Mandatory e-records management arrives

The National Archives and Records Administration has been circulating a draft bulletin on the scheduling of electronic records. The draft could benefit from many improvements.

NARA's chatty document is intended to instruct federal agencies on what to do with their electronic records in the wake of U.S. District Court Judge Paul Friedman's 1997 decision declaring null and void General Records Schedule 20. GRS 20 governed electronic records scheduling until the court tossed it out. The government appealed Friedman's decision, and oral arguments occurred last month.

One of the bulletin's striking elements is that it instructs agencies to submit revised schedules for their electronic records, or a plan for revising the schedules, within six months of the bulletin's issuance.

For many agencies, this deadline presents a tight timetable. What happens if agencies don't meet NARA's deadlines? They lose their records disposition authorities, which are the Archives' permission to dispose of the records. If agencies were to lose such authorities, presumably they would have to retain everything until they recovered disposition authorities. NARA ought to recall the government's argument in court earlier this year that a requirement to keep everything would paralyze agencies.

What the bulletin does not include is any timetable for NARA itself. How long will it take NARA to review agencies' revised schedules? NARA gives everyone tough deadlines except NARA, and it imposes Draconian penalties for failure to meet the deadlines. Is the rest of the world supposed to shift into crisis mode while NARA conducts business as usual? The proposal hardly seems even-handed.

For another point, I foresee confusion and mischief in the bulletin's definitions. NARA proposes, among others, the terms "electronic copy," "electronic record," "recordkeeping copy" and "information technology record." Now, let's see: All electronic copies are electronic records but not necessarily recordkeeping copies, and information technology records may or may not be electronic records. Is your head spinning yet?

What if someone submits an electronic Freedom of Information Act request for both an electronic copy and the recordkeeping copy of the same record and finds out they are different? Which will be the "real" record in this case?

At the bottom of this are some new realities. Except for the mini-agencies, all federal agencies should be planning for a near-term future when all word processing, spreadsheet and database files that qualify as records will be managed in an IT systems environment. Stop thinking in paper-based recordkeeping systems and start acquiring IT systems that will handle electronically the creation, maintenance and transference of federal records in a manner consistent with records management laws and regulations.

The government may win its legal appeal and get GRS 20 reinstated. But from best practices and good management standpoints, mandatory electronic records management is here, folks. Start dealing with it.

IT managers with prudent foresight already are asking: What products are coming onto the market to accomplish electronic records management? How will these products integrate with the IT systems already installed in my agency? How soon can my agency realistically implement such systems?

A few agencies have garnered some experience on this new frontier. The lessons they have learned strongly suggest that the movement from paper-based to electronic records management systems involves much more than just acquiring new systems. It also demands thorough business process re-

engineering. The advent of virtually mandatory electronic records management means that agencies must think through, all over again, just how to go about managing their information in day-to-day operations. This is not a simple or painless matter. The sooner agencies get started, the better off they will be.

-- Sprehe is president of Sprehe Information Management Associates, Washington, D.C. He can be reached at jtsprehe@jtsprehe.com.