Record Keeping Memo

Today, the President issued a memorandum to heads of Executive Departments and Agencies on Managing Government Records.  This marks the start of an executive branch-wide effort to reform records management policies and practices.

I strongly support this Presidential initiative, which sends a very clear message to Federal agencies about the importance of managing electronic records.  Records management must keep up with the technologies used to create records in the Federal government, and the President’s Memorandum underlines the critical nature of this responsibility.

Each agency will be required to report to the Archivist the name of a senior agency official who will supervise an agency-wide evaluation of its records management programs. These evaluations, which are to be completed in 120 days, are to focus on electronic records, including email and social media, as well as those programs that may be deploying or developing cloud-based services.

The President’s memorandum also asks that the National Archives identify opportunities for reforms that would facilitate improved government-wide records management practices.  We will begin immediately to coordinate discussions with Federal agencies, interagency groups, and external stakeholders.

My staff and I look forward to working with OMB, the Associate Attorney General, and all agencies to ensure that they comply with the new Memorandum and that we continue a government-wide effort to preserve permanent electronic records that eventually become part of the holdings of the National Archives.

I am delighted that this is a priority of this Administration, and appreciate that the President reiterated NARA’s philosophy that good records management is the backbone of open government.  This memorandum will ensure that history in the making will be preserved and that citizens will be able to make independent judgments about the actions of the federal government based on the records themselves.

Read the President’s Memorandum at The National Archives National Records Management Program Blog, Records Express, will post more information on the requirements laid out in the President’s Memorandum later in the week.


6 thoughts on “Record Keeping Memo

  1. Past self-assessments by Agencies have resulted in a wide range of responses, many of which were far below stellar; some of which were in an acceptable range, but were questionable in their validity. In cases where the IG was enlisted to review and validate the findings, there were great discrepancies.

    Many/most Agencies have named Records Management Officers, in most cases aligned within the CIOs organizational structure but some of these individuals have little, if any, practical RM knowledge and few have a clear understanding of the requirements to perform a Functional Requirements Assessment when it comes to electronic records. Even fewer comprehend the difficulty to ensure persistent access to electronic information assets for their required retention periods.

    The concept of asking for this “to be completed in 120 days” is arbitrary and makes no sense at all- the quality of the data that will be gathered will have little to no value. Having worked directly with Federal Agencies over a decade now, the time frame between Thanksgiving and President’s Day is routinely when many tenured Federal employees take vacation and therefore, staff is thin and those necessary to provide answers to critical questions will likely NOT be available.

    In addition, what will Agencies be provided to use as a “checklist” to ensure the data gathered will compare similar components, content, volume, systems, structures, workflow, access and privacy requirements, classification levels, roles and reporting structures, staffing and budget? If it’s the same as used previously, the results will NOT answer the new questions/requirements.

    There is another huge disconnect- how Agencies will interact with NARA once this data is gathered. The checklist used has to include data regarding volumes of data to ultimately be transferred to NARA’s ERA, including: volume of structured and unstructured content, forms and formats the data exists in, systems being used to manage the data, estimated dates of turnover (full or pre-accessioning), access or use needs for pre-accessioned content, volume of data requiring privacy controls based on content (PII, PHI, PFI), and volume of data requiring security protection (NSI, TS, RD).

    Few of these issues have been taken into account in past reviews, and many of these must be considered when it comes to electronic information assets to accurately determine the effort required to gain proper control of the growing volume of content.

    Estimates/projections of ongoing growth also needs to be considered. In part, this will assist in budgeting the effort required to periodically convert and migrate the content to avoid format, application and media obsolescence over its mandated retention period.

    120 days for ALL Federal Agencies? I don’t think so… The Federal Government has been waffling for 3 years now on “cloud storage”, has yet to develop a solid policy on “social media”, and should we even mention email? 36CFR, Part 1236 clearly defines email as a record when the content meets the definition and there is no plan in place for handling that 600 pound gorilla in the room.

  2. I too applaud the President’s memo. It is long overdue and an ambitious proposal to improve records management in the Federal sector. In fact I like it much better than the Archivist’s blog post, which I see as rooted in NARA’s traditional approach to records management which is primarily a message of responsibility and archival records. I don’t remember seeing one word in there about the benefits to Federal agencies in improving records management – something I do see in the President’s memo. Compliance is big in the records management community right now, but rethinking records management takes more than compliant agencies. It takes the best minds in and out of the Federal government thinking creatively about solutions that provide real benefits – and thereby incentives – for agencies.

    If this is to be effective agencies must embrace records management not comply with it and that means they recognize that records management will assist them in completing their mission not just complying with regulations. To do this NARA will have to take seriously the call to “reform records management and practices” by starting at home and examining how traditional Federal records management policies and practices – including the current interpretation of the definition of a Federal record – are barriers to effective agency records management. I with you all well in this endeavor.

    Mike Miller

  3. Sir-
    Like you, I am VERY happy to see the President taking an active role in Federal record keeping. My goal is to make the Department of the Navy a role model and best practice for other executive agencies. We look forward to responding to this memo and showing the strong commitment that the Navy and Marine Corps have towards our records program!

  4. @Mike Miller – interesting, thoughtful comment. As a federal historian, I remember coming to NARA and hearing your good analysis of record keeping changes at the Cold War International History Conference at Archives 2 in 1998. You’ll be pleased to hear that your paper has long been available on the NARA website.
    Unlike you, I don’t read David’s blog post as rooted in NARA’s traditional view of records management as a compliance matter. Rather, I relate it to what I know to be his strong interest in and commitment to civic literacy, which he touches on in his concluding sentence. His commitment to open government certainly is genuine. I’m particularly encouraged by his reference to reforms, which suggests a pretty comprehensive look at all the moving parts, not just the role of Records Managers.
    However, you point about incentives interests me, as an internal end user of records within a federal agency. I would add to your point that NARA also needs to look at the disincentives, some of which it can affect and some of which are beyond its control. The late Eduard Mark, Air Force historian, touched on some in his writing as have some other federal historians (John Earl Haynes). Some of these disincentives are difficult to acknowledge publicly but must be addressed candidly inside NARA.
    Agencies and departments face, assess and act to mitigate risk in different ways. Risk in retention or non-retention of corporate memory isn’t going to be assessed the same way in every agency. For some the imperative not to create some types of records in the first place is going to be greater than for others. Often there simply are competing dynamics in organizations, as a business professor once noted when he said “lawyers are the enemies of history.”
    The question of agency hold times is particularly tricky and requires exquisite situational awareness and contextual sophistication which under previous administrations wasn’t always there. While I am only guardedly optimistic about some aspects of this initiative, I do think David Ferriero’s NARA has a decent chance of widening the scope of review so as to recommend far reaching reforms. From my observation, David has great capacity and judgment as well as the extra advantage of having worked as a psychiatric technician as a Navy hospital corpsman in Vietnam. That he is so interested in and understands people issues so well suggests to me that NARA will not take a eyes lowered, head down, limited, technocratic approach to these important matters.

  5. Every long journey begins with a first step, and I am very pleased to see the President’s support reflected by the memorandum.
    Over the years, I have managed records work at dozens of Federal agencies. Many agencies, like our private sector clients, struggle with the definition of what is a record. As a society on the whole, we are having trouble moving from the concepts of records being paper and wet ink signatures and being associated with lawsuits and audits. Addressing the negative stigma of the term “record” will be fundamental to the long term objectives of the memorandum.
    A good example of this negative stigma is illustrated by an inventory that we performed at one of the National Laboratories. Although the objective of the inventory was to map the knowledge assets of the laboratory, the project was initially called a “records inventory”. The project had great difficulty getting started as we faced a plethora of excuses from the scientists ranging from “I don’t have time” to “I don’t have any records.” When we changed the contact message to “stuff” instead of “records”, we could not get to the scientists fast enough for them. They stated they had lots of important “stuff” representing their life’s research and they were extremely concerned about its preservation.
    Here’s to hoping the memorandum can provide the foundation to the Federal government to effectively manage its “stuff” and protect the rights and interests of our citizens.

  6. I suggest that Mr. Morris’ post indicates an ongoing problem: the distinction between “records” and “information” that we have been saddled with since the Federal Records Act of 1950. Even for basic management of never-to-be- scheduled “stuff” (see above), it is necessary, first, to state that it is not a record, and then still make a decision about how long to keep it. You have already made the two most basic record keeping decisions even if the item will require no more managment than tossing it out around the time policy says you can. Here is one of the “obstacles” the memo asks to be identified. Surely, all the information assets of an organization should (and given their volume really need to)benefit from appropriate good managment practices now applying to records.

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