The bulletin titled Guidance on Managing Records in Cloud Computing Environments covers everything an agency would need to start a move to cloud computing from defining what cloud computing is to meeting records management requirements and what an agency’s responsibilities are when dealing with contractors.
Also covered in the bulletin is a look at how Federal agencies are currently using cloud computing. NARA notes “agencies stated that managing records in a cloud computing environment is a concern that they are only beginning to address.”
Part of that challenge is figuring out how to make the on-demand nature of cloud computing suitable for information, classified and otherwise, agencies need to archive with permanent addresses.
Other challenges identified by NARA include:
Some cloud applications might not be able to “transfer and permanently delete records or perform other records management functions,”
Service providers need to be brought up to speed on federal records retention requirements,
Federal technical standards need to be met,
Figuring out what to do if a provider’s “business operations materially change (e.g., bankruptcy), or cease altogether.”
Once an agency figures out what services are needed and is ready to sign a contract with a provider, NARA has provided a general clause that can be changed as needed, “to fit the planned type of service and specific agency records management needs”.