‘What is’ and ‘How can’ series Part 4: Long-Term Cloud Storage

Welcome to the fourth posting in our series about ‘what is’ a particular area of regulatory concern and ‘how can’ RegDOX provide a solution. If you missed a previous post in this series, no worries! You can find all our blog posts here!

In this posting, we will first discuss various federal regulatory requirements for extended retention of CUI (Controlled Unclassified Information), such as ITAR-defined Technical Data.  Then we will review how  RegDOX® Long-Term Cloud Storage (LTS) for CUI is intended to allow companies to meet these requirements while maintaining unbroken regulatory compliance.

What are some of the U.S. federal requirements for extended retention of CUI?

There are a number of formal and informal federal retention requirements for CUI. You should retain expert advice on which apply to your company, but to illustrate what is required, here are some of the more familiar of those dealing with export and trade-related controls (EAR, ITAR, EEI, CBP, and OFAC) and, of course, defense procurement (DFARS):

• EAR: As a general rule the Department of Commerce’s Bureau of Industry and Security (BIS) has a five-year period of retention of export documents.  See 15 CFR §762.6. The period is measured from several possible events, such as the export, re-export, or transshipment of the covered item, etc.
• ITAR:  Records must be kept for a five-year period from the expiration of the license or other approval. In the case of a customs drawback, all records relating to the drawback must be kept for three years after the date of payment of the claim.  See 22 CFR §122.5.
• EEI (Foreign Trade Regulations/ Electronic Export Information): Records must be kept five years from the date of export or longer when required by other regulations.  See 15 CFR §§ 30.10 & 30.15 (c).
• CBP (U.S. Customs and Border Protection): Subject to specified exceptions allowing shorter periods, records that must be submitted to the agency must be kept five years from the date of entry, and records otherwise relating to an entry must be kept from the date of the activity that required the record to be created.  See 19 CFR §163.4.
• OFAC (Office of Foreign Assets Control): Records must be kept for five years after the transaction covered by the regulation, unless a transaction was blocked, in which case the period is five years after the property is blocked or unblocked.  See 31 CFR §501.601.
• DFARS: Generally, records shall be retained for three years after final payment or longer if specified in a contract, with certain financial documents retained for four years (See FARS Subpart §4.7).

   

  –     NARA (National Archives and Records Administration): All contract files must be retained for a period of six years after final payment.

What is  RegDOX® Long-Term Cloud Storage Solution (LTS) for CUI compliance?

The LTS is available to RegDOX’s enterprise customers and provides a price-efficient, always available, and stable alternative to retaining CUI that is not needed for production purposes, but must be retained during the federally specified retention periods.

The LTS from RegDOX works seamlessly in conjunction with a customer’s production RegDOX Data Room Secure Storage and Collaboration solution.  Individual items of content, as well as entire folder collections and data rooms, can easily be transferred back and forth between the two accounts while retaining persistent security controls and tracking.

What are the goals of  RegDOX® LTS?

 RegDOX achieves three primary goals of its customers in providing this service.

1. Ensures that all archived CUI is maintained without interruption in a safe, secure, and regulatory compliant environment
2. allows persistent storage to be as price effective as possible
3. Maintains a complete, unalterable, and reportable audit history of the retain content, such as is required for CUI.

It is important that companies have immediate access to all content, whether in production or long-term storage, and RegDOX’s LTS achieves that goal.  Content may be moved by the Customer at any time directly from the Production DRC to the Storage DRC and later directly back to the Production DRC, thus allowing for flexible, as well as very price-effective storage.

You can learn more about your company’s long-term electronic file storage needs and how RegDOX can help by Downloading our Long-Term Cloud Storage Whitepaper.

Also, we would welcome you Contacting us for more info!