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This post will focus on Information Compliance, the fourth and final part of the four-part series this week.I have received a few queries on my choice of sequence for this series: Availability, Security, Retention andCompliance.
Why not have them in alphabetical order? IBM avoids alphabetizing in one language, because thenit may not be alphabetized when translated to other languages.
Why not have them in a sequence that spells outan easy to remember mnemonic, like "CARS"? Again, when translated to other languages, those mnemonics no longerwork.
Instead, I worked with our marketing team for a more appropriate sequence, based on psychology and the cognitive bias of [primacy and recency effects].
Here's another short 2-minute video, on Information Compliance
Full disclosure: I am not a lawyer. The following will delveinto areas related to government and industry regulations. Consultyour risk officer or legal counsel to make sure any IT solution is appropriatefor your country, your industry, or your specific situation.
IBM estimates there are over 20,000 regulations worldwide related to information storage and transmission.
For information availability, some industry regulations mandate a secondary copy a minimum distance away toprotect against regional disasters like hurricanes or tsunamis.IBM offers Metro Mirror (up to 300km) and Global Mirror (unlimited distance) disk mirroring to support theserequirements.
For information security, some regulations relate to privacy and prevention of unauthorized access. Twoprominent ones in the United States are:
Health Insurance Portability and Accountability Act (HIPAA) of 1996
HIPAA regulates health care providers, health plans, and health care clearinghouses in how they handle the privacy of patient's medical records. These regulations apply whether the information is on film, paper, or storedelectronically. Obviously, electronic medical records are easier to keep private. Here is an excerpt froman article from [WebMD]:
"There are very good ways to protect data electronically. Although it sounds scary, it makes data more protected than current paper records. For example, think about someone looking at your medical chart in the hospital. It has a record of all that is happening -- lab results, doctor consultations, nursing notes, orders, prescriptions, etc. Anybody who opens it for whatever reason can see all of this information. But if the chart is an electronic record, it's easy to limit access to any of that. So a physical therapist writing physical therapy notes can only see information related to physical therapy. There is an opportunity with electronic records to limit information to those who really need to see it. It could in many ways allow more privacy than current paper records."
GLBA regulates the handling of sensitive customer information by banks, securities firms, insurance companies, and other financial service providers. Financial companies use tape encryption to comply with GLBA when sending tapes from one firm to another. IBM was the first to deliver tape drive encryption withthe TS1120, and then later with LTO-4 and TS1130 tape drives.
For information retention, there are a lot of regulations that deal with how information is stored, in some casesimmutable to protect against unethical tampering, and when it can be discarded. Two prominent regulations inthe United States are:
U.S. Securities and Exchange Commission (SEC) 17a-4 of 1997
In the past, the IT industryused the acronym "WORM" which stands for the "Write Once, Read Many" nature of certain media, like CDs, DVDs,optical and tape cartridges. Unfortunately, WORM does not apply to disk-based solutions, so IBM adopted the languagefrom SEC 17a-4 that calls for storage that is "Non-Erasable, Non-Rewriteable" or NENR. This new umbrella term applies to disk-based solutions, as well as tape and optical WORM media.
SEC 17a-4 indicates that broker/dealers and exchange members must preserve all electronic communications relating to the business of their firmm a specific period of time. During this time, the information must not be erased or re-written.
Sarbanes-Oxley (SOX) Act of 2002
SOX was born in the wake of [Enron and other corporate scandals]. It protects the way that financial information is stored, maintained and presented to investors, as well as disciplines those who break its rules. It applies onlyto public companies, i.e. those that offer their securities (stock shares, bonds, liabilities) to be sold to the publicthrough a listing on a U.S. exchange, such as NASDAQ or NYSE.
SOX focuses on preventing CEOs and other executives from tampering the financial records.To meet compliance, companies are turning to the [IBM System Storage DR550] which providesNon-erasable, Non-rewriteable (NENR) storage for financial records. Unlike competitive products like EMC Centera thatfunction mostly as space-heaters on the data center floor once they filled up, the DR550 can be configured as a blended disk-and-tape storage system, so that the most recent, and most likely to be accessed data, remains on disk, but the older, least likely to be accessed data, is moved automatically to less expensive, more environment-friendly "green" tape media.
Did SOX hurt the United States' competitiveness? Critics feared that these new regulations would discourage newcompanies from going public. Earnst & Young found these fears did not come true, and published a study [U.S. Record IPO Activity from 2006 Continues in 2007]. In fact, the improved confidence that SOX has given investors has given rise to similarlegislation in other parts of the world: Euro-Sox for the European Union Investor Protection Act, and J-SOX Financial Instruments and Exchange Law for Japan.
For those who only read the first and last paragraphs of each post, here is my recap:Information Compliance is ensuring that information is protected against regional disasters, unauthorizedaccess, and unethical tampering, as required to meet industry and government regulations. Such regulationsoften apply if the information is stored on traditional paper or film media, but can often be handled more cost-effectively when stored electronically. Appropriate IT governance can help maintain investor confidence.
In Monday's post, [IBM Information Infrastructure launches today], I explained how this strategic initiative fit into IBM's New EnterpriseData Center vision. The launch was presented at the IBM Storage and Storage Networking Symposium to over 400 attendeesin Montpelier, France, with corresponding standing-room-only crowds in New York and Tokyo.
This post will focus on Information Retention, the third of the four-part series this week.
Here's another short 2-minute video, on Information Retention
Let's start with some interesting statistics.Fellow blogger Robin Harris on his StorageMojo blog has an interesting post:[Our changing file workloads],which discusses the findings of study titled"Measurement and Analysis of Large-Scale Network File System Workloads"[14-page PDF]. This paper was a collaborationbetween researchers from University of California Santa Cruz and our friends at NetApp.Here's an excerpt from the study:
Compared to Previous Studies:
Both of our workloads are more write-oriented. Read to write byte ratios have significantly decreased.
Read-write access patterns have increased 30-fold relative to read-only and write-only access patterns.
Most bytes are transferred in longer sequential runs. These runs are an order of magnitude larger.
Most bytes transferred are from larger files. File sizes are up to an order of magnitude larger.
Files live an order of magnitude longer. Fewer than 50 percent are deleted within a day of creation.
Files are rarely re-opened. Over 66 percent are re-opened once and 95% fewer than five times.
Files re-opens are temporally related. Over 60 percent of re-opens occur within a minute of the first.
A small fraction of clients account for a large fraction of file activity. Fewer than 1 percent of clients account for50 percent of file requests.
Files are infrequently shared by more than one client. Over 76 percent of files are never opened by more than one client.
File sharing is rarely concurrent and sharing is usually read-only. Only 5 percent of files opened by multiple clients are concurrent and 90 percent of sharing is read-only.
Most file types do not have a common access pattern.
Why are files being kept ten times longer than before? Because the information still has value:
Provide historical context
Gain insight to specific situations, market segment demographics, or trends in the greater marketplace
Help innovate new ideas for products and services
Make better, smarter decisions
National Public Radio (NPR) had an interesting piece the other day. By analyzing old photos, a researcher for Cold War Analysis was able to identify an interesting [pattern for Russian presidents]. (Be sure to listen to the 3-minute audio to hear a hilarious song about the results!)
Which brings me to my own collection of "old photos". I bought my first digital camera in the year 2000,and have taken over 15,000 pictures since then. Before that,I used 35mm film camera, getting the negatives developed and prints made. Some of these date back to my years in High School and College. I have a mix of sizes, from 3x5, 4x6 and 5x7 inches,and sometimes I got double prints.Only a small portion are organized intoscrapbooks. The rest are in envelopes, prints and negatives, in boxes taking up half of my linen closet in my house.Following the success of the [Library of Congress using flickr],I decided the best way to organize these was to have them digitized first. There are several ways to do this.
This method is just too time consuming. Lift the lid place 1 or a few prints face down on the glass, close the lid,press the button, and then repeat. I estimate 70 percent of my photos are in [landscape orientation], and 30 percent in [portrait mode]. I can either spend extra time toorient each photo correctly on the glass, or rotate the digital image later.
I was pleased to learn that my Fujitsu ScanSnap S510 sheet-feed scanner can take in a short stack (dozen or so) photos, and generate JPEG format files for each. I can select 150, 300 or 600dpi, and five levels of JPEG compression.All the photos feed in portrait mode, which I can then rotate later on the computer once digitized.A command line tool called [ImageMagick] can help automate the rotations.While I highly recommend the ScanSnap scanner, this is still a time-consuming process for thousands of photos.
"The best way to save your valuable photos may be by eliminating the paper altogether. Consider making digital images of all your photos."
Here's how it works:You ship your prints (or slides, or negatives) totheir facility in Irvine, California. They have a huge machine that scans them all at 300dpi, no compression, andthey send back your photos and a DVD containing digitized versions in JPEG format, all for only 50 US dollars plusshipping and handling, per thousand photos. I don't think I could even hire someone locally to run my scanner for that!
The deal got better when I contacted them. For people like me with accounts on Facebook, flickr, MySpace or Blogger,they will [scan your first 1000 photos for free] (plus shipping and handling). I selected a thousand 4x6" photos from my vast collection, organized them into eight stacks with rubber bands,and sent them off in a shoe box. The photos get scanned in landscape mode, so I had spent about four hours in preparing what I sent them, making sure they were all face up, with the top of the picture oriented either to the top or left edge.For the envelopes that had double prints, I "deduplicated" them so that only one set got scanned.
The box weighed seven pounds, and cost about 10 US dollars to send from Tucson to Irvinevia UPS on Tuesday. They came back the following Monday, all my photos plus the DVD, for 20 US dollars shipping and handling. Each digital image is about 1.5MB in size, roughly 1800x1200 pixels in size, so easily fit on a single DVD. The quality is the sameas if I scanned them at 300dpi on my own scanner, and comparable to a 2-megapixel camera on most cell phones.Certainly not the high-res photos I take with my Canon PowerShot, but suitable enough for email or Web sites. So, for about 30 US dollars, I got my first batch of 1000 photos scanned.
ScanMyPhotos.com offers a variety of extra priced options, like rotating each file to the correct landscape or portrait orientation, color correction, exact sequence order, hosting them on their Web site online for 30 days to share with friends and family, and extra copies of the DVD.All of these represent a trade-off between having them do it for me for an additional fee, or me spending time doing it myself--either before in the preparation, or afterwards managing the digital files--so I can appreciate that.
Perhaps the weirdest option was to have your original box returned for an extra $9.95? If you don't have a hugecollection of empty shoe boxes in your garage, you can buy a similarly sized cardboard box for only $3.49 at the local office supply store, so I don't understand this one. The box they return all your photos in can easily be used for the next batch.
I opted not to get any of these extras. The one option I think they should add would be to have them just discardthe prints, and send back only the DVD itself. Or better yet, discard the prints, and email me an ISO file of the DVD that I can burn myself on my own computer.Why pay extra shipping to send back to me the entire box of prints, just so that I can dump the prints in the trash myself? I will keep the negatives, in case I ever need to re-print with high resolution.
Overall, I am thoroughlydelighted with the service, and will now pursue sending the rest of my photos in for processing, and reclaim my linen closet for more important things. Now that I know that a thousand 4x6 prints weighs 7 pounds, I can now estimate how many photos I have left to do, and decide on which discount bulk option to choose from.
With my photos digitized, I will be able to do all the things that IBM talks about with Information Retention:
Place them on an appropriate storage tier. I can keep them on disk, tape or optical media.
Easily move them from one storage tier to another. Copying digital files in bulk is straightforward, and as new techhologies develop, I can refresh the bits onto new media, to avoid the "obsolescence of CDs and DVDs" as discussed in this article in[PC World].
Share them with friends and family, either through email, on my Tivo (yes, my Tivo is networked to my Mac and PC and has the option to do this!), or upload themto a photo-oriented service like [Kodak Gallery or flickr].
Keep multiple copies in separate locations. I could easily burn another copy of the DVD myself and store in my safe deposit box or my desk at work.With all of the regional disasters like hurricanes, an alternative might be to backup all your files, including your digitized photos, with an online backup service like [IBM Information Protection Services] from last year's acquisition of Arsenal Digital.
If the prospect of preserving my high school and college memories for the next few decades seems extreme,consider the [Long Now Foundation] is focused on retaining information for centuries.They areeven suggesting that we start representing years with five digits, e.g., 02008, to handle the deca-millennium bug which will come into effect 8,000 years from now. IBM researchers are also working on [long-term preservation technologies and open standards] to help in this area.
For those who only read the first and last paragraphs of each post, here is my recap:Information Retention is about managing [information throughout its lifecycle], using policy-based automation to help with the placement, movement and expiration. An "active archive" of information serves to helpgain insight, innovate, and make better decisions. Disk, tape, and blended disk-and-tape solutions can all play a part in a tiered information infrastructure for long-term retention of information.
Earlier this year, IBM launched its[New Enterprise Data Center vision]. The average data center was built 10-15 years ago,at a time when the World Wide Web was still in its infancy, some companies were deploying their first storage areanetwork (SAN) and email system, and if you asked anyone what "Google" was, they might tell you it was ["a one followed by a hundred zeros"]!
Full disclosure: Google, the company, justcelebrated its [10th anniversary] yesterday, and IBM has partnered with Google on a varietyof exciting projects. I am employed by IBM, and own stock in both companies.
In just the last five years, we saw a rapid growth in information, fueled by Web 2.0 social media, email, mobile hand-held devices, and the convergenceof digital technologies that blurs the lines between communications, entertainment and business information. This explosion in information is not just "more of the same", but rather a dramatic shift from predominantly databases for online transaction processing to mostly unstructured content. IT departments are no longer just the"back office" recording financial transactions for accountants, but now also take on a more active "front office" role. For a growing number of industries, information technology plays a pivotal role in generating revenue, making smarter business decisions, and providing better customer service.
IBM felt a new IT model was needed to address this changing landscape, so IBM's New Enterprise Data Center vision has these five key strategic initiatives:
Highly virtualized resources
Business-driven Service Management
Green, Efficient, Optimized facilities
In February, IBM announced new products and features to support the first two initiatives, including the highlyvirtualized capability of the IBM z10 EC mainframe, and and related business resiliency features of the [IBM System Storage DS8000 Turbo] disk system.
In May, IBM launched its Service Management strategic initiative at the Pulse 2008 conference. I was there in Orlando, Florida at the Swan and Dolphin resort to present to clients. You can read my three posts:[Day 1; Day 2 Main Tent; Day 2 Breakout sessions].
In June, IBM launched its fourth strategic initiative "Green, Efficient and Optimized Facilities" with [Project BigGreen 2.0], which included the Space-Efficient Volume (SEV) and Space-Efficient FlashCopy (SEFC) capabilitiesof the IBM System Storage SAN Volume Controller (SVC) 4.3 release. Fellow blogger and IBM master inventor Barry Whyte (BarryW) has three posts on his blog about this:[SVC 4.3.0Overview; SEV and SEFCdetail; Virtual Disk Mirroring and More]
Some have speculated that the IBM System Storage team seemed to be on vacation the past two months, with few pressreleases and little or no fanfare about our July and August announcements, and not responding directly to critics and FUD in the blogosphere.It was because we were holding them all for today's launch, taking our cue from a famous perfume commercial:
"If you want to capture someone's attention -- whisper."
My team and I were actually quite busy at the [IBM Tucson Executive Briefing Center]. In between doing our regular job talking to excited prospects and clients,we trained sales reps and IBM Business Partners, wrote certification exams, and updated marketing collateral. Fortunately, competitors stopped promotingtheir own products to discuss and demonstrate why they are so scared of what IBM is planning.The fear was well justified. Even a few journalists helped raise the word-of-mouth buzz and excitement level. A big kiss to Beth Pariseau for her article in [SearchStorage.com]!
(Last week we broke radio silence to promote our technology demonstration of 1 million IOPS using Solid StateDisk, just to get the huge IBM marketing machine oiled up and ready for today)
Today, IBM General Manager Andy Monshaw launchedthe fifth strategic initiative, [IBM Information Infrastructure], at the[IBM Storage and Storage Networking Symposium] in Montpellier, France. Montpellier is one of the six locations of our New Enterprise Data Center Leadership Centers launched today. The other five are Poughkeepsie, Gaithersburg, Dallas, Mainz and Boebligen, with more planned for 2009.
Although IBM has been using the term "information infrastructure" for more than 30 years, it might be helpful to define it for you readers:
“An information infrastructure comprises the storage, networks, software, and servers integrated and optimized to securely deliver information to the business.”
In other words, it's all the "stuff" that delivers information from the magnetic surface recording of the disk ortape media to the eyes and ears of the end user. Everybody has an information infrastructure already, some are just more effective than others. For those of you not happy with yours, IBM hasthe products, services and expertise to help with your data center transformation.
IBM wants to help its clients deliver the right information to theright people at the right time, to get the most benefits of information, while controlling costs and mitigatingrisks. There might be more than a dozen ways to address the challenges involved, but IBM's Information Infrastructure strategic initiative focuses on four key solution areas:
Last, but not least, I would like to welcome to the blogosphere IBM's newest blogger, Moshe Yanai, formerly the father of the EMC Symmetrix and now leading the IBM XIV team. Already from his first poston his new [ThinkStorage blog], I can tell he is not going to pullany punches either.
"The murals in restaurants are on par with the food in museums." --- Peter De Vries
The quote above applies to blogs as well. Those about competitive products of which the blogger has little to no hands-on experience tend to be terribly misleading or technically inaccurate. We saw this last month as Sun Microsystems' Jeff Savit tried to discuss the IBM System z10 EC mainframe.
This time, it comes from EMC bloggers discussing NetApp equipment, and by association, IBM System Storage N series gear.I was going to comment on the ridiculous posts by fellow bloggers from EMC about SnapLock compliance feature on the NetApp, but my buddies at NetApp had already done this for me, saving me the trouble.
The hysterical nature of writing from EMC, and the calm responses from NetApp, speak volumes about the culturesof both companies.
The key point is that none of the "Non-erasable, Non-Rewriteable" (NENR) storage out there are certified as compliant by any government agency on the planet. Governments just aren't in the business of certifying such things. The best you can get is a third-party consultant, such as [Cohasset Associates], to help make decisions that are best for each particular situation.
In addition to SnapLock on N series, IBM offers the [IBM System Storage DR550], WORM tape and optical systems, all of which have been deemed compliant to the U.S. Securities and Exchange Commission [SEC 17a-4] federal regulations by Cohasset Associates. For medical patient records and images like X-rays, IBM offers the Grid Medical Archive Solution [GMAS]designed to meet the requirements of the U.S. Health Insurance Portability and Accountability Act[HIPAA].For other government or industry regulations, consult with your legal counsel.
Two weeks ago, I mentioned in my post [Pulse 2008 - Day 2 Breakout sessions] thatHenk de Ruiter from ABN Amro bank presented his success storyimplementing Information Lifecycle Management (ILM) across hisvarious data centers. I am no stranger to ABN Amro, having helped "ABN" and "Amro" banks merge their mainframe data in 1991. Henk has agreed to let me share with my readers more ofthis success story here on my blog:
Back in December 2005, Henkand his colleagues had come to visit the IBM Tucson ExecutiveBriefing Center (EBC) to hear about IBM products and services. At the time, I was part of our "STG Lab Services" team that performed ILM assessments at client locations. I explained to ABN Amro that the ILM methodology does not requirean all-IBM solution, and that ILM could even provide benefits with their current mix of storage, software and service providers.The ABN Amro team liked what I had to say, andmy team was commissioned to perform ILM assessments atthree of their data centers:
Sao Paulo (Brazil)
Chicago, IL (USA)
Each data center had its own management, its owndecision making, and its own set of issues, so we structuredeach ILM assessment independently. When we presented our results,we showed what each data center could do better with their existing mixed bagof storage, software and service providers, and also showed howmuch better their life would be with IBM storage, software andservices. They agreed to give IBM a chance to prove it, and soa new "Global Storage Study" was launched to take the recommendationsfrom our three ILM studies, and flesh out the details to make aglobally-integrated enterprise work for them. Once completed,it was renamed the "Global Storage Solution" (GSS).
Henk summarized the above with "I am glad to see Tony Pearsonin the audience, who was instrumental to making this all happen."As with many client testimonials, he presented a few charts onwho ABN Amro is today, the 12th largest bank worldwide, 8th largest in Europe. They operate in 53 countries and manage over a trillioneuros in assets.
They have over 20 data centers, with about 7 PB of disk, and over20 PB of tape, both growing at 50 to 70 percent CAGR. About 2/3 of theiroperations are now outsourced to IBM Global Services, the remaining 1/3is non-IBM equipment managed by a different service provider.
ABN Amro deployed IBM TotalStorage Productivity Center, variousIBM System Storage DS family disk systems, SAN Volume Controller (SVC), Tivoli StorageManager (TSM), Tivoli Provisioning Manager (TPM), and several other products. Armed with these products, they performed the following:
Clean Up. IBM uses the term "rationalization" to relate to the assignment of business value, to avoid confusion with theterm "classification" which many in IT relate to identifyingownership, read and write authorization levels. Often, in theinitial phases of an ILM deployment, a portion of the data isdetermined to be eligible for clean up, either to move to a lower-cost tier or deleted immediately. ABN Amro and IBM set a goal to identifyat least 20 percent of their data for clean up.
New tiers. Rather than traditional "storage tiers" which are often justTier 1 for Fibre Channel disk and Tier 2 for SATA disk, ABN Amroand IBM came up with seven "information infrastructure tiers" thatincorporate service levels, availability and protection status.They are:
High-performance, Highly-available disk with Remote replication.
High-performance, Highly-available disk (no remote replication)
Mid-performance, high-capacity disk with Remote replication
Mid-performance, high-capacity disk (no remote replication)
Non-erasable, Non-rewriteable (NENR) storage employinga blended disk and tape solution.
Enterprise Virtual Tape Library with remote replicationand back-end physical tape
Mid-performance physical tape
These tiers are applied equally across their mainframe anddistributed platforms. All of the tiers are priced per "primary GB", so any additional capacity required for replication orpoint-in-time copies, either local or remote, are all folded into the base price.ABN Amro felt a mission-critical applicationon Windows or UNIX deserves the same Tier 1 service level asa mission-critical mainframe application. Exactly!
Deployed storage virtualization for disk and tape. Thisinvolved the SAN Volume Controller and IBM TS7000 series library.
Implemented workflow automation. The key product here is IBM Tivoli Provisioning Manager
Started an investigation for HSM on distributed. This would be policy-based space management to migrate lessfrequently accessed data to the TSM pool for Windows or UNIX data.
While the deployment is not yet complete, ABN Amro feels they have alreadyrecognized business value:
Reduced cost by identifying data that should be stored on lower tiers
Simplified management, consolidated across all operating systems (mainframe, UNIX, Windows)
Increased utilization of existing storage resources
Reduced manual effort through policy-based automation, which can lead to fewer human errors and faster adaptability to new business opportunities
Standardized backup and other operational procedures
Henk and the rest of ABN Amro are quite pleased with the progress so far,although recent developments in terms of the takeover of ABN AMRO by aconsortium of banks means that the model is only implemented so far in Europe. Further rollout depends on the storage strategy of the new owners. Nonetheless,I am glad that I was able to work with Henk, Jason, Barbara, Steve, Tom, Dennis, Craig and othersto be part of this from the beginning and be able to see it rollout successfully over the years.