GSA Office of the Chief Information Officer

September 29, 2011

Ms. Anne L. Weismann Citizens for Responsibility and Ethics in Washington 1400 Eye Street, NW, Suite 450 Washington, DC 20005 Dear Ms. Weismann: This letter responds to your Freedom of Information Act request dated June 24, 2011 (GSA FOIA number 198427) in which you seek records relating to "GSA's decision to move its email systems to Google's Gmail and to use Google Apps for its employees" as well as "considerations the GSA has made, and steps that the GSA has taken, or plans to take, to address records management issues in a cloud computing environment." GSA hereby grants your request, and copies of the following responsive documents are provided in the requested categories as follows: a) CREW request 1 -"All records reflecting the GSA's records management policies and data governance practices, and the development of these policies and practices, for the GSA's future cloud computing email system .... " GSA offers its Directive CIO 2160.2B, GSA Electronic Messaging and Related Services dated June 16, 2011; "Gmail Retention Policy Challenge and Strategy," dated March 26, 2011; and user training slides, "Record Keeping Implications for Move from Lotus Notes to Gmail." b) CREW request 2- "All records indicating steps the GSA has taken or plans to take to address record keeping requirements in a cloud computing environment including, but not limited to, any considerations given to NARA's Bulletin 2010-05, Guidance on Managing Records in Cloud Computing Environments .... " The NARA Bulletin 2010-05 dated September 08, 2010, was not published during the acquisition planning for the contract awarded November 30, 201 0; GSA used the best guidance we had at the time to develop its approach. Since publication of NARA Bulletin 201 0-05, GSA's Federal Acquisition Service has initiated an "e-mail as a service" acquisition in which records management is addressed. Information regarding this acquisition is publically available at https: I /www.ebuy.gsa.gov I advantage/ ebuy/start page.do.
U.S. General Services Administration 1275 Rrst Street, NE Washington, DC20417 www.gsa.gov

-2c) CREW request 10 - "All portions of contracts between Google, Unisys, Tempus Nova, or Acumen Solution and the GSA that show language reflecting record management considerations for the GSA's use of Google's Gmail, including, but not limited to, language set forth in the answer to question 8 in NARA Bulletin 2010-05." GSA is including a copy of the Unisys task order with redacted technical and price proposals. The Statement of Objectives and all pre-award documentation related to the solicitation are posted online at www.gsa.gov/emailcollaboration . We are partially denying the requested infonnation concerning the Unisys Award pursuant to the fourth statutory exemption under FOA that penn its an agency to withhold 'trade secrets and commercial and financial infonnation obtained from a person [that is] privileged or confidential." Commercial or financial infonnation is confidential "if disclosure of the infonnation is likely to (1) impair the Govemmenfs ability to obtain the necessary infonnation in the future; or (2) cause substantial harm to the competitive position from whom the infonnation was obtained." The infonnation contained in both the technical and price proposal, if released, could cause substantial, competitive hann to Unisys, and partners. d) In response to CREW request 11 - "All records reflecting communication between Google, Microsoft, Unisys, Tempus Nova, or Acumen Solution and the GSA regarding record management and compliance with records management laws in a cloud computing environment." Enclosed is a zip file of 13 e-mail messages related to Gmail records management. e) No GSA records exist in response to CREW requests 3, 4, 5, 6, 7, 8, or 9. You have the right to appeal the denial of records. To do so, you must write within 120 days of your receipt of this letter to the Freedom of Information Act Officer (ACMC), General Services Administration, 1275 First Street, NE, Washington, DC 20417. Your appeal must be in writing and should contain a brief statement of the reasons why the requested information should be released. Enclosed is a copy of your initial request and this denial. Both the appeal letter and envelope should be marked prominently, "Freedom of Information Act Appeal." Sincerely,

Casey Colem Chief Information Officer (I) Enclosures