Review: James Lappin’s “The state of records management in 2013”

James Lappin’s thought-provoking and easy-to-read articles on various aspects of records and information management are, in my opinion, must-read. The latest one is “The state of records management in 2013: the challenges”, http://thinkingrecords.co.uk/2013/02/13/the-state-of-records-management-in-2013-the-challenges/

It’s a good article, albeit being seriously misguided in certain aspects.

I am especially dissatisfied with records managers being portrayed as Don Quixotes of sorts, which are fighting for some business-irrelevant ancient principles. IT people, on the contrary, are presumed to be white and fluffy guardians of company’s interests 🙂 Probably James should learn a bit more about our profession…

EDRMS systems are shown as unsatisfactory because of expensive and/or time-consuming customization / configuration / integration which are necessary in order to ensure interoperability between them and business systems. But what will be the final advice? To implement “records governance tool / repository” i.e. EDRMS disguised by a fancy name! And, in the absence of standardization, it will be impossible to avoid customization / configuration / integration.

And standardization isn’t mentioned. Strange… The article in general seems to imply something, “the one who must not be named”. What’s wrong about openly speaking about MoReq2010 specifications and their possible benefits? 🙂

Does Russian legislation allow for destruction of the original paper records after digitizing or microfilming?

This article was originally published at Saperion blog at http://www.saperion.com/news-media/newsletter-archive/saperioninside-032012/details/article/does-russian-legislation-allow-destroying-the-original-paper-records-after-digitizing-or-microfilmin/

Generally speaking, the answer to this question is “No”. Current Russian legislation does not provide for the possibility to satisfy the legal and regulatory retention requirements by preserving electronic or microfilm copies in lieu of original paper records.

It should be noted, however, that since 2009 the Russian legislation is being quickly and radically reformed. Nearly all the previously existing obstacles to electronic recordkeeping in government and in business sectors have been removed. It is quite possible that at some point in the future the lawmakers will consider the possibility to store the digital and/or microfilm copies instead of bulky paper originals.

So far the Russian legislation allows permanent retention of scanned copies and destruction of the originals after scanning for a single type of records – the census questionnaires. Government Decree of July 26, 2010 No. 554 “On approval of storage procedures of forms and other records of National Population Census of 2010” prescribes permanent preservation of scanned copies of census records and authorizes the destruction of the paper originals after completion of their processing and expiry of one-year retention period after the publication of preliminary census results.

As in many other countries, the judges of the Russian courts have a discretionary power (but not obliged) to admit the copies into evidence instead of the originals (see, for example, “The Civil Procedure Code of the Russian Federation” of 14.11.2002 No. 138-FZ, Art. 67 “Assessment of evidence”, http://base.consultant.ru/cons/cgi/online.cgi?req=doc;base=LAW;n=127758;div=LAW;mb=LAW;opt=1;ts=C3825233E4DDF89093C2078DF0415927  ). Courts generally do so provided the opposing party in litigation doesn’t challenge the fidelity of the copy. In case of doubt the court asks for the originals, and their absence without good reason sufficiently reduces the probative value of copies.

Hence in the current Russian practice the organizations may digitize/microfilm and consequently destroy the paper originals of only those records which are not covered by legal or regulatory retention requirements (or the corresponding requirements are already satisfied) and are not expected to be required as evidence in litigation or investigations. Usually that’s the records that are retained by the organization solely for its internal purposes. It is recommended, however, to conduct a risk analysis in each specific case and consult with lawyers. Organizations obligated by the statutes or contractual agreements to transfer their permanent records to state archives must get the approval by the relevant archival authorities of the destruction of originals and their replacement with copies.

When making microfilm copies, one can also consult the voluntary national standard GOST 13.1.101-93 “Reprography. Micrography – Microfilm of document with the status of original – Order of manufacture, registration, storage and application” (the English title is given according to the standard itself).

The moments to ponder about your digital information

After reading and excellent article by Kate Cumming “Top 7 moments you should think, ‘Is my digital information OK??’” (published on March 12, 2012 at http://futureproof.records.nsw.gov.au/top-7-moments-you-should-think-is-my-digital-information-ok/ ), I’ve thought I could suggest some additional “moments” to consider:

1. When you create a database or a database-driven system.
– What is a record in the database? How the database content will be documented? (output records, flat files, snapshots, SIARD files etc.)
– If there might be a need to erase or anonymize some data in the future, the database’ architecture should support this.
– Database documentation is vital. Unlike traditional records, the data in the database can be easily misinterpreted (unintentionally or deliberately).

2. When it’s time to dispose of old stuff
– How to eliminate all (controllable) copies of the information?
– How to control the uncontrollable copies? To implement or not to implement DRM technologies?
– How to ensure the expungement of the information from all the backup copies?

3. When you start using social media for business

Impact of the social media on professional discourse

Some people believe that the proliferation of social media results in more original content and more opinions, especially in comparison with traditional media.

What we actually see is that very few professionals are willing to share their thoughts. The same few authors dominate both paper-based media and various e-media. I’ve just checked the statistics of the major Russian records/archival forum http://forum.rusarchives.ru/ : 5899 registered, some 4% deemed “active” i.e. they’ve posted at least one post, and the majority of the posts is authored by a dozen of most active contributors. There are not so many «new faces» (i.e. the people that don’t write in paper journals) among the activists …

So it seems to me that social media is an excellent new way of communication. It makes asking questions and spreading the word so much easier. New content, however, is still being created mostly by the same small group, as it were in the times before the Internet.

Is something wrong with standard setters?

Recent discussions about the prospects for such different standards as ISO 30300/30301 (Management System for Records, MSR) and MoReq2010 make me wonder whether present-day standard setters are in touch with real world, with its economic troubles, austerity measures, redundancies etc.

As a consultant, I am willing to use any tool that comes my way, including the above-mentioned documents. But I honestly can’t see the incentives for traditional ECM/ERM vendors to spend a fortune for implementing MoReq2010 in their products – what could they possibly gain? They’ve got more urgent problems to cope with such as competition vs SharePoint and cloud services, tougher sales due to buyers’ more cautious spending.

In a similar way, at present I see no suitable niche for MSR. If someone needs certification, it’s better to get well-established one (Quality, Information Security) for the same money. Adding MSR to Quality Managements System seems like overkill. Strategically IMHO it would be better to offer MSR as mandatory component of all the management systems…

Of course, national environments differ, as I’ve learned from discussions at LinkedIn and Twitter. Maybe European environment is more favorable for these standards… Well, I don’t mind my skeptical assessment to be proved wrong.

NARA’s crowdsourcing project

Recently NARA has opened “Managing Government Records” portal (see http://blogs.archives.gov/records-express/?p=1579 ). The goal of this crowdsourcing project is “public information gathering related to the Presidential Memorandum on Managing Government Records”.

Two things are IMHO worth noting.

The first one is cultural. When people don’t know how to solve a problem, the Russians will create a committee or two, while Americans will appoint a C-level official. Now wonder the first idea was to mandate a post of Chief Records Office (CRO) for the federal agencies 🙂

The second issues concerns general management of crowdsourcing projects. If NARA really wants to get some useful ideas and discussions, it should personally invite leading records & information management, IT, legal etc. professionals to participate.