This document provides an overview of cloud computing and discusses records management challenges associated with cloud environments. It defines cloud computing and its essential characteristics. It also outlines NARA guidance on managing records in the cloud, including a FAQ and upcoming bulletin. The document discusses challenges such as ensuring records retention and disposition schedules are followed and that records remain accessible and portable. It recommends including records management staff in planning cloud solutions and addressing records management requirements in contracts.

1. NARA’s FAQ and Bulletin on
Managing Federal Records in
Cloud 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_o
nline_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
1. Differences between service models affect how
and by whom (agency/contractor) records
management activities can be performed.
2. 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