Managing records in cloud computing environments — Part 1: Issues and concerns

This document presents a model for cloud records management and outlines the risks and issues that are considered by records managers before adopting cloud services for records management. The model for cloud records management includes a stakeholder model, processes, metadata, architecture, and use cases. Risks and issues are classified into those originating from cloud services internally and those originating from cloud services externally. Internal risks are associated with cloud services, systems and stakeholders. External risks and issues can occur in the social and legal context in which cloud services operate. The target audience of this document includes: — records, information, knowledge, and governance professionals; — cloud service architects; — archivists using cloud services for managing records; — developers of cloud-deployed records management software; — ICT staff; and — providers of cloud-based records management services.

Gestion des documents d'activité dans les environnements d'informatique en nuage — Partie 1: Enjeux et préoccupations

Upravljanje zapisov v okoljih računalništva v oblaku - 1. del: Vprašanja in pomisleki

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Status
Published
Publication Date
14-Sep-2020
Current Stage
6060 - International Standard published
Start Date
15-Sep-2020
Completion Date
15-Sep-2020

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SLOVENSKI STANDARD
SIST-TP ISO/TR 22428-1:2021
01-marec-2021
Upravljanje zapisov v okoljih računalništva v oblaku - 1. del: Vprašanja in
pomisleki
Managing records in cloud computing environments - Part 1: Issues and concerns
Gestion des documents d'activité dans les environnements d'informatique en nuage
Ta slovenski standard je istoveten z: ISO/TR 22428-1:2020
ICS:
01.140.20 Informacijske vede Information sciences
35.210 Računalništvo v oblaku Cloud computing
SIST-TP ISO/TR 22428-1:2021 en
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

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SIST-TP ISO/TR 22428-1:2021

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SIST-TP ISO/TR 22428-1:2021
TECHNICAL ISO/TR
REPORT 22428-1
First edition
2020-09
Managing records in cloud computing
environments —
Part 1:
Issues and concerns
Gestion des documents d'activité dans les environnements
d'informatique en nuage —
Partie 1: Enjeux et préoccupations
Reference number
ISO/TR 22428-1:2020(E)
©
ISO 2020

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SIST-TP ISO/TR 22428-1:2021
ISO/TR 22428-1:2020(E)

COPYRIGHT PROTECTED DOCUMENT
© ISO 2020
All rights reserved. Unless otherwise specified, or required in the context of its implementation, no part of this publication may
be reproduced or utilized otherwise in any form or by any means, electronic or mechanical, including photocopying, or posting
on the internet or an intranet, without prior written permission. Permission can be requested from either ISO at the address
below or ISO’s member body in the country of the requester.
ISO copyright office
CP 401 • Ch. de Blandonnet 8
CH-1214 Vernier, Geneva
Phone: +41 22 749 01 11
Email: copyright@iso.org
Website: www.iso.org
Published in Switzerland
ii © ISO 2020 – All rights reserved

---------------------- Page: 4 ----------------------
SIST-TP ISO/TR 22428-1:2021
ISO/TR 22428-1:2020(E)

Contents Page
Foreword .v
Introduction .vi
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Stakeholder model . 4
4.1 General . 4
4.2 Cloud records management service customer . 5
4.2.1 General. 5
4.2.2 Cloud records producer . 5
4.2.3 Cloud records manager . 6
4.2.4 Cloud records user . 6
4.3 Cloud records management service provider . 6
4.3.1 General. 6
4.3.2 Records management SaaS provider . 6
4.3.3 PaaS provider . 7
4.3.4 IaaS provider . 7
4.4 Cloud records management service partner . 7
4.4.1 Cloud records management agent . 7
4.4.2 Cloud records management auditor . 7
5 Cloud records management environments . 8
5.1 General . 8
5.2 Records management processes in the cloud environment . 8
5.3 Metadata in cloud records management services . 9
5.4 Cloud reference architecture for managing authoritative records .10
6 Use cases in cloud records management .11
6.1 General .11
6.2 SaaS shared by customers .12
6.3 SaaS developed by customers .13
6.4 Records management based on IaaS .13
6.5 Multiple IaaS used by customers .14
6.6 Records management agent .15
7 Risks in cloud records system .16
7.1 General .16
7.2 Cloud service risks .16
7.3 Cloud system risks .18
7.4 Cloud stakeholder risks .19
8 Social and legal issues of cloud services .19
8.1 General .19
8.2 Legal issues .20
8.2.1 General.20
8.2.2 Cross-border data jurisdictional issues .20
8.2.3 Inability to enforce contractual terms .20
8.2.4 Non-negotiable licensing terms .21
8.2.5 Data ownership issues .21
8.2.6 Conflict between the terms and conditions .21
8.3 Social issues .21
8.3.1 General.21
8.3.2 Limitations of technical security .22
8.3.3 Social impact of personal information leakage accidents .22
8.3.4 Unavailability of personal records.23
© ISO 2020 – All rights reserved iii

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8.3.5 Risk of long-term preservation of records in the cloud service .23
Bibliography .24
iv © ISO 2020 – All rights reserved

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ISO/TR 22428-1:2020(E)

Foreword
ISO (the International Organization for Standardization) is a worldwide federation of national standards
bodies (ISO member bodies). The work of preparing International Standards is normally carried out by
ISO technical committees. Each member body interested in a subject has the right to be represented on
the relevant technical committee if such committee has been established. International organizations,
governmental and non-governmental, in liaison with ISO, also take part in the work. ISO collaborates
closely with the International Electro-technical Commission (IEC) on all matters related to electro-
technical standardization.
The procedures used to develop the present document and those intended for its further maintenance
are described in the ISO/IEC Directives, Part 1. In particular, the various approval criteria needed for
different types of ISO documents should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www .iso .org/ directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. ISO shall not be held responsible for identifying any or all such patent rights. Details of
any patent rights identified during the development of the document will be listed in the Introduction
and/or on the ISO list of patent declarations received (see www .iso .org/ patents).
Any trade name used in this document is given for the purpose of information for users’ convenience
and does not constitute an endorsement.
For an explanation of the voluntary nature of standards, the meaning of ISO-specific terms and
expressions related to conformity assessment, as well as information on ISO's adherence to the World
Trade Organization (WTO) principles in the Technical Barriers to Trade (TBT), see www .iso .org/ iso/
foreword .html.
This document was prepared by Technical Committee ISO/TC 46, Information and documentation,
Subcommittee SC 11, Archives/records management.
A list of all parts in the ISO 22428 series can be found on the ISO website.
Any feedback or questions on this document should be directed to the user’s national standards body. A
complete listing of these bodies can be found at www .iso .org/ members .html.
© ISO 2020 – All rights reserved v

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ISO/TR 22428-1:2020(E)

Introduction
A cloud service refers to capabilities offered via cloud computing where users can borrow, to use
flexibly, physical or virtual resources which include software and platform, as well as computing
infrastructure, such as data storage and computing servers. The cloud service offers benefits, such as
dynamic scalability, enhanced organizational agility, resilience and cost reduction, enabling improved
organizational competitiveness and efficiency. Cloud services are emerging as an essential aspect of
information technology due to location-independent resource sharing, availability via the Internet and
mobile devices, and the ability to deliver on-demand services and lower costs.
Currently, the explosive growth of digital content through mobile platforms and the Internet of things
is driving organizations to move their computing systems and information assets to the cloud. As a
result, a number of companies and government organizations have shifted their business systems to
cloud services, and many other organizations are planning to adopt cloud services. In the near future, it
is expected that most data will be processed and stored in cloud services.
Cloud services might prove to be an alternative for organizations that are reluctant to invest in
establishing their own computer systems for digital records management. Cloud services can provide
the software, hardware, and platform needed to implement a system for records at an affordable price.
It is often not easy for an organization to implement a system for records that meets all the criteria set
out in ISO 15489-1. If there is a cloud service that satisfies all the criteria set out in ISO 15489-1 and
which is provided at a low price, organizations have good reasons to consider using the cloud service.
However, organizations can be reluctant to adopt cloud services for their records management due
to unknown risks, safety and privacy concerns, and an absence of convincing use cases. While the
advantages of cloud services are well-advertised, awareness of the risks and issues that should be taken
into account in a records management context is often lacking.
Cloud services are based on the concept of borrowing computing resources provided by third
parties. The functions, processes or architectures inside the cloud are not disclosed externally. Even
if a customer agrees with a cloud service provider about their requirements, it is difficult to know
in advance whether their requirements can be met. In particular, it can be very difficult for general-
purpose cloud services to fully satisfy the requirements of the records management process. There are
various types of cloud services according, each of which offers different capabilities. In order to apply a
cloud service to the records management task, the customer could select a cloud service that is suitable
for the characteristics of the records management. The customer also to understands the general
characteristics of cloud services. Otherwise, there is a possibility that desired records management
outcomes will not be able to be delivered after adopting a cloud service.
In addition, in the case of large cloud services, cloud systems can be distributed around the world
transcending national borders. Users from various countries or regional communities can share a cloud
service belonging to a particular country. These characteristics of the cloud can cause various conflicts
and issues because the jurisdictional structure and social environment of the country where the cloud
service provider belongs is different from those of the cloud users. As a result, cloud users can be faced
with unexpected risks associated with immature legal and social agreements for cloud technology.
Therefore, when records managers introduce cloud services to records management, they should
consider the legal and social aspects as well as the technical aspects in advance in order to prepare for
potential risks. Records managers can provide cloud service providers with prerequisites for managing
risks, specified in contracts to reduce the probability of risks coming to fruition. This document aims
to provide guidelines for persons and organizations who are intend to adopt cloud services for records
management.
vi © ISO 2020 – All rights reserved

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SIST-TP ISO/TR 22428-1:2021
TECHNICAL REPORT ISO/TR 22428-1:2020(E)
Managing records in cloud computing environments —
Part 1:
Issues and concerns
1 Scope
This document presents a model for cloud records management and outlines the risks and issues that
are considered by records managers before adopting cloud services for records management. The
model for cloud records management includes a stakeholder model, processes, metadata, architecture,
and use cases. Risks and issues are classified into those originating from cloud services internally and
those originating from cloud services externally. Internal risks are associated with cloud services,
systems and stakeholders. External risks and issues can occur in the social and legal context in which
cloud services operate.
The target audience of this document includes:
— records, information, knowledge, and governance professionals;
— cloud service architects;
— archivists using cloud services for managing records;
— developers of cloud-deployed records management software;
— ICT staff; and
— providers of cloud-based records management services.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
ISO 30300, Information and documentation — Management system for records — Core concepts and
vocabulary
ISO 13008, Information and documentation — Digital records conversion and migration process
ISO/IEC 17788, Information technology — Cloud computing — Overview and vocabulary
3 Terms and definitions
For the purposes of this document, the terms and definitions given in ISO 30300, ISO 13008,
ISO/IEC 17788 and the following apply.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https:// www .iso .org/ obp
— IEC Electropedia: available at http:// www .electropedia .org/
© ISO 2020 – All rights reserved 1

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ISO/TR 22428-1:2020(E)

3.1
cloud computing
paradigm for enabling network access to a scalable and elastic pool of shareable physical or virtual
resources with self-service provisioning and administration on-demand
[SOURCE: ISO/IEC 17788:2014, 3.2.5]
Note 1 to entry: Examples of resources include servers, operating systems, networks, software, applications, and
storage equipment.
3.2
cloud capability type
classification of the functionality provided by a cloud service to the cloud service customer, based on
the nature of resources used
[SOURCE: ISO/IEC 17788:2014, 3.2.4]
3.3
cloud deployment model
ways in which cloud computing (3.1) can be organized based on the control and sharing of physical or
virtual resources
[SOURCE: ISO/IEC 17788:2014, 3.2.7]
3.4
cloud records
digital records created, preserved or managed by a cloud service
3.5
cloud records management
records management entrusted to cloud service
3.6
cloud records management service customer
party that is in a business relationship with the records management service provider for the purpose
of using cloud records management services
3.7
cloud records management service partner
party that is engaged in support of, or as auxiliary to, activities of either the cloud records management
service provider (3.8) or the cloud records management service customer (3.6), or both
3.8
cloud records management service provider
party that makes cloud records management (3.5)services available
3.9
cloud service
one or more capabilities offered via cloud computing (3.1) invoked using a defined interface
[SOURCE: ISO/IEC 17788:2014, 3.2.8]
3.10
cloud service customer
party which is in a business relationship for the purpose of using cloud services (3.9)
[SOURCE: ISO/IEC 17788:2014, 3.2.11]
2 © ISO 2020 – All rights reserved

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3.11
cloud SLA
cloud service level agreement
part of the cloud service agreement that includes cloud service level objectives and cloud service
qualitative objectives for the covered cloud service(s)
[SOURCE: ISO/IEC 19086-1:2016, 3.4]
3.12
cloud service provider
party which makes cloud services (3.9) available
[SOURCE: ISO/IEC 17788:2014, 3.2.15]
3.13
IaaS
Infrastructure as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the infrastructure capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.24]
3.14
multi-tenancy
allocation of physical or virtual resources such that multiple tenants (3.21) and their computations and
data are isolated from and inaccessible to one another
[SOURCE: ISO/IEC 17788:2014, 3.2.27]
3.15
PaaS
Platform as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the platform capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.30]
3.16
private cloud
cloud deployment model (3.3) where cloud services (3.9) are used exclusively by a single cloud service
customer (3.10) and resources are controlled by that cloud service customer
[SOURCE: ISO/IEC 17788:2014, 3.2.32]
3.17
public cloud
cloud deployment model (3.3) where cloud services (3.9) are potentially available to any cloud service
customer (3.10) and resources are controlled by the cloud service provider (3.12)
[SOURCE: ISO/IEC 17788:2014, 3.2.33]
3.18
SaaS
Software as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the application capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.36]
© ISO 2020 – All rights reserved 3

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3.19
SOA
Service Oriented Architecture
architectural style that supports service orientation and is a paradigm for building business solutions
using IT
[SOURCE: ISO/IEC 18384-1:2016, 2.48; ISO/IEC TR 30102:2012]
3.20
SORMA
Service Oriented Records Management Architecture
reference architecture model for records management based on cloud services, which includes service
components for supporting records management in the form of SOA (3.19)
3.21
tenant
one or more cloud service users sharing access to a set of physical and virtual resources
[SOURCE: ISO/IEC 17788:2014, 3.2.37]
4 Stakeholder model
4.1 General
The cloud stakeholder model in this document is borrowed from the service model provided by
ISO/IEC 17788, and extends it to the records management domain. A cloud records management service
customer is a party that enters a business relationship with a cloud records management service
provider for the purpose of using cloud records management services. A cloud records management
service provider is a party that makes cloud records management services available. A cloud records
management service partner is a party that is engaged in support of, or as auxiliary to, activities of
either the cloud records management service provider or the cloud records management service
customer, or both.
4 © ISO 2020 – All rights reserved

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ISO/TR 22428-1:2020(E)

Key
  party
  entity
Figure 1 — Cloud records management stakeholder model
4.2 Cloud records management service customer
4.2.1 General
Cloud records management service customers use cloud services to produce, transmit, maintain, and
dispose of digital records and metadata. Customers strive to negotiate records management policies
and procedures with cloud service providers on prior to entering the service contract. Customers can
have cloud SLA contracts with cloud service providers to ensure confidence in the quality of records
management.
Customers can be divided into several entities (individuals, teams, organizations) based on their
records management role internally as follows:
— cloud records producer;
— cloud records manager;
— cloud records user.
4.2.2 Cloud records producer
Cloud records producers use cloud records management services to produce reliable records. This
means that the cloud records producer ensures the authenticity, integrity, and reliability of the records
by means of a cloud service. Cloud records producers inspect the records they write and verify that the
records are stored in the cloud service without compromising their attributes.
© ISO 2020 – All rights reserved 5

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ISO/TR 22428-1:2020(E)

When creating a record, cloud records producers are able to generate metadata that includes business
context and verify that the metadata are generated without distortion. Cloud records producers is
responsible for verifying that metadata are registered and preserved at a cloud service.
4.2.3 Cloud records manager
Cloud records managers have the responsibility of managing the records of their organization using
cloud records management services. The cloud records manager leverages cloud services to perform
administrative tasks such as registration and preservation of records, migration and conversion,
search/query requests, verification of records integrity, and user authentication. The cloud records
manager is expected to be familiar with the data management policies of the cloud service provider
before using the cloud service, and consult with the cloud service provider if necessary.
The cloud records manager is responsible for reviewing the cloud service, ensuring that all requirements
that arise from business and stakeholder expectations and the organization’s regulatory environment
can be met. The cloud records manager is responsible for inspecting the cloud service to see whether
there are any constraints or problems in the functionalities by which records are created, registered,
preserved, retrieved, browsed, and destructed.
When constraints are required for records management in the cloud, cloud records managers can
establish records management policies and procedures for those constraints, and may make specific
demands from cloud service providers as needed. For example, a cloud records manager may require
a private cloud service provider to store records in a separate repository. The cloud records manager
may ask the cloud service provider for access control policy on the records.
The cloud records manager manages access to records by setting the access level of each cloud records
and specifying the access rights of cloud records users. The access rights of cloud records users are
specified depending on their role, seniority, security clearance, location, etc.
The cloud records manager periodically monitors the registration and classification of records, their
preservation status, and security mechanisms. Cloud records managers can maintain records stability
and security quality beyond a certai
...

TECHNICAL ISO/TR
REPORT 22428-1
First edition
2020-09
Managing records in cloud computing
environments —
Part 1:
Issues and concerns
Gestion des documents d'activité dans les environnements
d'informatique en nuage —
Partie 1: Enjeux et préoccupations
Reference number
ISO/TR 22428-1:2020(E)
©
ISO 2020

---------------------- Page: 1 ----------------------
ISO/TR 22428-1:2020(E)

COPYRIGHT PROTECTED DOCUMENT
© ISO 2020
All rights reserved. Unless otherwise specified, or required in the context of its implementation, no part of this publication may
be reproduced or utilized otherwise in any form or by any means, electronic or mechanical, including photocopying, or posting
on the internet or an intranet, without prior written permission. Permission can be requested from either ISO at the address
below or ISO’s member body in the country of the requester.
ISO copyright office
CP 401 • Ch. de Blandonnet 8
CH-1214 Vernier, Geneva
Phone: +41 22 749 01 11
Email: copyright@iso.org
Website: www.iso.org
Published in Switzerland
ii © ISO 2020 – All rights reserved

---------------------- Page: 2 ----------------------
ISO/TR 22428-1:2020(E)

Contents Page
Foreword .v
Introduction .vi
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Stakeholder model . 4
4.1 General . 4
4.2 Cloud records management service customer . 5
4.2.1 General. 5
4.2.2 Cloud records producer . 5
4.2.3 Cloud records manager . 6
4.2.4 Cloud records user . 6
4.3 Cloud records management service provider . 6
4.3.1 General. 6
4.3.2 Records management SaaS provider . 6
4.3.3 PaaS provider . 7
4.3.4 IaaS provider . 7
4.4 Cloud records management service partner . 7
4.4.1 Cloud records management agent . 7
4.4.2 Cloud records management auditor . 7
5 Cloud records management environments . 8
5.1 General . 8
5.2 Records management processes in the cloud environment . 8
5.3 Metadata in cloud records management services . 9
5.4 Cloud reference architecture for managing authoritative records .10
6 Use cases in cloud records management .11
6.1 General .11
6.2 SaaS shared by customers .12
6.3 SaaS developed by customers .13
6.4 Records management based on IaaS .13
6.5 Multiple IaaS used by customers .14
6.6 Records management agent .15
7 Risks in cloud records system .16
7.1 General .16
7.2 Cloud service risks .16
7.3 Cloud system risks .18
7.4 Cloud stakeholder risks .19
8 Social and legal issues of cloud services .19
8.1 General .19
8.2 Legal issues .20
8.2.1 General.20
8.2.2 Cross-border data jurisdictional issues .20
8.2.3 Inability to enforce contractual terms .20
8.2.4 Non-negotiable licensing terms .21
8.2.5 Data ownership issues .21
8.2.6 Conflict between the terms and conditions .21
8.3 Social issues .21
8.3.1 General.21
8.3.2 Limitations of technical security .22
8.3.3 Social impact of personal information leakage accidents .22
8.3.4 Unavailability of personal records.23
© ISO 2020 – All rights reserved iii

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ISO/TR 22428-1:2020(E)

8.3.5 Risk of long-term preservation of records in the cloud service .23
Bibliography .24
iv © ISO 2020 – All rights reserved

---------------------- Page: 4 ----------------------
ISO/TR 22428-1:2020(E)

Foreword
ISO (the International Organization for Standardization) is a worldwide federation of national standards
bodies (ISO member bodies). The work of preparing International Standards is normally carried out by
ISO technical committees. Each member body interested in a subject has the right to be represented on
the relevant technical committee if such committee has been established. International organizations,
governmental and non-governmental, in liaison with ISO, also take part in the work. ISO collaborates
closely with the International Electro-technical Commission (IEC) on all matters related to electro-
technical standardization.
The procedures used to develop the present document and those intended for its further maintenance
are described in the ISO/IEC Directives, Part 1. In particular, the various approval criteria needed for
different types of ISO documents should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www .iso .org/ directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. ISO shall not be held responsible for identifying any or all such patent rights. Details of
any patent rights identified during the development of the document will be listed in the Introduction
and/or on the ISO list of patent declarations received (see www .iso .org/ patents).
Any trade name used in this document is given for the purpose of information for users’ convenience
and does not constitute an endorsement.
For an explanation of the voluntary nature of standards, the meaning of ISO-specific terms and
expressions related to conformity assessment, as well as information on ISO's adherence to the World
Trade Organization (WTO) principles in the Technical Barriers to Trade (TBT), see www .iso .org/ iso/
foreword .html.
This document was prepared by Technical Committee ISO/TC 46, Information and documentation,
Subcommittee SC 11, Archives/records management.
A list of all parts in the ISO 22428 series can be found on the ISO website.
Any feedback or questions on this document should be directed to the user’s national standards body. A
complete listing of these bodies can be found at www .iso .org/ members .html.
© ISO 2020 – All rights reserved v

---------------------- Page: 5 ----------------------
ISO/TR 22428-1:2020(E)

Introduction
A cloud service refers to capabilities offered via cloud computing where users can borrow, to use
flexibly, physical or virtual resources which include software and platform, as well as computing
infrastructure, such as data storage and computing servers. The cloud service offers benefits, such as
dynamic scalability, enhanced organizational agility, resilience and cost reduction, enabling improved
organizational competitiveness and efficiency. Cloud services are emerging as an essential aspect of
information technology due to location-independent resource sharing, availability via the Internet and
mobile devices, and the ability to deliver on-demand services and lower costs.
Currently, the explosive growth of digital content through mobile platforms and the Internet of things
is driving organizations to move their computing systems and information assets to the cloud. As a
result, a number of companies and government organizations have shifted their business systems to
cloud services, and many other organizations are planning to adopt cloud services. In the near future, it
is expected that most data will be processed and stored in cloud services.
Cloud services might prove to be an alternative for organizations that are reluctant to invest in
establishing their own computer systems for digital records management. Cloud services can provide
the software, hardware, and platform needed to implement a system for records at an affordable price.
It is often not easy for an organization to implement a system for records that meets all the criteria set
out in ISO 15489-1. If there is a cloud service that satisfies all the criteria set out in ISO 15489-1 and
which is provided at a low price, organizations have good reasons to consider using the cloud service.
However, organizations can be reluctant to adopt cloud services for their records management due
to unknown risks, safety and privacy concerns, and an absence of convincing use cases. While the
advantages of cloud services are well-advertised, awareness of the risks and issues that should be taken
into account in a records management context is often lacking.
Cloud services are based on the concept of borrowing computing resources provided by third
parties. The functions, processes or architectures inside the cloud are not disclosed externally. Even
if a customer agrees with a cloud service provider about their requirements, it is difficult to know
in advance whether their requirements can be met. In particular, it can be very difficult for general-
purpose cloud services to fully satisfy the requirements of the records management process. There are
various types of cloud services according, each of which offers different capabilities. In order to apply a
cloud service to the records management task, the customer could select a cloud service that is suitable
for the characteristics of the records management. The customer also to understands the general
characteristics of cloud services. Otherwise, there is a possibility that desired records management
outcomes will not be able to be delivered after adopting a cloud service.
In addition, in the case of large cloud services, cloud systems can be distributed around the world
transcending national borders. Users from various countries or regional communities can share a cloud
service belonging to a particular country. These characteristics of the cloud can cause various conflicts
and issues because the jurisdictional structure and social environment of the country where the cloud
service provider belongs is different from those of the cloud users. As a result, cloud users can be faced
with unexpected risks associated with immature legal and social agreements for cloud technology.
Therefore, when records managers introduce cloud services to records management, they should
consider the legal and social aspects as well as the technical aspects in advance in order to prepare for
potential risks. Records managers can provide cloud service providers with prerequisites for managing
risks, specified in contracts to reduce the probability of risks coming to fruition. This document aims
to provide guidelines for persons and organizations who are intend to adopt cloud services for records
management.
vi © ISO 2020 – All rights reserved

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TECHNICAL REPORT ISO/TR 22428-1:2020(E)
Managing records in cloud computing environments —
Part 1:
Issues and concerns
1 Scope
This document presents a model for cloud records management and outlines the risks and issues that
are considered by records managers before adopting cloud services for records management. The
model for cloud records management includes a stakeholder model, processes, metadata, architecture,
and use cases. Risks and issues are classified into those originating from cloud services internally and
those originating from cloud services externally. Internal risks are associated with cloud services,
systems and stakeholders. External risks and issues can occur in the social and legal context in which
cloud services operate.
The target audience of this document includes:
— records, information, knowledge, and governance professionals;
— cloud service architects;
— archivists using cloud services for managing records;
— developers of cloud-deployed records management software;
— ICT staff; and
— providers of cloud-based records management services.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
ISO 30300, Information and documentation — Management system for records — Core concepts and
vocabulary
ISO 13008, Information and documentation — Digital records conversion and migration process
ISO/IEC 17788, Information technology — Cloud computing — Overview and vocabulary
3 Terms and definitions
For the purposes of this document, the terms and definitions given in ISO 30300, ISO 13008,
ISO/IEC 17788 and the following apply.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https:// www .iso .org/ obp
— IEC Electropedia: available at http:// www .electropedia .org/
© ISO 2020 – All rights reserved 1

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ISO/TR 22428-1:2020(E)

3.1
cloud computing
paradigm for enabling network access to a scalable and elastic pool of shareable physical or virtual
resources with self-service provisioning and administration on-demand
[SOURCE: ISO/IEC 17788:2014, 3.2.5]
Note 1 to entry: Examples of resources include servers, operating systems, networks, software, applications, and
storage equipment.
3.2
cloud capability type
classification of the functionality provided by a cloud service to the cloud service customer, based on
the nature of resources used
[SOURCE: ISO/IEC 17788:2014, 3.2.4]
3.3
cloud deployment model
ways in which cloud computing (3.1) can be organized based on the control and sharing of physical or
virtual resources
[SOURCE: ISO/IEC 17788:2014, 3.2.7]
3.4
cloud records
digital records created, preserved or managed by a cloud service
3.5
cloud records management
records management entrusted to cloud service
3.6
cloud records management service customer
party that is in a business relationship with the records management service provider for the purpose
of using cloud records management services
3.7
cloud records management service partner
party that is engaged in support of, or as auxiliary to, activities of either the cloud records management
service provider (3.8) or the cloud records management service customer (3.6), or both
3.8
cloud records management service provider
party that makes cloud records management (3.5)services available
3.9
cloud service
one or more capabilities offered via cloud computing (3.1) invoked using a defined interface
[SOURCE: ISO/IEC 17788:2014, 3.2.8]
3.10
cloud service customer
party which is in a business relationship for the purpose of using cloud services (3.9)
[SOURCE: ISO/IEC 17788:2014, 3.2.11]
2 © ISO 2020 – All rights reserved

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ISO/TR 22428-1:2020(E)

3.11
cloud SLA
cloud service level agreement
part of the cloud service agreement that includes cloud service level objectives and cloud service
qualitative objectives for the covered cloud service(s)
[SOURCE: ISO/IEC 19086-1:2016, 3.4]
3.12
cloud service provider
party which makes cloud services (3.9) available
[SOURCE: ISO/IEC 17788:2014, 3.2.15]
3.13
IaaS
Infrastructure as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the infrastructure capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.24]
3.14
multi-tenancy
allocation of physical or virtual resources such that multiple tenants (3.21) and their computations and
data are isolated from and inaccessible to one another
[SOURCE: ISO/IEC 17788:2014, 3.2.27]
3.15
PaaS
Platform as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the platform capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.30]
3.16
private cloud
cloud deployment model (3.3) where cloud services (3.9) are used exclusively by a single cloud service
customer (3.10) and resources are controlled by that cloud service customer
[SOURCE: ISO/IEC 17788:2014, 3.2.32]
3.17
public cloud
cloud deployment model (3.3) where cloud services (3.9) are potentially available to any cloud service
customer (3.10) and resources are controlled by the cloud service provider (3.12)
[SOURCE: ISO/IEC 17788:2014, 3.2.33]
3.18
SaaS
Software as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the application capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.36]
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ISO/TR 22428-1:2020(E)

3.19
SOA
Service Oriented Architecture
architectural style that supports service orientation and is a paradigm for building business solutions
using IT
[SOURCE: ISO/IEC 18384-1:2016, 2.48; ISO/IEC TR 30102:2012]
3.20
SORMA
Service Oriented Records Management Architecture
reference architecture model for records management based on cloud services, which includes service
components for supporting records management in the form of SOA (3.19)
3.21
tenant
one or more cloud service users sharing access to a set of physical and virtual resources
[SOURCE: ISO/IEC 17788:2014, 3.2.37]
4 Stakeholder model
4.1 General
The cloud stakeholder model in this document is borrowed from the service model provided by
ISO/IEC 17788, and extends it to the records management domain. A cloud records management service
customer is a party that enters a business relationship with a cloud records management service
provider for the purpose of using cloud records management services. A cloud records management
service provider is a party that makes cloud records management services available. A cloud records
management service partner is a party that is engaged in support of, or as auxiliary to, activities of
either the cloud records management service provider or the cloud records management service
customer, or both.
4 © ISO 2020 – All rights reserved

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ISO/TR 22428-1:2020(E)

Key
  party
  entity
Figure 1 — Cloud records management stakeholder model
4.2 Cloud records management service customer
4.2.1 General
Cloud records management service customers use cloud services to produce, transmit, maintain, and
dispose of digital records and metadata. Customers strive to negotiate records management policies
and procedures with cloud service providers on prior to entering the service contract. Customers can
have cloud SLA contracts with cloud service providers to ensure confidence in the quality of records
management.
Customers can be divided into several entities (individuals, teams, organizations) based on their
records management role internally as follows:
— cloud records producer;
— cloud records manager;
— cloud records user.
4.2.2 Cloud records producer
Cloud records producers use cloud records management services to produce reliable records. This
means that the cloud records producer ensures the authenticity, integrity, and reliability of the records
by means of a cloud service. Cloud records producers inspect the records they write and verify that the
records are stored in the cloud service without compromising their attributes.
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ISO/TR 22428-1:2020(E)

When creating a record, cloud records producers are able to generate metadata that includes business
context and verify that the metadata are generated without distortion. Cloud records producers is
responsible for verifying that metadata are registered and preserved at a cloud service.
4.2.3 Cloud records manager
Cloud records managers have the responsibility of managing the records of their organization using
cloud records management services. The cloud records manager leverages cloud services to perform
administrative tasks such as registration and preservation of records, migration and conversion,
search/query requests, verification of records integrity, and user authentication. The cloud records
manager is expected to be familiar with the data management policies of the cloud service provider
before using the cloud service, and consult with the cloud service provider if necessary.
The cloud records manager is responsible for reviewing the cloud service, ensuring that all requirements
that arise from business and stakeholder expectations and the organization’s regulatory environment
can be met. The cloud records manager is responsible for inspecting the cloud service to see whether
there are any constraints or problems in the functionalities by which records are created, registered,
preserved, retrieved, browsed, and destructed.
When constraints are required for records management in the cloud, cloud records managers can
establish records management policies and procedures for those constraints, and may make specific
demands from cloud service providers as needed. For example, a cloud records manager may require
a private cloud service provider to store records in a separate repository. The cloud records manager
may ask the cloud service provider for access control policy on the records.
The cloud records manager manages access to records by setting the access level of each cloud records
and specifying the access rights of cloud records users. The access rights of cloud records users are
specified depending on their role, seniority, security clearance, location, etc.
The cloud records manager periodically monitors the registration and classification of records, their
preservation status, and security mechanisms. Cloud records managers can maintain records stability
and security quality beyond a certain level through the cloud SLA contract with a cloud service provider.
In addition, the cloud records manager establishes a disaster recovery plan in advance with the cloud
service provider in order to resolve any potential problem related to records within the cloud service.
4.2.4 Cloud records user
A cloud records user is an entity (such as an individual, team, or organization) that searches, accesses,
or browses records through cloud services. Cloud records users are authenticated to cloud service
providers before they use records. Cloud records users' authorization to access to cloud records is
managed by the cloud records manager.
4.3 Cloud records management service provider
4.3.1 General
Cloud service providers are classified as IaaS providers, PaaS providers, and SaaS providers, depending
on the capabilities they provide, and have the roles and responsibilities necessary to perform secure
and reliable digital records management.
4.3.2 Records management SaaS provider
A records management SaaS provider is a party that provides application services for records
...

TECHNICAL ISO/TR
REPORT 22428-1
First edition
Information and documentation —
Records management in the cloud —
Part 1:
Issues and concerns
PROOF/ÉPREUVE
Reference number
ISO/TR 22428-1:2020(E)
©
ISO 2020

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ISO/TR 22428-1:2020(E)

COPYRIGHT PROTECTED DOCUMENT
© ISO 2020
All rights reserved. Unless otherwise specified, or required in the context of its implementation, no part of this publication may
be reproduced or utilized otherwise in any form or by any means, electronic or mechanical, including photocopying, or posting
on the internet or an intranet, without prior written permission. Permission can be requested from either ISO at the address
below or ISO’s member body in the country of the requester.
ISO copyright office
CP 401 • Ch. de Blandonnet 8
CH-1214 Vernier, Geneva
Phone: +41 22 749 01 11
Email: copyright@iso.org
Website: www.iso.org
Published in Switzerland
ii PROOF/ÉPREUVE © ISO 2020 – All rights reserved

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ISO/TR 22428-1:2020(E)

Contents Page
Foreword .v
Introduction .vi
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Stakeholder model . 4
4.1 General . 4
4.2 Cloud records management service customer . 5
4.2.1 General. 5
4.2.2 Cloud records producer . 5
4.2.3 Cloud records manager . 6
4.2.4 Cloud records user . 6
4.3 Cloud records management service provider . 6
4.3.1 General. 6
4.3.2 Records management SaaS provider . 6
4.3.3 PaaS provider . 7
4.3.4 IaaS provider . 7
4.4 Cloud records management service partner . 7
4.4.1 Cloud records management agent . 7
4.4.2 Cloud records management auditor . 7
5 Cloud records management environments . 8
5.1 General . 8
5.2 Records management processes in the cloud environment . 8
5.3 Metadata in cloud records management services . 9
5.4 Cloud reference architecture for managing authoritative records .10
6 Use cases in cloud records management .11
6.1 General .11
6.2 SaaS shared by customers .12
6.3 SaaS developed by customers .13
6.4 Records management based on IaaS .13
6.5 Multiple IaaS used by customers .14
6.6 Records management agent .15
7 Risks in cloud records system .16
7.1 General .16
7.2 Cloud service risks .16
7.3 Cloud system risks .18
7.4 Cloud stakeholder risks .19
8 Social and legal issues of cloud services .19
8.1 General .19
8.2 Legal issues .20
8.2.1 General.20
8.2.2 Cross-border data jurisdictional issues .20
8.2.3 Inability to enforce contractual terms .20
8.2.4 Non-negotiable licensing terms .21
8.2.5 Data ownership issues .21
8.2.6 Conflict between the terms and conditions .21
8.3 Social issues .21
8.3.1 General.21
8.3.2 Limitations of technical security .22
8.3.3 Social impact of personal information leakage accidents .22
8.3.4 Unavailability of personal records.23
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ISO/TR 22428-1:2020(E)

8.3.5 Risk of long-term preservation of records in the cloud service .23
Bibliography .24
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ISO/TR 22428-1:2020(E)

Foreword
ISO (the International Organization for Standardization) is a worldwide federation of national standards
bodies (ISO member bodies). The work of preparing International Standards is normally carried out by
ISO technical committees. Each member body interested in a subject has the right to be represented on
the relevant technical committee if such committee has been established. International organizations,
governmental and non-governmental, in liaison with ISO, also take part in the work. ISO collaborates
closely with the International Electro-technical Commission (IEC) on all matters related to electro-
technical standardization.
The procedures used to develop the present document and those intended for its further maintenance
are described in the ISO/IEC Directives, Part 1. In particular, the various approval criteria needed for
different types of ISO documents should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www .iso .org/ directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. ISO shall not be held responsible for identifying any or all such patent rights. Details of
any patent rights identified during the development of the document will be listed in the Introduction
and/or on the ISO list of patent declarations received (see www .iso .org/ patents).
Any trade name used in this document is given for the purpose of information for users’ convenience
and does not constitute an endorsement.
For an explanation of the voluntary nature of standards, the meaning of ISO-specific terms and
expressions related to conformity assessment, as well as information on ISO's adherence to the World
Trade Organization (WTO) principles in the Technical Barriers to Trade (TBT), see www .iso .org/ iso/
foreword .html.
This document was prepared by Technical Committee ISO/TC 46, Information and documentation,
Subcommittee SC 11, Archives/records management.
A list of all parts in the ISO 22428 series can be found on the ISO website.
Any feedback or questions on this document should be directed to the user’s national standards body. A
complete listing of these bodies can be found at www .iso .org/ members .html.
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ISO/TR 22428-1:2020(E)

Introduction
A cloud service refers to capabilities offered via cloud computing where users can borrow, to use
flexibly, physical or virtual resources which include software and platform, as well as computing
infrastructure, such as data storage and computing servers. The cloud service offers benefits, such as
dynamic scalability, enhanced organizational agility, resilience and cost reduction, enabling improved
organizational competitiveness and efficiency. Cloud services are emerging as an essential aspect of
information technology due to location-independent resource sharing, availability via the Internet and
mobile devices, and the ability to deliver on-demand services and lower costs.
Currently, the explosive growth of digital content through mobile platforms and the Internet of things
is driving organizations to move their computing systems and information assets to the cloud. As a
result, a number of companies and government organizations have shifted their business systems to
cloud services, and many other organizations are planning to adopt cloud services. In the near future, it
is expected that most data will be processed and stored in cloud services.
Cloud services might prove to be an alternative for organizations that are reluctant to invest in
establishing their own computer systems for digital records management. Cloud services can provide
the software, hardware, and platform needed to implement a system for records at an affordable price.
It is often not easy for an organization to implement a system for records that meets all the criteria set
out in ISO 15489-1. If there is a cloud service that satisfies all the criteria set out in ISO 15489-1 and
which is provided at a low price, organizations have good reasons to consider using the cloud service.
However, organizations can be reluctant to adopt cloud services for their records management due
to unknown risks, safety and privacy concerns, and an absence of convincing use cases. While the
advantages of cloud services are well-advertised, awareness of the risks and issues that should be taken
into account in a records management context is often lacking.
Cloud services are based on the concept of borrowing computing resources provided by third
parties. The functions, processes or architectures inside the cloud are not disclosed externally. Even
if a customer agrees with a cloud service provider about their requirements, it is difficult to know
in advance whether their requirements can be met. In particular, it can be very difficult for general-
purpose cloud services to fully satisfy the requirements of the records management process. There are
various types of cloud services according, each of which offers different capabilities. In order to apply a
cloud service to the records management task, the customer could select a cloud service that is suitable
for the characteristics of the records management. The customer also to understands the general
characteristics of cloud services. Otherwise, there is a possibility that desired records management
outcomes will not be able to be delivered after adopting a cloud service.
In addition, in the case of large cloud services, cloud systems can be distributed around the world
transcending national borders. Users from various countries or regional communities can share a cloud
service belonging to a particular country. These characteristics of the cloud can cause various conflicts
and issues because the jurisdictional structure and social environment of the country where the cloud
service provider belongs is different from those of the cloud users. As a result, cloud users can be faced
with unexpected risks associated with immature legal and social agreements for cloud technology.
Therefore, when records managers introduce cloud services to records management, they should
consider the legal and social aspects as well as the technical aspects in advance in order to prepare for
potential risks. Records managers can provide cloud service providers with prerequisites for managing
risks, specified in contracts to reduce the probability of risks coming to fruition. This document aims
to provide guidelines for persons and organizations who are intend to adopt cloud services for records
management.
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---------------------- Page: 6 ----------------------
TECHNICAL REPORT ISO/TR 22428-1:2020(E)
Information and documentation — Records management
in the cloud —
Part 1:
Issues and concerns
1 Scope
This document presents a model for cloud records management and outlines the risks and issues that
are considered by records managers before adopting cloud services for records management. The
model for cloud records management includes a stakeholder model, processes, metadata, architecture,
and use cases. Risks and issues are classified into those originating from cloud services internally and
those originating from cloud services externally. Internal risks are associated with cloud services,
systems and stakeholders. External risks and issues can occur in the social and legal context in which
cloud services operate.
The target audience of this document includes:
— records, information, knowledge, and governance professionals;
— cloud service architects;
— archivists using cloud services for managing records;
— developers of cloud-deployed records management software;
— ICT staff; and
— providers of cloud-based records management services.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
ISO 30300, Information and documentation — Management system for records — Core concepts and
vocabulary
ISO 13008, Information and documentation — Digital records conversion and migration process
ISO/IEC 17788, Information technology — Cloud computing — Overview and vocabulary
3 Terms and definitions
For the purposes of this document, the terms and definitions given in ISO 30300, ISO 13008,
ISO/IEC 17788 and the following apply.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https:// www .iso .org/ obp
— IEC Electropedia: available at http:// www .electropedia .org/
© ISO 2020 – All rights reserved PROOF/ÉPREUVE 1

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ISO/TR 22428-1:2020(E)

3.1
cloud computing
paradigm for enabling network access to a scalable and elastic pool of shareable physical or virtual
resources with self-service provisioning and administration on-demand
[SOURCE: ISO/IEC 17788:2014, 3.2.5]
Note 1 to entry: Examples of resources include servers, operating systems, networks, software, applications, and
storage equipment.
3.2
cloud capability type
classification of the functionality provided by a cloud service to the cloud service customer, based on
the nature of resources used
[SOURCE: ISO/IEC 17788:2014, 3.2.4]
3.3
cloud deployment model
ways in which cloud computing (3.1) can be organized based on the control and sharing of physical or
virtual resources
[SOURCE: ISO/IEC 17788:2014, 3.2.7]
3.4
cloud records
digital records created, preserved or managed by a cloud service
3.5
cloud records management
records management entrusted to cloud service
3.6
cloud records management service customer
party that is in a business relationship with the records management service provider for the purpose
of using cloud records management services
3.7
cloud records management service partner
party that is engaged in support of, or as auxiliary to, activities of either the cloud records management
service provider (3.8) or the cloud records management service customer (3.6), or both
3.8
cloud records management service provider
party that makes cloud records management (3.5)services available
3.9
cloud service
one or more capabilities offered via cloud computing (3.1) invoked using a defined interface
[SOURCE: ISO/IEC 17788:2014, 3.2.8]
3.10
cloud service customer
party which is in a business relationship for the purpose of using cloud services (3.9)
[SOURCE: ISO/IEC 17788:2014, 3.2.11]
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ISO/TR 22428-1:2020(E)

3.11
cloud SLA
cloud service level agreement
part of the cloud service agreement that includes cloud service level objectives and cloud service
qualitative objectives for the covered cloud service(s)
[SOURCE: ISO/IEC 19086-1:2016, 3.4]
3.12
cloud service provider
party which makes cloud services (3.9) available
[SOURCE: ISO/IEC 17788:2014, 3.2.15]
3.13
IaaS
Infrastructure as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the infrastructure capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.24]
3.14
multi-tenancy
allocation of physical or virtual resources such that multiple tenants (3.21) and their computations and
data are isolated from and inaccessible to one another
[SOURCE: ISO/IEC 17788:2014, 3.2.27]
3.15
PaaS
Platform as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the platform capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.30]
3.16
private cloud
cloud deployment model (3.3) where cloud services (3.9) are used exclusively by a single cloud service
customer (3.10) and resources are controlled by that cloud service customer
[SOURCE: ISO/IEC 17788:2014, 3.2.32]
3.17
public cloud
cloud deployment model (3.3) where cloud services (3.9) are potentially available to any cloud service
customer (3.10) and resources are controlled by the cloud service provider (3.12)
[SOURCE: ISO/IEC 17788:2014, 3.2.33]
3.18
SaaS
Software as a Service
cloud service category in which the cloud capabilities type (3.2) provided to the cloud service customer
is of the application capabilities type
[SOURCE: ISO/IEC 17788:2014, 3.2.36]
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ISO/TR 22428-1:2020(E)

3.19
SOA
Service Oriented Architecture
architectural style that supports service orientation and is a paradigm for building business solutions
using IT
[SOURCE: ISO/IEC 18384-1:2016, 2.48; ISO/IEC TR 30102:2012]
3.20
SORMA
Service Oriented Records Management Architecture
reference architecture model for records management based on cloud services, which includes service
components for supporting records management in the form of SOA (3.19)
3.21
tenant
one or more cloud service users sharing access to a set of physical and virtual resources
[SOURCE: ISO/IEC 17788:2014, 3.2.37]
4 Stakeholder model
4.1 General
The cloud stakeholder model in this document is borrowed from the service model provided by
ISO/IEC 17788, and extends it to the records management domain. A cloud records management service
customer is a party that enters a business relationship with a cloud records management service
provider for the purpose of using cloud records management services. A cloud records management
service provider is a party that makes cloud records management services available. A cloud records
management service partner is a party that is engaged in support of, or as auxiliary to, activities of
either the cloud records management service provider or the cloud records management service
customer, or both.
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ISO/TR 22428-1:2020(E)

Key
  party
  entity
Figure 1 — Cloud records management stakeholder model
4.2 Cloud records management service customer
4.2.1 General
Cloud records management service customers use cloud services to produce, transmit, maintain, and
dispose of digital records and metadata. Customers strive to negotiate records management policies
and procedures with cloud service providers on prior to entering the service contract. Customers can
have cloud SLA contracts with cloud service providers to ensure confidence in the quality of records
management.
Customers can be divided into several entities (individuals, teams, organizations) based on their
records management role internally as follows:
— cloud records producer;
— cloud records manager;
— cloud records user.
4.2.2 Cloud records producer
Cloud records producers use cloud records management services to produce reliable records. This
means that the cloud records producer ensures the authenticity, integrity, and reliability of the records
by means of a cloud service. Cloud records producers inspect the records they write and verify that the
records are stored in the cloud service without compromising their attributes.
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ISO/TR 22428-1:2020(E)

When creating a record, cloud records producers are able to generate metadata that includes business
context and verify that the metadata are generated without distortion. Cloud records producers is
responsible for verifying that metadata are registered and preserved at a cloud service.
4.2.3 Cloud records manager
Cloud records managers have the responsibility of managing the records of their organization using
cloud records management services. The cloud records manager leverages cloud services to perform
administrative tasks such as registration and preservation of records, migration and conversion,
search/query requests, verification of records integrity, and user authentication. The cloud records
manager is expected to be familiar with the data management policies of the cloud service provider
before using the cloud service, and consult with the cloud service provider if necessary.
The cloud records manager is responsible for reviewing the cloud service, ensuring that all requirements
that arise from business and stakeholder expectations and the organization’s regulatory environment
can be met. The cloud records manager is responsible for inspecting the cloud service to see whether
there are any constraints or problems in the functionalities by which records are created, registered,
preserved, retrieved, browsed, and destructed.
When constraints are required for records management in the cloud, cloud records managers can
establish records management policies and procedures for those constraints, and may make specific
demands from cloud service providers as needed. For example, a cloud records manager may require
a private cloud service provider to store records in a separate repository. The cloud records manager
may ask the cloud service provider for access control policy on the records.
The cloud records manager manages access to records by setting the access level of each cloud records
and specifying the access rights of cloud records users. The access rights of cloud records users are
specified depending on their role, seniority, security clearance, location, etc.
The cloud records manager periodically monitors the registration and classification of records, their
preservation status, and security mechanisms. Cloud records managers can maintain records stability
and security quality beyond a certain level through the cloud SLA contract with a cloud service provider.
In addition, the cloud records manager establishes a disaster recovery plan in advance with the cloud
service provider in order to resolve any potential problem related to records within the cloud service.
4.2.4 Cloud records user
A cloud records user is an entity (such as an individual, team, or organization) that searches, accesses,
or browses records through cloud services. Cloud records users are authenticated to cloud service
providers before they use records. Cloud records users' authorization to access to cloud records is
managed by the cloud records manager.
4.3 Cloud records management service provider
4.3.1 General
Cloud service providers are classified as IaaS providers, PaaS providers, and SaaS providers, depending
on the capabilities they provide, and have the roles and responsibilities necessary to perform secure
and reliable digital records management.
4.3.2 Records management SaaS provider
A records management SaaS provider is a party
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