements among the participating offices or agencies. 10. What else is NARA doing in regards to cloud computing? …. records management implications (44 USC 3303) and risks associated with contracting (36 CFR 1222.32— formerly 1222.48), statutory compliance (44 USC 3301), and data governance. 11. Where do I go for more information? If you need additional information about the contents of this FAQ, please contact ERM@nara.gov.
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