Electronic Records Management (ERM)
I recently did a webinar with Sue Trombley from Iron Mountain on the impact of the Obama Administration's records management initiative -- not just on the federal government, but on records management in general. The webinar was so much fun; I thought I would follow it up with a short series of questions with Sue. Here's the interview.
JM: One of the themes that we explored on the webinar was the notion that the implications of this directive stretch beyond the federal government. Tell me a little bit about how you see those implications and what the directive tells us about sound records management practice.
ST: I think that the Directive brings to light some of the very basic best practices that we have been espousing for RIM for years. First is the acknowledgment that electronic records are the way we conduct the majority of our business, and as a result, we must have a strategy to enable the people, process, and technology required to manage information in a distributed data environment. Next is the recognition that successful and sustained RIM programs must be led from the highest levels in the organization, hence the Senior Agency Official role that is at the assistant Secretary level. The Directive mentions formal training, certification of Records Officers, and the establishment of an occupation classification for RIM employees – all of which are sound records and information management practices for public and private organizations.
JM: One of the themes at the core of the directive is the necessity for regular and sustaining records management training within an organization. Tell me a little bit about the importance of training and how well organizations have done in providing this training in the past.
ST: Training has been hit or miss – it all depends on the organization’s culture, seriousness of attitude about RIM, and, of course, available resources. I like the use of eLearning courses that can be taken on-line anytime regardless of the physical location of the employee. Employees hear the exact same message and can be tested to determine if they understand the concepts as well as their role and responsibilities. These courses can be supplemented by department-specific training by records officers, or others. I’ve found the “lunch and learn” approach to be very successful. Without proper training and reinforcement, there is no chance that a RIM program can achieve maximum success. It would be great if Records Management can partner with internal Communications or HR departments to ensure on-going communication about the Program through emails, posters, website entries, or special events.
JM: I like your concept of thinking in big buckets rather than micro buckets when it comes to setting up classification and taxonomy schemes. At the core of our conversation was the idea of getting something right and moving on rather than biting off too much and not being able to actually implement. Tell me about your concept of big buckets and how they ultimately play into our ability to use technology to automatically classify records.
ST: Dr. Susan Cisco spearheaded the call for big buckets a couple of years ago. What’s interesting is that in her research, some of the early adopters of big buckets were the Government Accountability Office (GAO) in 2003 and the U.S. Patent Office in 2004. We know from research the fewer series or classes of records with more distinction between them are easier for humans and machines to classify records – whether that is through auto-assisted classification or auto-classification. I like to think of “right-sizing” schedule series to create those greater distinctions while not increasing any element of risk.
JM: The concept of designating a senior agency official or SAO with ultimate responsibility for the creation and enforcement of records management practices and procedures within an agency is a significant new departure. Do you have any insights as to how effective the agencies have been so far in designating these SAOs?
ST: I don’t have much insight at this point. I do know that the SAOs were supposed to be named by 11/15/12. From what we have seen, the list seems to be a combination of C-Level (CIO, CFO), Chiefs of Staff, and records officers.
JM: Do you see “defensible disposition” – getting rid of information that is no longer needed – as a complement to becoming more prudent and strategic with regards to what you actually keep?
ST: Absolutely. If we are managing our records according to a RIM policy – that must include the entire lifecycle of the record from its creation through to its movement to an archive if deemed a permanent record or its destruction if not. When it comes to Discovery, Courts support the destruction of data providing it is 1) not on a legal hold 2) destruction is informed by retention rules in an approved Schedule, and 3) that destruction happens in a systematic and consistent fashion – it cannot be ad hoc. As organizations remove records no longer required for business purposes, they have easier access to active records, reduce their storage costs, and reduce the cost/risk of litigation.
JM: Do you have any thoughts about the formats in which electronic records must be retained? I’m thinking specifically, for example, about PDF/A. Did the directive say anything about specific electronic formats?
ST: The directive does not give any specifics about formats for permanent electronic records. It does say that NARA will provide guidance by 12/31/13 regarding the transfer of records to NARA – including “sustainable formats commonly used to meet agency business needs.” It would seem as though since states and other countries have adopted the PDF/A as the format of choice, that it will factor into NARA’s guidance.
JM: if someone wants to be kept informed about the directive on an ongoing basis, are there particular resources that you recommend?
ST: NARA is a primary source, including their blog, Records Express. Webinars such as the AIIM/Iron Mountain event, Federal News Radio, and records management blogs and listservs are just a few other resource options.
