Interagency panel reviews recordkeeping policy

An interagency committee working on a new policy for preserving federal electronic records plans to suggest ways that agencies can set priorities for cataloging their digital files.

The decision, reached at a meeting of the Electronic Records Work Group last month, is in response to comments from government officials and interest groups about a draft electronic recordkeeping policy the work group developed. With millions of electronic files to manage, agencies said they need to know where to start, while researchers want to ensure that documents of historic importance do not disappear.

Michael Miller, director of modern records programs at the National Archives and Records Administration (NARA) and head of the workgroup, said the panel has not decided exactly what it will recommend. "There were a number of different ideas.... All include the concept of historically valuable [records]," he said. Archivist John Carlin would make the final decision on the advice the group will issue.

The policy is being developed under a court order while the government appeals a ruling that invalidated an earlier policy, General Records Schedule 20, which allowed agencies to delete electronic files after printing paper copies. New rules are due Sept. 30, although Miller said not all the revisions to the draft would be completed by then.

Revisions also are likely to other sections of the proposal, including one provision concerning how long agencies will have to develop their plans. Miller said the "predominant criticism'' of the proposal was that it did not give agencies enough time to craft their plans.

A summary of the meeting issued by NARA said "there was a strong sense'' among some committee members that "established time frames should remain'' but that agencies might be allowed to ask for extensions.

"We didn't conclude on this,'' said Richard Barry, an independent consultant who is a member of the panel.

Electronic Source Records

Meanwhile, NARA plans to revisit one issue at the heart of the proposal: what agencies should do with what are called electronic source records, or the digital files from which agencies create their official copies. The draft says agencies can destroy these files once they make official "recordkeeping'' copies.

Barry said, however, that the proposed provision "would create an enormous amount of confusion'' because agencies might end up having to maintain these records separately from those in their official files. The problem, he said, is that if the official record is a paper one, which would be allowed under some circumstances, that may not meet the court's scrutiny.

What is meant by electronic source record, a term created by the workgroup, is widely debated. Agency records managers and information technology officials alike consider the term confusing.

Christopher Olsen, a workgroup member who is chief of records and classification management with the CIA, wrote in his official comments on the proposal that if this "electronic source document'' is not the "recordkeeping copy'' maintained by the agency, then it does not need to be accounted for at all. "Then it is a convenience copy,'' Olsen wrote, "and can be destroyed when it is no longer needed for reference.'' Olsen rejected the entire framework of the proposed policy, which would give agencies three options for maintaining their files, depending in part on their capacity to keep their official records in digital form.

The proposed record scheduling models "will do little, if anything, to stimulate the evolution of federal agencies to electronic recordkeeping,'' he wrote. Instead, he said the workgroup should recommend one simple model that covers all agency records regardless of their format. He said NARA "should remind each agency head...that the agency should determine retention of the copy in the format that best meets its business needs, legal requirements and ability to serve the public.''

Miller said the panel will "do a major revision'' of a section of the proposal that sets timetables for disposing of IT records such as help-desk files that have no long-term value. Criticisms of this section included complaints of too many retention categories, thereby making the records hard to manage.


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