Critics fault AIIM guidelines

Some open-government advocates are questioning why recent recommendations for electronic document management systems make no specific mention of compliance with the Freedom of Information Act or support for public access to government information.

The guidance document, “Recommended Practice, Analysis, Selection, and Implementation Guidelines Associated with Electronic Document Management Systems,” was issued by the Association for Information and Image Management (AIIM), an international authority on enterprise content management.

The new guidelines apply to all systems government agencies and businesses use.

Terry Francke, general counsel for the nonprofit group Californians Aware, said that until procurement recommendations such as the AIIM document explicitly discuss FOIA and public access to information, it will remain difficult to pry information out of government organizations.

“Security is overtly and understandably mentioned,” he said. “But it seems to me that unless the bias for disclosure that is expressed in FOIA and its state law equivalents is somehow engineered into these systems, access will, de facto, be a neglected and therefore needlessly and persistently burdened right.”

When the government buys electronic records systems, it should require that those systems facilitate public access to information, Francke said.

The government should require software vendors to propose systems that segregate legally confidential information from public records and then make the latter easily searchable by the public, he said.

“It’s an issue that might have been addressed had records been electronic at the time that FOIA was first passed [in 1966] but somehow has been bypassed by the evolution of the technology,” Francke said.

An AIIM committee composed of representatives from federal, state and local government agencies, and industry drafted the recommendations.

Robert Blatt, chairman of the AIIM committee and president of Electronic Image Designers, a document-management consulting firm, said the document does not attempt to instruct organizations on managing their internal records, permissions or archives. Rather, it provides guidance on the technologies so records managers can make access decisions.

Blatt said organizations can easily comply with FOIA requests if the system is properly configured and implemented.

The document references FOIA indirectly in a section that advises agencies and institutions to determine whether vendors under consideration meet the organization’s legality standards, he noted.

“Legality issues that should be considered by legal advisers include information expungement, legal acceptance of records, retention requirements and information redaction. Each of these issues are organization-dependent and should be considered by legal advisers,” the AIIM guidelines state.

Blatt said software vendors have already made it easy to separate legally confidential information from public information via standard administrative controls.

“The issue isn’t with the [enterprise content management] software, but rather the configuration controls selected and implemented by the organization,” he said. “It’s not the technology; it’s the implementation.”

California’s chief information officer, Clark Kelso, said the state is beginning to deal with the issue of Web site accessibility. A policy-making committee that oversees California’s Web presence has made accessibility one of its priorities, he said.