Archives seeks e-records feedback

Federal Register notice

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As was expected, the National Archives and Records Administration this week asked for public comment on proposed changes to how electronic records are managed, scheduled and preserved.

In an Oct. 10 Federal Register notice, NARA asked agencies and the public to comment on a petition that was filed last year by the nonprofit Public Citizen Litigation Group. The notice fulfills a promise NARA made in January to solicit comment on two of the three proposed changes presented in the Public Citizen petition.

The petition requested that NARA amend rules concerning the management, scheduling and preservation of text documents created in electronic form, including the provisions of General Records Schedule 20 concerning word processing and e-mail.

Specifically, one proposal under consideration concerns the requirement that record-keeping systems need to preserve the content, structure and context of a record. The other proposal requested that NARA mandate early appraisal of text documents and mandate that agencies incorporate disposition instructions in the design of new electronic information systems.

GRS 20, which contains key rules on electronic records, does not require that those records be kept in electronic form. Instead, it permits agencies to print copies of electronic records and delete the electronic originals.

Public Citizen has steadfastly opposed GRS 20, arguing that printing electronic records does not preserve some key electronic elements, such as descriptive information, annotations and hyperlinks.

A U.S. district court sided with Public Citizen in 1997, but an appeals court overturned that ruling in 1999. The Supreme Court declined to take up the matter. However, the 1999 ruling handed Public Citizen a partial victory by requiring that when printing copies of electronic records, agencies must preserve all of their elements—the content, structure and context.

In its advance notice of proposed rulemaking, NARA said it would accept comments until Jan. 8 and would use the feedback to decide whether any regulatory amendment or other changes are necessary.

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