یکپارچه سازی مدیریت سوابق با مدیریت منابع اطلاعاتی در سازمان های دولتی ایالات متحده

This article presents several key issues facing federal agencies with regards to electronic records management practices. The article identifies selected management, technology, implementation, and definitional barriers that agencies encounter when considering how to create and maintain an electronic records management process. A key question for federal agency technology managers is: If an enterprise creates and manages virtually all of its information in an automated information technology systems environment, does it make any sense to manage its records in a manual environment? Based on research conducted by the author, the article reviews various federal agency electronic records management processes and the implications for those practices.

Federal agencies, like other organizations, keep records because they need records to conduct their business (see Figure 2). They keep records because they need to be accountable to themselves and to external entities (e.g., the Congress, other agencies, and the public) for how they have spent public funds in discharging their missions. Businesses must keep records for tax and auditing purposes and for legal reasons. Records are the critical element in the “institutional memory” of any enterprise, its knowledge of how and why things were done in the past, whether the past is last week or last decade. The business imperative to keep records is so strong that it is codified in statute as the Federal Records Act,5 the legal requirements for federal record keeping.Like other enterprises, agencies do not keep records simply because of statutory mandates or because they would be “nice to have” from an historical viewpoint, even though the historical value of records is part of the legal requirement in the Federal Records Act. They keep records because they believe they may need to access the records. The raison d’etre of record keeping is access to the information in records, not simple preservation. If agency officials believe they will not need to access the information as evidence of the agency’s past collective behavior, then the information should not qualify as a record in the first place. Records are valuable because the agency places value on the information contained therein for its relevance to agency mission and program performance; they are not just the detritus of yesterday’s activities. To put the matter another way, when one speaks of agency records, it is assumed that one speaks of information that a responsible agency official has determined is valuable for executing agency programs and hence worth keeping for future access. If records management has been a perennial backroom and backstage activity, that situation began to change radically in the late 1980s. The Iran-Contra scandal in the White House came to light because of the idiosyncrasies of PROFs, the IBM electronic communications system used in the White House, a forerunner to what today is universally called e-mail. Unbeknownst to the PROFS users on the National Security Council, messages intended for deletion were still captured by the computer backup system. After the Tower Commission’s report on the scandal, the White House proposed to destroy the computer backup tapes. Scott Armstrong and the National Security Archives, a nonprofit organization, sued the White House alleging that the tapes were federal records that should not be destroyed. Thus, began a series of federal court cases that has decisively altered the ways in which federal agencies think about records management and treat their records. The White House rationale for destroying the PROFS tapes was that they were not federal records. This contention was based on the existing White House records management policy, namely, that staff were instructed to print out in paper form any information that rose to the level of a record. In Armstrong v. Executive Office of the President, Armstrong and the National Security Archives argued that paper printouts were not adequate substitutes for the electronic versions on the computer tapes. Federal Judge Charles Richey held for the plaintiffs in late 1992, deciding that the paper record was not equivalent to the electronic record. What is generalizable from Judge Richey’s opinion was the finding that the White House “record keeping procedures are arbitrary and capricious because there is no adequate management program or supervision by record keeping personnel of the staff’s determination of record or nonrecord status of computer material.” It was not enough that agency staff were charged with preserving record material appearing on the e-mail system; the agency records officers were not involved in the decision making. What the decision meant for federal agencies was that they must establish a well defined relationship between e-mail and federal records, and must be able to show that agency records officers were supervising how staff decided which e-mail messages were records and which were not. What was true for e-mail records was sure to be true for all other federal records in electronic formats: word processing documents, spreadsheets, and administrative and scientific databases. Richey’s 1992 decision was one of the first in a series of federal court decisions pertaining to the legal status of records “born digital.” It signaled that agencies would have to reevaluate their traditional practice of printing out electronic files and saving the paper versions and be prepared to take their records management in an entirely new direction. An even stronger blow to traditional practice came in October 1997 when Judge Paul Friedman ruled that the National Archives and Records Administration’s (NARA’s) General Records Schedule (GRS) 20, Electronic Records, was arbitrary and capricious in its contents and judged GRS 20 null and void.6 General records schedules cover disposition of records that are common to all agencies (e.g., travel and payroll). NARA issued GRS 20 in response to Judge Richey’s decision concerning the PROFS tapes. In its pertinent part, GRS 20 said that, when agencies have records in electronic form, the records must be transmitted to a NARA-approved record keeping system and that such a system could be paper, microform, or electronic. The paper loophole—the option of printing electronic files to paper—was the target of Friedman’s opinion. The decision held that electronic files have unique characteristics not captured in paper printouts. Those characteristics are the capabilities for electronic records to be manipulated, searched, indexed, and transmitted via telecommunications in ways that are not mirrored in the paper world. Paper copies, in the court’s view, simply do not capture the full legal, administrative, research, and historical value of the electronic record. Friedman also held that, in issuing GRS 20, NARA had exceeded its authority by improperly lumping together in a general records schedule administrative and program records. He declared GRS 20 null and void. The Friedman decision was a major shock to the federal information technology (IT) community. Federal IT managers now considered it inevitable that the courts would order the agencies to manage electronic records in an electronic environment and cease the practice of paper printouts. The Clinton administration appealed the Friedman decision. The government did not contest the court’s argument about the unique characteristics of electronic records. Rather, it contested the court’s conclusions about whether the Archivist had exceeded his authority in issuing GRS 20. It also argued that the court’s decision, if practically implemented, would have a paralyzing effect on the government because the software tools to implement the decision did not exist and/or were not installed on government computers. On August 6, 1999, to the surprise of the IT community, the Court of Appeals for the District of Columbia overturned the Friedman decision (http://www.cadc.uscourts.gov/). The Court of Appeals held that the Archivist had not exceeded his authority and reinstated GRS 20. The decision effectively threw the problem of electronic records management policy back into the lap of NARA.7 The plaintiffs in the case appealed to the Supreme Court on November 4, 1999.8 The series of court cases also had the effect of spotlighting the growing business case for electronic records management. IT managers were asking themselves: if an enterprise creates and manages virtually all of its information in an automated IT systems environment, does it make any sense to manage its records in a manual environment? The answer seemed obviously to be no.9 The effect of the court decisions and the business case logic on federal agencies was to convince the more forward thinking IT managers that they must begin actively exploring acquisition of electronic records management capability. Whereas up until now agencies had progressed toward an ever more electronic environment for creating, managing, and disseminating government information, they had continued the practice of printing out paper copies of documents and treating the paper copy as the record copy. The agencies practiced increasingly automated information management except for manual records management. By the mid-1990s progressive IT managers adopted the conviction that mandatory electronic records management was simply a matter of time.

The advent of electronic RMAs and the incorporation of records management into the automated office environment has potentially profound consequences for federal IRM. The statutory definition of IRM found in the original Paperwork Reduction Act of 1980 and echoed in the 1985 OMB Circular No. A-130, Management of Federal Information Resources,17 was a bifurcated concept. IRM was two things: • The management of information considered as a resource; and • The management of those resources associated with information, such as computers, telecommunications, personnel, and funds. Federal IRM has lived throughout its brief history with the curse of this bifurcation. Although agency managers might give lip service to the primacy of information management as the essence of IRM, resources have flowed overwhelmingly to IT management. Typically, the senior-most IRM official, today called the Chief Information Officer (CIO), came from a background of IT management and spent most of his or her career with the acquisition and management of IT. The vast majority of IRM dollars went to IT acquisition and management. Information management typically referred to the duties of an agency’s Privacy Act officer, Freedom of Information Act officer, paperwork control official, and records officer, four sets of duties usually relegated to lower ranking personnel. As the demand for greater information dissemination to the public grew in the 1980s and hyper-accelerated with the advent of the Internet in the 1990s, information management began to occupy more of the time and attention of agency CIOs, intruding on the primacy of IT management. The 1995 amendments to the Paperwork Reduction Act particularly placed emphasis on information dissemination, adding responsibilities in this area both to the duties of the Director of the Office of Management and Budget (OMB) and to agency heads. Congress, in effect, widened the missions of all federal agencies to include attention to information dissemination. Initiatives such as the Vice President’s National Performance Review accentuated the message. Electronic records management’s arrival onstage has occurred somewhat independent from the new emphasis on dissemination, driven more by Iran-Contra and the court decisions. Whatever the historical causality, the integration of information management and IT management in federal agencies is finally being forced. Once electronic RMAs are incorporated into an agency’s IRM environment, the following propositions are truer than ever before: • It is no longer possible to plan and manage the life cycle of information without taking into account the life cycle of the IT system in which the information resides. • It is no longer possible to plan and manage the life cycle of an IT system without taking into account the life cycle of the information residing in the system. What evidence presents itself for these assertions? As an example, consider the study of digital imaging standards completed in 1999 by Lockheed Martin on behalf of NARA and DoD.18 Following are excerpts from the executive summary of the study; The use of computers is changing the way government documents are created, accessed and managed. Electronic records, the Internet and E-mail have become an increasingly large part of the everyday work environment. To improve access, distribution, and interoperability, Federal agencies are converting large numbers of documents from paper to electronic digital images. … Long-term preservation of digitally imaged records has become problematic for Federal records requiring permanent retention. While the advantages of digitally imaged documents are tremendous, due to the relatively short life cycle of digital image technology (both hardware and software), it is commonly accepted that all formats used today will eventually become obsolete. … For an electronic record long term preservation requires that as the technology changes that the record be migrated from one format to another and then verified to ensure no loss of data. … Plan and budget for migration of digital images every 3–5 years with cost equivalent to 50–100% of the costs associated with original imaging project. [emphasis added] These quotations were selected to make a point. The point is that the study tells federal IT managers to change their thinking about information system planning because of the nature of their information management responsibilities. The logic and economies of today’s IT capabilities drive agencies toward digitization of information, but the nature of records management forges an indissoluble link between information management and IT management. Yes, an agency realizes economies and efficiencies by automating its information management. But the agency also incurs new and perhaps unanticipated IT management costs by the same token. To restate the propositions: information management and IT management must occur in an integrated framework in today’s office environment. Records management requirements are only a reflection of the need for an agency to manage its information holdings efficiently and effectively. This realization gives new weight to dicta records managers have been uttering for years. Archivists have long preached that the time to plan for records management is at the point when IT systems are being designed; that is, at the beginning of the system life cycle, not at the end. Failure to plan and budget for proper information (read: records) management at the outset of the system life cycle leads to far greater costs at the end of the cycle and/or the failure to carry out statutory records management responsibilities altogether.