Where does the recordkeeping buck stop?

Electronic Records Policy Working Group's draft report: Barriers to the Effective Management of Government Information on the Internet and Other Electronic Records

The nagging question of who should be responsible for determining whether an electronic document must be maintained as a federal record is at the heart of a new report issued this month.

According to the report from the Electronic Records Policy Working Group, most experts already acknowledge that electronic records are poorly managed. To fix that, the report recommends user-training programs as a way of encouraging better records practices. Some electronic-records experts, however, have criticized the findings.

"Records managers need to work with [information technology] managers to figure out how to get electronic records management transparent in the background," said J. Timothy Sprehe, president of Sprehe Information Management Associates Inc. "User training won't work unless agencies are willing to make [technology] investments."

The draft report describes barriers to effective records management and possible solutions. Although the report calls attention to a long-neglected problem, some records analysts say it fails to take into account agency culture and best practices.

On the one hand, the report gives high-level visibility to the problem, said Charles Dollar, a records management consultant at Cohasset Associates Inc. "It seems to be addressing the underlying problem, which is that there is not a recordkeeping culture," he said. "Records are either a burden or something you do and forget about."

On the other hand, the report recommends training, which is not universally effective in changing organizational culture, Dollar said. "Training is a long-term enterprise," he said, adding that the missing ingredient may be incentives for people to change their behavior.

Sprehe added that the report misses the mark entirely and that its approach and language are muddled.

"It's confused and confusing," he said. "I'd say they tried and failed. They need to reconceptualize the whole problem."

Sprehe faulted the report for suggesting that electronic-records management should be handled with desktop training directed at end users. Instead, records management, similar to security, should be managed at a system level and should be invisible to users, he said.

The report identifies four barriers to effective records management. It recommends new training programs to teach employees about the benefits of records management.

"We are trying to provide tools for agencies to build records management as painlessly and as early [in] the process as possible," said Nancy Allard, a senior member of the policy group and co-manager of the e-records management initiative for the National Archives and Records Administration.

Allard said the report, which is open for public comment until Aug. 1, gathers previously identified issues into a single reference and offers a glimpse of future directions.

Based on comments about the report, the working group's members will develop final recommendations and a framework to submit to the Interagency Committee on Government Information (ICGI). Officials from ICGI, created under the E-Government Act of 2002, will then send the final report to the Office of Management and Budget and NARA.

To promote managing records as business assets, members of the working group suggest training and advocacy that promote records management. In addition, they propose developing a toolkit to help agencies manage large volumes of records.

The group is also considering recommendations in line with a NARA advocacy program designed to demonstrate to senior agency officials why it is critical that agencies manage electronic records as assets.

The report identifies training as a means of integrating records management into routine business procedures. But it also suggests including records management as a crosscutting layer in the federal enterprise architecture rather than as a subcategory under one of the lines of business.

The policy group proposed developing templates for enterprise architecture information associated with records


Training also surfaced as a solution for two other barriers the group identified. One of those barriers is the marginal support for records management that has led to a lack of tools and guidance. According to the report, although promoting support for the discipline can be difficult given an agency's culture, training initiatives can ease that problem.

The report also states that records management and IT are poorly integrated.

Records management initiatives "should address some of the awareness problems presented in this barrier by developing specific training modules for IT staff on [records management] issues," the report states. "Likewise, training

will be encouraged for [records management] staff to promote a better understanding of IT terminology and technical concepts."

Some analysts said the report fails to include examples of agencies that have effective records management programs. In addition, records management consultant Rick Barry said the report is lacking in criticism of records managers and senior-level agency managers.

"I find no fault with anything said in the report


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