NARA’s FAQ and Bulletin on Managing Federal Records in Cloud Computing Environments

1. NARA’s FAQ and Bulletin onManaging Federal Records inCloud Computing Environments Arian D. Ravanbakhsh Electronic Records Policy Specialist RACO Chicago August 24, 2010

2. Outline • Context/Background re. Cloud Computing • Use scenarios • RM Challenges • Tactics to solve challenges • Intervening at procurement • Questions?

3. NARA Issuances • Frequently Asked Questions About Managing Federal Records In Cloud Computing Environments • February 2010 • http://www.archives.gov/records-mgmt/faqs/cloud.html • Bulletin on Managing Records in Cloud Computing Environments • Due out: ANY DAY NOW • Watch our Blog for updates: • http://blogs.archives.gov/records-express

4. What Is Cloud Computing? • 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)

5. Cloud Computing’s Essential Characteristics/Business Drivers • 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.

6. Cloud Computing – Service Models • Cloud Software as a Service (SaaS) • The capability provided to the consumer is to use the provider’s applications running on a cloud infrastructure. The applications are accessible from various client devices through a thin client interface such as a web browser (e.g., web-based email). The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, storage, or even individual application capabilities, with the possible exception of limited user-specific application configuration settings. • Cloud Platform as a Service (PaaS) • The capability provided to the consumer is to deploy onto the cloud infrastructure consumer-created or acquired applications created using programming languages and tools supported by the provider. The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, or storage, but has control over the deployed applications and possibly application hosting environment configurations. • Cloud Infrastructure as a Service (IaaS) • The capability provided to the consumer is to provision processing, storage, networks, and other fundamental computing resources where the consumer is able to deploy and run arbitrary software, which can include operating systems and applications. The consumer does not manage or control the underlying cloud infrastructure but has control over operating systems, storage, deployed applications, and possibly limited control of select networking components (e.g., host firewalls). (All definitions are from NIST Definition of Cloud Computing, Version 15, 10-07-2009)

7. Cloud Computing – Deployment Models • Private cloud • The cloud infrastructure is operated solely for an organization. It may be managed by the organization or a third party and may exist on premise or off premise. • Community cloud • The cloud infrastructure is 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 premise or off premise. • Public cloud • The cloud infrastructure is made available to the general public or a large industry group and is owned by an organization selling cloud services. • Hybrid cloud • The cloud infrastructure 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 (e.g., cloud bursting for load-balancing between clouds). (All definitions are from NIST Definition of Cloud Computing, Version 15, 10-07-2009)

8. Cloud Computing Use By Governments*(*from http://www.cio.gov/documents/StateOfCloudComputingReport-FINALv3_508.pdf) • Federal • Department of Defense, Defense Information Systems Agency • IaaS – Forge.mil • State • State of New Jersey, NJ Transit Authority • SaaS - Customer relationship management • http://www.nj.com/news/index.ssf/2008/05/nj_transit_to_test_online_sugg. Local • Local • City of Miami, FL • PaaS – City-wide 311 • http://gcn.com/articles/2010/03/10/city-of-miami-microsoft-azure

9. So Is There A Problem? • Potentially • If the benefits of the drivers outweigh perceptions of records management responsibilities • If cloud solutions are procured without consideration of records management requirements • If particular cloud deployments present insurmountable obstacles to exercising records management

10. What are some of the records management challenges associated with cloud computing? • Cloud applications may lack the capability to implement records disposition schedules, including the ability to transfer and permanently delete records or perform other records management functions. Therefore specific service and deployment models may not meet all of the records management requirements of 36 CFR part 1236 (formerly 36 CFR part 1234). Examples of these requirements include: • Maintaining records in a way that maintains their functionality and integrity throughout the records’ full lifecycle • Maintaining links between the records and their metadata • Transfer of archival records to NARA or deletion of temporary records according to NARA-approved retention schedules.

11. What are some of the records management challenges associated with cloud computing? • 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 are stored and manipulated in cloud environments. This threatens the long-term trustworthiness and sustainability of the data.

12. What are some of the records management challenges associated with cloud computing? • A lack of portability standards may result in difficulty removing records for recordkeeping requirements or complicate the transition to another environment. This could affect the ability of agencies to meet their recordkeeping responsibilities for temporary or historically valuable records being transferred to NARA.

13. How can the records management challenges be met? • Provisos • Differences between service models affect how and by whom (agency/contractor) records management activities can be performed. • Several organizations are working on developing cloud computing standards. HOWEVER, their initial focus has been primarily on security and interoperability issues, not on records management. • Given these, early cloud adopters will still need to adopt tactics to address ‘RM in the cloud’

14. How can the records management challenges be met? • Include the records management staff in the planning, development, deployment, and use of cloud computing solutions. • Define which copy of records will be declared as the agency’s record copy and manage these in accordance with your juridical RM context Remember, the value of records in the cloud may be greater than the value of the other set because of indexing or other reasons. In such instances, this added value may require designation of the copies as records. • Include instructions for determining if records in a cloud environment are covered under an existing records retention schedule.

15. How can the records management challenges be met? • Include instructions on how all records will be captured, managed, retained, made available to authorized users, and retention periods applied. • Include instructions on conducting a records analysis, developing and submitting records retention schedules for unscheduled records in a cloud environment, These instructions should include scheduling system documentation, metadata, and related records. • Include instructions to periodically test transfers of records to other environments, including agency servers, to ensure the records remain portable.

16. How can the records management challenges be met? • Include instructions on how data will be migrated to new formats, operating systems, etc., so that records are readable throughout their entire life cycles. Include in your migration planning provisions for transferring permanent records in the cloud to the records authority. • Resolve portability and accessibility issues through good records management policies and other data governance practices. Data governance typically addresses interoperability of computing systems, portability of data (able to move from one system to another), and information security and access. However, such policies by themselves will not address an agency’s compliance with governing statutes and regulations.

17. Intervention at Procurement • Draft RM-related Terms of Service [ToS] clause to append to any CC procurement • E.g., • The Entity [adopting CC services] acknowledges that use of Provider’s site and services may require management of records. User-generated content in the form of comments, contributions to drafts, and other materials may also meet the definition of records as determined by the Entity. If the provider holds records, the Entity and the Provider must manage records in accordance with all applicable records management laws and regulations, including cite your specifics here. Managing the records includes, but is not limited to, secure storage, retrievability, and proper disposition of all records including transfer of permanently valuable records in a format and manner acceptable to insert A/RM authority here at the time of transfer at the time of transfer. The Entity is responsible for ensuring that the contractor is compliant with applicable records management laws and regulations through the life of the contract.

18. Questions? Contact Information: Arian D. Ravanbakhsh arian.ravanbakhsh@nara.gov Blog: http://blogs.archives.gov/records-express