Commitment Analysis: Modernizing Records Management

The following was written by Anne Weismann of Citizens for Responsibility and Ethics in Washington and Amy Bennett of OpenTheGovernment.org

The Administration's latest National Action Plan carries forward its commitment from the first Plan to improve the state of records management across the federal government.  At its core, the new Plan has two goals: (1) improving the management of email, and (2) making it easier for the public to find records.  However laudable these goals, the new commitment offers little promise of reaching them, as it requires agencies to take only small steps, and critically leaves too many things to agency discretion.

In the interest of improving records management, the commitment requires the National Archives and Records Administration (NARA) to continue to work with agencies to implement the Records Management Directive (a policy generally welcomed, although it sets deadlines for agencies to comply that are too far in the future).  The commitment also requires NARA to "work with federal agencies to implement new guidance that addresses the automated electronic management of email records."

The "new guidance" the commitment references is NARA's Capstone approach — a simplified process that allows agencies to designate certain email accounts as permanent records by job position or role.  Prior to Capstone, many agencies kept all email for a relatively short period of time.  Upon a determination that a specific email was a federal record that needed to be preserved, employees were directed to print and file the email for preservation.  Unfortunately, more often than not the printed copy did not find its way into a federal record keeping system.  As a result, as NARA found, many agencies were at high risk for losing or destroying records that should have been preserved.  Capstone eliminates this risk, because it requires agencies to save as permanent records all email from high-level officials and decision-makers.

According to NARA, agencies can meet the Records Management Directive requirement to manage their emails electronically by 2016 by adopting the Capstone approach. The Directive, however, is not proscriptive, and leaves agencies free to use other approaches to reach this bar, and to choose the software or systems they wish to use.  Given this broad latitude, agencies are unlikely to meet the 2016 deadline without interim deadlines established by NARA, and public access to information concerning the agencies’ choices.  These components, however, are missing from the latest Plan.

The second part of the commitment requires NARA to "collaborate with industry to establish voluntary data and metadata standards."  Data and metadata standards will make it easier for the public to search publicly-available records, and find related information.  Missing from the commitment, however, is any express commitment for NARA to be transparent about this collaboration, and any requirement that NARA seek public input.  Further, creating standards will not make a difference unless agencies adopt and consistently use them.  

The records management commitment is an important step forward, but lacks clearly imposed deadlines and greater public access to steps agencies are taking to comply.  These are important components that will help ensure the commitment’s success and make it easier for the public to find government records.

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