NARA floats plan for storing records about IT systems

A draft proposal from the National Archives and Records Administration would establish set lengths of time for maintaining records about the development, operation and maintenance of federal information systems throughout the government.

The plan, which is modeled after an information technology records management blueprint used by the state of New York, would replace rules that let agencies determine how long they want to maintain such records as billing information, systems documentation, help-desk files, data dictionaries and source code. It would cover only records common to most federal systems, requiring agencies to account separately for records pertaining to unique, mission-critical systems.

"It's a totally new approach," said Michael Miller, director of Modern Records Programs with NARA and head of the Electronic Records Work Group, which developed the policy. "We're tossing this out to see if it's going to work."

The plan is part of a larger proposal for managing electronic documents that is designed to replace General Records Schedule 20, which provided the rules for maintaining and destroying most computer records. A federal judge ruled last fall that the rule was invalid, in part because it lumped e-mail and word processing documents containing substantive information about agency programs together with files that were unlikely to be needed long term. The government is appealing that ruling.

NARA has circulated the proposal governmentwide and has not released it publicly, but FCW obtained a copy last week.

While most of the debate over the preservation and destruction of computer-related records has centered on documents about policy decisions of interest to journalists, researchers, lawyers and historians, routine systems operating records are unlikely to have much historical value, said Page Putnam Miller, director of the National Coordinating Committee for the Promotion of History. Miller said this part of the plan was significant mainly because it distinguishes these run-of-the-mill reports from more valuable documents.

According to current and former federal IT managers, there is little consistency across the government in how agencies retain files on systems specifications, operations and management.

Under the NARA proposal, agencies would have to start keeping files, depending on their content, for up to three years after the systems, files or procedures to which they pertain are upgraded, replaced or otherwise obsolete.

Some agencies have "a pretty decent records-management program," said Bob Woods, a former federal IT executive who is now with Federal Sources Inc. "But there are some that have been ignoring this area for years, and that's probably more the case than not."

Woods said agencies need some concrete standards for managing their IT records "to ensure the corporate investment is maintained...but you have to have something that guards against the pack rats" who keep records they no longer need or can't find.

Not everyone agrees, however. One civilian federal IT manager, who asked not to be named, said the proposal seemed to be "overkill" because not everything mentioned in the proposal necessarily needed to be maintained.

"This will be like the accounting rules and the computer security rules and some other things...that are all worthwhile to do, but the resources are just not there to do them," said Jim Kerrigan, a former federal IT manager who now runs the market research firm Colmar Corp. "It's not because agencies are antagonistic to it. They have more important things to worry about."

Rich Kellett, director of the General Services Administration Emerging Policies Division, is examining governmentwide electronic recordkeeping issues.

He said the proposal "looks reasonable," but that "it should leave more discretion to agencies" to tailor their plans to their systems. "Things are changing very rapidly," he said. "Some organizations don't even last a year or two."