NARA issues electronic records guidelines

The National Archives and Records Administration last week issued instructions to agencies for cataloging their e-mail and word processing files.

The guidelines, outlined in NARA Bulletin 99-04, cover copies of program-related records that remain on agencies' "live" e-mail systems, file servers and hard drives after official copies of those records are filed.

Although the bulletin does not prescribe any format in which official records should be maintained, it will force agencies to decide whether electronic versions have lasting value. Agencies now have until Feb. 1, 2000, to revise their records schedules to include their electronic files or to describe how they plan to accomplish this task within two years.

"They're records, [and] we know they're records," said Michael Miller, director of modern records programs with NARA. "We tell agencies that they have to take a look at how they want to keep these records, and they have to look at it in terms of their business needs." For example, the bulletin tells agencies that they should determine whether employees will need to refer to the electronic versions for any reason.

Some agencies may decide that the electronic versions of their records should become the official copies, he said. Meanwhile, because their plans must undergo public comment and be approved by NARA, agencies ultimately may be required to preserve records electronically that they would rather continue to maintain on paper. If the electronic versions are well-organized and secure, "we would say, 'Are these of such research interest that it would make sense to take them electronically?' " Miller said.

Bette Behal, the records officer with the Agriculture Department, said "the guidance is our starting point" for cataloging electronic files, a process that records managers call "scheduling."

"What is important is designating which format is going to be your official recordkeeping copy," she said. "Working copies of records need to be dealt with because they take up space on systems, and they take up file space in drawers."

To make these decisions, Behal said, agency program managers, information technology managers and records officers will have to assess not only what electronic records they have but also what systems are needed to track and store them. Agencies likely will need to revamp their business processes and acquire new software. "This is the type of thing you have to build into [long-term] planning and budgeting," she said.

The new instructions were prompted by a federal court decision in the case Public Citizen v. Carlin, which in 1997 invalidated a government policy that allowed agencies simply to delete all of their electronic files if they kept paper copies. The case is under appeal, with a decision expected soon.

Michael Tankersley, senior staff attorney with Public Citizen, a consumer advocacy group, said the bulletin addresses the heart of his case - that agencies should not treat all electronic records alike. But he thinks the guidelines should go further by pointing out which categories of electronic records are most valuable and should be scheduled first.

"They ought to be able to say, 'Here are our guidelines for what qualifies as permanent,' " he said. "In the interim period, it doesn't say what agencies are supposed to be doing, but everyone knows that what they're doing is destroying the electronic versions of those records."

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