Presidential Records Management Directive: It Takes A Village - InformationWeek
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Sue Trombley
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Presidential Records Management Directive: It Takes A Village

Agencies will need to draw from varied resources to meet the deadline for digitally archiving federal government records by 2019.

Since the establishment of our federal government, records have been instrumental in preserving the evidence of communications, agreements, laws, and transactions. But today, an explosion of information growth has combined with decreasing budgets and real estate to make caring for these records a more daunting task than ever before. As a result, President Obama stepped in and addressed federal records management modernization.

The Presidential Records Management Directive, enacted in 2012, calls for all permanent electronic records to be managed in electronic format by 2019 (that is, if they originated as electronic records, they have to be managed that way). Although this deadline is still five years away, agencies need to begin to focus on the benefits of digital migration before the Directive requires them to do so. By digging in now, agencies also will be better positioned to meet other critical mandates currently underway such as the Open Data Policy and Freeze the Footprint. According to The National Archives and Records Administration (NARA), agencies that digitize their records will better:

  • Share and track records effectively;
  • prepare for disasters;
  • respond to audits and Freedom of Information (FOIA) requests from citizens;
  • salvage damaged records and protect older media;
  • make paper originals more readily available;
  • save money through freed-up office space;
  • create openness and transparency; and
  • increase their search and e-discovery capabilities significantly.

With these benefits alone, agencies that begin the work to modernize their information programs now will not only improve compliance and minimize maintenance costs, they also will promote a greater sense of openness among agencies and citizens. Furthermore, they'll be able to capture and use relevant metadata to improve workflows.

[Is hybrid worth it? Read Hybrid Cloud Security: New Tactics Required.]

With agency budgets dwindling, information expanding, some NARA facilities closing, and several Directive deadlines to be met in the next five years, agencies are at a true tipping point in records and information management. There is a critical need to modernize -- and looming deadlines increasing the urgency to do so effectively. But Federal agencies won't be alone; they can tap into a community of industry partners to drive their information modernization efforts. Simply put, it will take a village to modernize federal information programs.

Federal agencies will need to tackle the unification and digitization of records in incremental, strategic steps. To do this on time and on budget, it will take people in both government and industry who are planners, managers, and technology experts. A smooth transition won't happen on its own. Here's a look at the roles agencies will need to enlist:

The inventory specialist. As a first step, the agency will need to have an inventory specialist who should conduct a baseline records program assessment and inventory to identify, categorize, and locate all information assets, regardless of format. In order to help the agency develop appropriate information policies for the future, the inventory specialist will help it navigate every component of the information inventory. After everything has been inventoried, retention policies will need to be applied to manage the vast number of temporary records versus permanent ones -- which make up approximately 97% to 99% of all federal records.

The planner. Based on the baseline assessment and inventory results, the planner creates the strategy and action plan for the agency to achieve Directive milestones and makes sure the agency keeps to it. The planner can be the agency's industry partner who creates a tailored plan, based on situational factors and agency dynamics, to meet deadlines while supporting agency missions. To ensure the pace for modernization is on track, target milestones and metrics will be built into the plan.

The digitizer. Digitization of the agency's records is a critical step in transitioning to a more modernized, electronic records system by 2019, but this can be done earlier than the 2019 deadline to make sure all information assets can be managed effectively. Outside specialists that digitize agency records could be responsible for developing a strong program that is able to gain control of all electronic records, currently and in the future, including those "born" in digital formats.

The enterprise content manager. After records are digitized, the metadata for all information assets -- whether digital or paper -- will need to be centralized into a single system that serves as a secure, accessible repository for managing their lifecycle. An enterprise content management platform can be used to deliver powerful, efficient search capabilities that improve e-discovery and FOIA processes, better inform end users, consistently apply records policies, and allow for the proper disposition of both permanent and temporary records.

The cloud expert. Although the Directive does not require agencies to move records into the cloud, the White House's Cloud First Policy does mandate that agencies adopt cloud usage in some way, so it's a good idea for them to start looking at options, especially in storage. Cloud service experts can help agencies gain a better understanding of the benefits of using the cloud to store and manage agency records.

In the next five years, agencies will face a number of hurdles. With an entire village of experts working together, the federal industry can help provide agencies with the assistance they need to implement a well-designed, unified methodology to modernize their information programs. Ultimately, agencies will be empowered to manage and digitize their paper records, as appropriate, to achieve savings, streamline their current records information management systems, and meet the deadlines of the Presidential Records Management Directive.

Even space explorers must follow the rules. Read the InformationWeek Tech Digest, NASA Mission: Cloud Compliance (free registration required).

Sue Trombley has more than 25 years of information governance consulting experience. Prior to her current role, she led Iron Mountain's Consulting group responsible for business development, managing a team of subject matter experts and running large engagements. Trombley ... View Full Bio
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User Rank: Apprentice
8/15/2014 | 11:32:20 AM
Takes MUCH MORE than a village
For this effort to succeed, it will take funding and staffing... lots of both.  And given the manner in which funds are allocated to Federal Agencies (and their Contractors, who manage the Lion's Share of Federal records), we've already missed the boat for FY 2015.  The budgeting process for FY15 failed to include ANY estimates of cost/effort for this work, because few Agencies have even scoped it yet.

The other key component missing is written guidance from NARA providing specifications, processes and practices needed for proper capture and conversion of these records into digital formats.  Many "Permanent" records are still in regular active use by Agencies and Contractors, so when this effort takes place, "reference copies" will need to be retained locally to support ongoing work, in some cases for DECADES into the future. 

Guidance regarding preparation, sampling procedures, QC for scanners, selection of proper equipment, minimum required metadata elements, common file naming conventions, and capture in a quality for legal acceptance should ALL be produced by NARA in a "manual".  This guidance should CLEARLY DETAIL the requirements to allow Agencies, Contractors and others (if the work is vended to a third party) to perform the work properly.  36CFR lists Standards for micrographic work, but fails to give guidance for conversion of paper source materials to digital images. As a final step, captured images and metadata applied need to be QC checked to ensure there are no skewed images, dyslexic entries, or glaring errors.  Where this becomes even more critical is images will be transferred to NARA from many different Agencies and then managed in a single repository. The potential for commingling of content and items with identical identifiers overwriting each other is HUGE.

Standards for consideration should include:

ANSI/AIIM TR31, TR34, MS 44, MS52, MS54 and ISO TR 15801 and 19005-1 AT MINIMUM.

But rather than simply citing the specs, NARA should dig out the SPECIFIC necessary requirements and put them into language and methods for Agencies to follow in a "cookbook fashion".  The reason this is CRITICAL, is if a wide range of Agencies are left on their own to determine how to go about doing this, then the original source materials are destroyed. Once the resultant images are captured, if insufficient, the source information WILL BE GONE.  Key to consider is there is a REASON these records have a Permanent retention.  If the information included in them is no longer accessible, then all is lost. 

The long accepted estimate of the volume of Federal records that reach the level of Permanent is anywhere between 3-5%, however, with some Agencies the number is substantially higher.  And some of those records are critical to Agency process and practices.  Among the more obvious examples are records from DOE, DOD, DOJ, HHS, and DHS.


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