Records Managers

Frequently Asked Questions about Managing Federal Records In Cloud Computing Environments

  1. What is the purpose of this FAQ? The Obama Administration, including the Federal CIO, is encouraging Federal agencies to adopt cloud-based solutions for a wide range of activities. Many of the recent Government 2.0 initiatives, including, use cloud computing services. The purpose of this FAQ is to provide agency records officers with a basic overview of cloud computing, its benefits and concerns, and records management implications that agencies will need to consider when implementing cloud computing services.

  2. What is cloud computing? Multiple definitions of cloud computing have been published as the technology is refined and its attributes and characteristics continue to evolve. 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 using a scalable range of resources without having to build infrastructure to support these resources within their own environments or networks.

    The National Institute of Standards and Technology (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)

  3. What are cloud computing service and deployment models? Cloud computing service models can be described 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 (see

    • 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.
    • 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.

  4. What are the benefits/concerns of cloud computing? There are a number of benefits and concerns associated with implementing cloud computing services. Cloud computing is evolving; therefore, some of the listed benefits and concerns may change.
    Common benefits include:
    • Cost savings with "pay-as-you go" service plans
    • Scalability of resource procurement in response to needed IT capacity
    • Accessibility of services often from any networked machine
    • Collaboration capabilities with access to shared applications and records
    • Flexibility to procure resources on demand
    • Capacity to outsource large computing needs and non-critical applications

      Common concerns include:

    • Security and privacy of information in a shared environment that resides outside of 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

  5. 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:
      • Maintaining records in a way that maintains their functionality and integrity throughout the record’s full life cycle
      • 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
    • 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. Agencies are responsible for complying with records management regulations wherever records are created and stored.

  6. What else is NARA doing in regards to cloud computing? NARA will issue a bulletin on cloud computing by the end of fiscal year 2010. The bulletin will provide a more in-depth exploration of the implications for Federal records that are created, managed, and stored in cloud computing environments. The bulletin will address the 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.

  7. Where do I go for more information? If you need additional information about the contents of this FAQ, please contact

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