Notes from Megameeting 16th November 2009
Attendees
Summary
There was a discussion of the meaning and implementation of "surveillance" and recertification, and of the distinction between Stage 1 and Stage 2 audits.
It was agreed that terms must be used consistently - they will either be inherited from the "parent" standards or should be defined in section 3.
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Transcript of chat
BruceAmbacher >> (All): My thought on recertification is five years due to
effort, costs, trying to win over repositories to undergo audit. Three years
is just too short.
Mark Conrad >> (All): 7.2.1.2 Management of the decision taking process - Is
there text missing?
BruceAmbacher >> (All): David, expand on your thoughts on Surveillance. What
"right" does the audit body have to snoop around in a certified repository?
Would this occue only when an egregious incident occurs? Or would it be a
constant passive oversight?
JohnGarrett >> (All): I think ISO 9000 has 3 years before recertification. I
think usually if your certification is active, they only do a spot check on a
few things for recertification. Do we do a full audit or only spot check
things fro the recertification?
David Giaretta >> (All): Bruce I have no views on surveillance other than that
I assume it works the same way as all other certifications. DO you think the
docuemnt suggests something special - if so it may be inherited from the
security document we borrowed text from and perhaps we can remove it.
David Giaretta >> (All): Mark - looks like missing text - we need to compare
with the Word doc
BruceAmbacher >> (All): No, I was just going from the General points at the top.
BruceAmbacher >> (All): John, I like that spot check, less than 100%
recertification. Has it been the same things in each recert or does it change
institution to institution based on weaknesses in the initial audit?
David Giaretta >> (All): John - yes, need to check but my recollection of STFC
ISO 9000 recertification was that it was not very thorough
BruceAmbacher >> (All): Presumably then the recert costs is not nearly as high.
RobertDowns >> (All): If we are going to consider recertification as early as
three years, we need to be sure that the costs are not prohibitive for small
repositories.
JohnGarrett >> (All): I'm not real plugged into what happens in the recerts, but
I think they have a different area or two that they look at each time for
recertification. I guess rotating through things so over time all the elements
are eventually rechecked. I don't know if it is based perhaps on any changes
the organization may have identified.
BruceAmbacher >> (All): ditto for the time investment
David Giaretta >> (All): Mark - checking with the Word doc it looks as if
7.2.1.2 is missing the name of the RAC documemnt
Mark Conrad >> (All): ok.
SimonLambert >> (All): David - yes - I assume because ref was in angle brackets
which the wiki treats specially.
TerryLongstreth >> (All): The recert process should probably be tailored to the
certification body's specs; some recert processing might occur as an outgrowth
of surveillance (which I interpret more as continuous monitoring, rather than
reconnaissance)
JohnGarrett >> (All): What is the best way to generate use/acceptance/discussion
of our document? 3 year or 5 year certifications?
David Giaretta >> (All): I suggest my "get out of jail free" card - say 3 years
of whatever time is specified by the initial audit committee
David Giaretta >> (All): .."3 years or whatever time is specified by the
initial audit committee"
BruceAmbacher >> (All): I would lean toward 5 years due to cost, time, burden on
small repositories, especially if the initial audit involves actions by the
repository to bring itself up to standards.
BruceAmbacher >> (All): I like the idea of doing only a partial reaudit with
different aspects checked each time and with an emphasis on any weaknesses
revealed in the initial audit.
BruceAmbacher >> (All): Perhaps a reaudit team could be smaller, possibly only
one person onsite and more reliance on written self assessment by the repository
geared to identified issues/weaknesses/changes in preservation oriented
activities.
JohnGarrett >> (All): Yes, I like idea of any weakness in one audit being an
emphasized area in the recertificiation audit.
RobertDowns >> (All): Perhaps we could consider 5 year recert to look at
potential weaknesses given the potential costs and time commitments for
recertivication.
TerryLongstreth >> (All): If certification involves continuous monitoring of
administrative artifacts, then a time period is irrelevant
Mark Conrad >> (All): Pick one. Put it in. See what kinds of comments we get.
JohnGarrett >> (All): Looking at weaknesses works to fulfill our underlying
reason for doing the audits to ensure that we have competant, trusted
repositories
BruceAmbacher >> (All): Terry, do we want repositories having a sense that ig
brother auditor is always looking over their shoulder? Or can it be viewed as a
resource to be called upon when the repository is facing a new issue?
TerryLongstreth >> (All): That's a decision for the committee; banks seem to get
along with daily reporting
David Giaretta >> (All): I tend to agree with Mark
BruceAmbacher >> (All): Whatever we pick we need to define what the reaudit will
consist of.
David Giaretta >> (All): In terms of surveillance - this is something that goes
through all the audit/certification docs. We need to check what it means in
these terms. I don't think there is a real "big brother" intent
Mark Conrad >> (All): Bruce, Agreed.
TerryLongstreth >> (All): I agree with David on surveillance.
BruceAmbacher >> (All): ok
David Giaretta >> (All): I meant to collect together all the definitions in the
hierarchy of docs so we could get the full picture but I've been tied up with
other work.
David Giaretta >> (All): I hope to get to it this weekend
TerryLongstreth >> (All): something of a tangent, that might intersect this
issue of continuous audit presence, is whether the audited institution can
access an expert for judgements of future actions that might impact audit status
BruceAmbacher >> (All): As a strwaman - "Recertification will occur no more
than five years after the initial audit and certification. It may occur sooner
if the repsoitory or the audit committee believe it is warranted. The reaudit
process will focus on any initial weaknesses and
BruceAmbacher >> (All): a revolving subset of the audit criteria."
David Giaretta >> (All): Terry - not sure where "continuous audit presence"
comes from
TerryLongstreth >> (All): "surveillance"
David Giaretta >> (All): Terry - not sure surveillance means continuous audit
presence
RobertDowns >> (All): Bruce - the strawman looks good.
Mark Conrad >> (All): Bruce, I like it.
TerryLongstreth >> (All): Ok, then I don't know what surveillance means after
all. C A P doesn't mean intrusion, simply availability
David Giaretta >> (All): Bruce - we need to check how consistent this is with
the ISO audit guidelines. However I would prefer not to tie the hands of the
auditors. It may be possible to suggest that the recertification period is
negotiable.
David Giaretta >> (All): Terry - you may be right - I guess I'm just keen that
we use the right definitions otherwise we will get lost. Is C.A.P. used in the
ISO docs?
TerryLongstreth >> (All): Recertification may be driven by TRP events, like
replacing technology
Mark Conrad >> (All): TRP?
David Giaretta >> (All): Terry - what is "TRP"?
TerryLongstreth >> (All): I don't know. I was trying to bridge what I thought
might be a cultural gap between us (on the meaning of surveillance)
JohnGarrett >> (All): For me to trust a repository, I would expect that it would
need to pass a recertification with some specified time period. I don't think I
would be willing to accept that they would be recertified when they felt like
it.
David Giaretta >> (All): I guess I don't like the definition Bruce proposes
because in 5 years a whole heap of things could change. It seems to me that
surveillance and recertification are tied tiogether - although I do need to
check with the ISO docs again
TerryLongstreth >> (All): Sorry, trying to type to fast. TRP- repository being
audited.
Mark Conrad >> (All): I vote that we go with Bruce's strawman and see what
comments we get.
TerryLongstreth >> (All): what David said; recert on a qualifying event
RobertDowns >> (All): I agree that we should go with Bruce's strawman.
David Giaretta >> (All): ...so for example I could imagine that surveillance
might mean a call asking if all the technology and staff have changed. If they
have then a recertification would be in order - even if only to decide whether
to withdraw the certification.
Mark Conrad >> (All): See 7.2.1(c).
BruceAmbacher >> (All): If SurveillanceCAP infers availability we may need a new
section to define what that presence entails, what resources it can bring to
that surveillance, and what "authority" it possess.
TerryLongstreth >> (All): And that's where some kind of continuous audit
presence might be important; the repository should be responsible for notifying
the auditors when a audit impact event happens.
BruceAmbacher >> (All): My strawman allows reaudit sooner if either the
repository or the audit commitee think it is called for.
JohnGarrett >> (All): Again, I'm not as tied in as I used to be, but I think in
the ISO 9000 case, there is nothing really active going on in the surveillance
period. However, if the certifying organization does notice something perhaps
in the news, like a bankruptcy or some major change in the organization, then
according to their contract, the certifying organization can pull the
certification until they are assured that the audited organaizaition could still
pass.
BruceAmbacher >> (All): John, That's the kind of role I see. Perhaps reinforced
by an annual reporting from the repository.
JohnGarrett >> (All): That sounds good to me.
David Giaretta >> (All): Re-reading Bruce's text - it looks OK
TerryLongstreth >> (All): Yes to Bruce, but substitute periodic or continuous
reporting.
JohnGarrett >> (All): If an organization is going to provide expert advice over
time that would either need to be billed separately or if included in the
original audit costs would increase initial costs quite a bit.
TerryLongstreth >> (All): strike my last, substitute "periodic or regular
reporting"
RobertDowns >> (All): Again, we need to ensure that the annual reporting
requirement does not become prohibitively costly or time consuming for small
repositories.
JohnGarrett >> (All): Do we have any view on what would be included in annual
reporting? Would it be detailed or would it just be a statement about major
changes since the audit?
BruceAmbacher >> (All): Perhaps focus the annual report on actions taken to
address weaknesses and/or actions taken that modify the preservation function
directly or indirectly.
David Giaretta >> (All): In terms of costs I guess there is a difference between
the actual audit and any "consultants" which a repository might bring in to help
it come up to scratch. The latter are outside our scope I would think and are
determined by the market.
BruceAmbacher >> (All): Combine John's idea and mine
David Giaretta >> (All): Could one or other of you put text on the WIki page?
David Giaretta >> (All): ...or both
BruceAmbacher >> (All): which wiki page? In which document?
David Giaretta >> (All): http://wiki.digitalrepositoryauditandcertification.org/bin/view/Main/AuditorGuidelinesIssues
JohnGarrett >> (All): Bruce, if you're willing, I'll let you do it. I think your
words are close and it would be better to have a single statement to start from.
David Giaretta >> (All): ...that is the page we are trying to put everything in.
There may be implications for other parts of the whole doc but the rest of the
doc is pretty generic
David Giaretta >> (All): By the way, what about my additions about the "initial
audit committee"?
TerryLongstreth >> (All): They look good to me
Mark Conrad >> (All): Are these the places where it says lead audit committee in
the text?
David Giaretta >> (All): If that's the case then one outstanding issue is
"surveillance" - we should check the inherited definitions and see if we need
something in thos doc or whether we can leave it to the operating procedures
(not standards) of the audit body.
David Giaretta >> (All): Mark - yes
JohnGarrett >> (All): They look good enough for me. I say put it in and see
what comments we get in the review.
David Giaretta >> (All): ... assuming I was consistent
RobertDowns >> (All): There also are references to initial audit committee in
the text
David Giaretta >> (All): Oops - I was afraid that I mixed "lead" and "initial"!!
TerryLongstreth >> (All): In an earlier discussion, there was a distinction. the
Initial committee was responsible for bootstrapping the process
David Giaretta >> (All): Terry - yes - I rolled them together thinking that we
would have to revise this standard at some point and perhaps refine the defition
Mark Conrad >> (All): Section 9.2.3.2 TDR 9.2.3.2 discusses a Stage 2 audit is
a Stage 1 Audit described some place else?
David Giaretta >> (All): ...i.e. revise in 3 or 5 years
BruceAmbacher >> (All): Mark,
David Giaretta >> (All): MArk - yes 9.2.3.1 I think
Mark Conrad >> (All): David, I don't see it.
BruceAmbacher >> (All): Mark, I think the stage 1 audit is the background work
by the repository - self assessment, and the offsite prep work by the audit
team.
RobertDowns >> (All): 9.2.3.1 is not on the web page
David Giaretta >> (All): Mark - looks like Simon omitted it - it's in John's
marke dup doc
David Giaretta >> (All): http://wiki.digitalrepositoryauditandcertification.org/pub/Main/ReqtsForAuditors/AuditorGuidelines-rev2009Sep09w17021InBoxes.doc
Mark Conrad >> (All): Need to look at the copmplete document to see if we are
still missing anything.
David Giaretta >> (All): Yes, I guess Simon omitted very small sections which
did not need any decisions. There are many places where the only change proposed
is to put in the reference to the metrics doc
David Giaretta >> (All): Stage 1 is "The objective of the stage 1 audit is to
provide a focus for planning the stage 2 audit by gaining an understanding of
the TDR in the context of the client organization's TDR policy and objectives,
and, in particular, of the client organization's state of preparedness for the
audit."
David Giaretta >> (All): "The stage 1 audit includes, but should not be
restricted to, the document review. The certification body shall agree with the
client organization when and where the document review is conducted. In every
case, the document review shall be completed prior to the commencement of the
stage 2 audit."
David Giaretta >> (All): "The results of the stage 1 audit shall be documented
in a written report. The certification body shall review the stage 1 audit
report before deciding on proceeding with the stage 2 audit and for selecting
the stage 2 audit team members with the necessary competence."
David Giaretta >> (All): "The certification body shall make the client
organization aware of the further types of information and records that may be
required for detailed examination during the stage 2 audit."
David Giaretta >> (All): Thanks about the whole of that sub-section
David Giaretta >> (All): oopos - "Thats about..."
Mark Conrad >> (All): So in this case the certification body is the audit team?
the initial audit committee? something else?
JohnGarrett >> (All): Yes doing a stage 1 audit (reviewing documents) is a cost
saving measure. You could possibly determine that an organization had no chance
to pass and should do other work before a stage 2 audit. And no travel expenses
would result from a stage 1 audit.
David Giaretta >> (All): Mark - I guess in the startup period the only auditors
will be the "initial audit committee"
David Giaretta >> (All): ...so they would make up those initial audits
themselves
David Giaretta >> (All): .....when we then accredit other auditors then we will
have more options
David Giaretta >> (All): .....and when we have related national certification
bodies then things get very devolved
Mark Conrad >> (All): There are many places in this document where it is not
clear who/what is being referred to. "Client organizations" "certifying body"
etc.
David Giaretta >> (All): John - I guess that's a possibility
RobertDowns >> (All): Perhaps the terms intial audit committee and lead audit
committee should be resolved so that they are consistent.
JohnGarrett >> (All): Yes, I think that at the beginning the initial audit
committee will also make up the lead auditors, but I would hope that would
change to having more lead auditors over time. I think we need to keep the
concepts separate. Hopefully we can get a number of additional lead auditors
before the the first time we need to update the document.
David Giaretta >> (All): Robert - yes - I intended that we use just a single
term "initial audit committee"
Mark Conrad >> (All): Robert, I believe all the terms relating to all actors in
the document should be clearly defined.
David Giaretta >> (All): It may be that because we are looking at extracts from
the doc that things may be unclear.
Mark Conrad >> (All): I am not sure that terms are used consistently throughout
the document.
David Giaretta >> (All): Once we resolve the issues we should put everything
together and check - but we can always go back to John's markup at the moment
to clarify
JohnGarrett >> (All): I thought most of the terms were clear if you looked at
the whole document.
David Giaretta >> (All): John - yes I hope so
David Giaretta >> (All): Mark - there may be two roles but initially I intended
there be just one body
JohnGarrett >> (All): The certifying bodies are the organizations doing the
auditing and granting certifications. They themselves are possibly certified as
acceptable auditing organizations by the initial audit committee.
JohnGarrett >> (All): Client organizations are the hopefully TDRs that contract
with the certifying organizations to be audited.
BruceAmbacher >> (All): Can we address this by including clauses that will focus
on launching the audit function and indicate they will be inoperable once the
process is launched and will be deleted in the first revision?
David Giaretta >> (All): John - perhaps it should be "possibly accredited as
acceptable auditing organizations by the initial audit committee. "
Mark Conrad >> (All): I believe it would be helpful if we defined terms in
section three and used those terms consistently throughout the document.
JohnGarrett >> (All): Agreed
RobertDowns >> (All): I also agree
David Giaretta >> (All): Mark - yes
JohnGarrett >> (All): I think we need to look back and see which terms are
already defined in the inherited documents.
David Giaretta >> (All): Bruce - yes - we can think of some wording or a
footnote or something
David Giaretta >> (All): Mark - we should try to use the inherited definitions -
I put my new "initial audit committee" definition on the Wiki page - we can add
that the the full doc when we put it all together
BruceAmbacher >> (All): Here is my draft: "Recertification will occur no more
than five years after the initial audit and certification. It may occur sooner
if the repository or the audit committee believes it is warranted. The
recertification process will focus on any initial weaknesses and a revolving
subset of the audit criteria."“In the interim between audits the repository will
be responsible for submitting an annual report that focuses on any significant
changes in the repository’s procedures, staff, and/or actions taken that affect
the repository’s mission to preserve information.”
David Giaretta >> (All): Looks good
RobertDowns >> (All): Looks good to me, too.
Mark Conrad >> (All): and a revolving subset of the OTHER audit criteria?
BruceAmbacher >> (All): Mark, good addition.
David Giaretta >> (All): Bruce - will you put that on the Issues page ?
BruceAmbacher >> (All): I suggest locating this at a new 9.2.3.3.4. The
recertification Process
BruceAmbacher >> (All): I will try to put it on the issues page.
David Giaretta >> (All): How about ACTIONS: (1) all to check definition of
surveillance is the ISO docs (2) all to check the wiki page on issues (3) all to
add things to the draft on
http://wiki.digitalrepositoryauditandcertification.org/bin/view/Main/DraftPlanForOrganisation
and (4) Bruce to add text on recertification to issues page
JohnGarrett >> (All): Bruce, I like it.
David Giaretta >> (All): Any other actions?
BruceAmbacher >> (All): Time to sign off?
Mark Conrad >> (All): David, Are you sure that is the right URL?
David Giaretta >> (All): which one?
David Giaretta >> (All): Draft plan for organisation is http://wiki.digitalrepositoryauditandcertification.org/bin/view/Main/DraftPlanForOrganisation
David Giaretta >> (All): Issues page is http://wiki.digitalrepositoryauditandcertification.org/bin/view/Main/AuditorGuidelinesIssues
David Giaretta >> (All): John's marked up doc is http://wiki.digitalrepositoryauditandcertification.org/pub/Main/ReqtsForAuditors/AuditorGuidelines-rev2009Sep09w17021InBoxes.doc
David Giaretta >> (All): ...I think
Mark Conrad >> (All): So which one are we supposed to posting what to?
BruceAmbacher >> (All): I will post the strawman to the issues page
Mark Conrad >> (All): 1) URL?
Mark Conrad >> (All): 2) URL?
Mark Conrad >> (All): 3) URL?
David Giaretta >> (All): Issues on the issues page and ideas on how to set up
the organisation in practice on the plan for organisation page
Mark Conrad >> (All): Issues is http://wiki.digitalrepositoryauditandcertification.org/bin/view/Main/AuditorGuidelinesIssues?
David Giaretta >> (All): Yes
David Giaretta >> (All): (1) refers to JOhn's doc or the other PDF's you have
containing the "parent" docs
David Giaretta >> (All): (2) and (4) refer to the issues page
David Giaretta >> (All): (3) refers to the "plan for organisation" page
Mark Conrad >> (All): Where should we post anything we have for 1)?
David Giaretta >> (All): Good question - we can add it to the "issues" page I
guess under "general points and issues to check"
Mark Conrad >> (All): Ok.
David Giaretta >> (All): ... or just email any thoughts to the list
TerryLongstreth >> (All): I vote for email
David Giaretta >> (All): ........if that's easier
JohnGarrett >> (All): OK. I'll catch you all next week
BruceAmbacher >> (All): I am signing off now
Mark Conrad >> (All): We are going to have parts of this scattered all over the
place.
David Giaretta >> (All): I may be in a meeting in the hague next week
David Giaretta >> (All): I think everything about the draft standard is on the
"issues" page. Ideas about how to set the thing up are on the "plan for
organisation" page.
TerryLongstreth >> (All): For the rest of us; same time and place next week?
Mark Conrad >> (All): See you then.
RobertDowns >> (All): Bye
David Giaretta >> (All): Once we agree on the "issues" we merge that into the
Word doc and remove Johns text boxes at the very end
David Giaretta >> (All): Bye all
--
SimonLambert - 16 Nov 2009