responsive documents - crew: nara: regarding record management and cloud computing: 11/28/2011 -...
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Bulletin on
Managing Federal Records inCloud Computing Environments
ERM/NRMP TeamSeptember 8, 2010
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Development Team Members
ERM
Denise Pullen
Mark Giguere
Arian Ravanbakhsh
Don Rosen
Beth Cron
Jill Shaver
NRMP
Addie Compton
Scott Roley
We also interviewed four agencies who reviewed a
draft. Concurrence within NARA, OMB, and FRC.
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Outline
We will highlight: Purpose
Definitions Examples of Use
RM Challenges
Tactics to solve challenges Contracting
Questions?
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Purpose
Administration backing Cloud Computing
Agencies are adopting it
NARA put out an FAQ and promised a Bulletinlater this year
FAQ is largely definitional
Bulletin includes
expanded definitions
recommendations
agency uses of cloud computing
4(Bulletin Question 1 & 2)
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Cloud Computing: Definition
Basically, using shared resources over the
Internet
Many interpretations exist Renting storage space
Social Media Tools (only in SaaS)
We are using NIST definitions
5(Bulletin Question 3)
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Cloud Computing: Definition
NIST defines cloud computing as a model forenabling convenient, on-demand networkaccess to a shared pool of configurable
computing resources (e.g., networks, servers,storage, applications, and services) that can berapidly provisioned and released with minimalmanagement effort or service provider
interaction. (NIST Definition of CloudComputing, Version 15, 10-07-2009)
6(Bulletin Question 3)
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NISTs Essential Characteristics
On-demand self-service
Increase storage, etc. automatically
Broad network access
Capabilities are available over the network
Resource pooling The providers computing resources are pooled to serve multiple
consumers
There is a sense of location independence; customer generally has nocontrol or knowledge over the exact location of resources
Rapid elasticity
Quickly scale out or scale in computing power Measured Service
automatically control and optimize resource through a meteringcapability
7(Bulletin Question 3)
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Cloud Computing Service Models Cloud Software as a Service (SaaS)
Providers applications running on a cloud infrastructure
Consumer does not manage or control the underlying cloud infrastructure
Web mail systems in the cloud
Cloud Platform as a Service (PaaS)
Consumer-created or acquired applications created using programming
languages and tools supported by the provider Consumer does not manage or control the underlying cloud infrastructure
Cloud Infrastructure as a Service (IaaS)
Consumer receives computing resources that the consumer is able to deploy
and run arbitrary software, which can include operating systems and
applications
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)
8(Bulletin Question 4)
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Cloud Computing Deployment Models
Private cloud
Cloud is operated solely for an organization by the organizationor a third party
Community cloud
Cloud is shared by several organizations and supports a specificcommunity that have mutual concerns
Public cloud
Cloud is made available to the general public or a large industrygroup and is owned by an organization selling cloud services
Hybrid cloud Cloud is a composition of two or more clouds (private,
community, or public) that remain unique entities but are boundtogether by standardized or proprietary technology that enablesdata and application portability
9(Bulletin Question 4)
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Cloud Computing Use By Agencies
Team interviewed four agencies using clouds All received business benefits to solve various
problems
Some created private cloud others usedcommercial offerings
All had some issues with records management
One keeps everything, but is working to figure it
out Two are still working on agreements that place
responsibility on participating agencies, but notthe providing agency
10(Bulletin Question 5)
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So Is There A Problem?
Potentially
If the benefits of the drivers outweighperceptions of records management
responsibilities If cloud solutions are procured without
consideration of records managementrequirements
If particular cloud deployments presentinsurmountable obstacles to exercising recordsmanagement
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Some RM Challenges
Cloud applications may lack the capability toimplement records disposition schedules
Maintaining records in a way that maintains
their functionality and integrity throughoutthe records full lifecycle
Maintaining links between the records andtheir metadata
Transfer of archival records to NARAaccording to NARA-approved retentionschedules
12(Bulletin Question 6)
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Some RM Challenges
Depending on the application, vendors may
not be able to ensure the complete deletion of
records
Various cloud architectures lack formal
technical standards governing how data are
stored and manipulated in cloud
environments
13(Bulletin Question 6)
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Some RM Challenges
A lack of portability standards may result in
difficulty removing records for recordkeeping
requirements or complicate the transition to
another environment
Agencies and cloud service providers need to resolve
issues if a cloud service ceases or changes
dramatically
14(Bulletin Question 6)
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Meeting RM Challenges
Provisos1. Differences between service models affect how
and by whom (agency/contractor) records
management activities can be performed
2. Service or Deployment Models used could affect
where records are stored or created
PaaS and IaaS might contain no Federal records
depending on how they are used3. In SaaS model, records may often be held in
contracted space
15(Bulletin Question 7)
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Meeting RM Challenges
Include RM staff in cloud computing solution
Define which copy of records will be declaredas the agencys record copy (value of records
in the cloud may be greater than the value ofthe other set because of indexing or otherreasons)
Include instructions for determining if recordsin a cloud environment are covered under anexisting records retention schedule
16(Bulletin Question 7)
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Meeting RM Challenges
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, including records scheduling
Include instructions to periodically test transfers
of records to other environments, includingagency servers, to ensure the records remain
portable
17(Bulletin Question 7)
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Meeting RM Challenges
Include instructions on how data will be
migrated, so records are readable throughout
their entire life cycles
Resolve portability and accessibility issues
through good records management policies
and other data governance practices
18(Bulletin Question 7)
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Contracting
Agency is always responsible for its Federal
records even if they are in contracted space
Agencies must ensure contractors are awareof the agencies RM responsibilities
Agencies must work with contractors to
manage records
If a contractor quits the business, agencies
must get the records back
19(Bulletin Question 8)
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Contracting
We created model language that informs allparties of RM responsibilities
Working to add similar language to GSAs apps.gov
store
Agencies can modify as needed, other clausescan be included in contracts
Agencies may be partners in a private orcommunity
Include RM in MOUs or other agreements
20(Bulletin Question 8)
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Questions?
Bulletin points agencies with questions to
NRMP staff
Toolkit is a resource
Contact Information:
[email protected] [email protected]
Blog: http://blogs.archives.gov/records-express
21(Bulletin Question 9, etc.)