In November 2011, the White House told agencies in a memo to submit evaluations of their records management practices and suggest reforms to the National Archives and Records Administration and the Office of Management and Budget by March 27.
Archivist David Ferriero told attendees of the FOSE conference Thursday that agencies can expect NARA and OMB to issue reforms in response to agency suggestions by July 25, according to FierceGovernment IT.
Ferriero said he could not predict what the directive will look like coming this summer but indicated many agencies had reviewing general records schedules high on their list.
He said the general records schedule team is examining the schedule and will include a project plan updating general records schedules in its final report.
Ferriero expects the revision to include clarifications as to what is and what is not a record, such as a tweet or a Facebook post.
He said the NARA’s general records team is creating a records schedule to cover social media outlet records.
The review will additionally update the time frames for agencies to turn records over to NARA, he said.
Agencies said they were dissatisfied with the turnaround time in submitting records through NARA and Ferriero said NARA will examine that turnaround time as well.
According to Ferriero, agencies also identified the Electronic Records Archive system as an area needing improvement.
Agencies said the system is clunky and needs to be more user friendly, he said.
There is no way a thorough review of the submittals by ALL Agencies can be completed and fully thought out new directives could be turned around by July. If they are NARA directives, they would come in the form of 36CFR revisions, which have to go through the Federal Register review process, which would take longer than that.
In addition, if the content of this article is any indication of the types of directives that will be coming out, they BETTER spend more time than planned! One comment was: “Ferriero expects the revision to include clarifications as to what is and what is not a record, such as a tweet or a Facebook post…” Based on records management practices, the determination of “what is a record” is based on the CONTENT, not the source… in that case ANY tweet or FB post could be a record or a non-record, but until someone evaluates the content AND the context , there is no way to make that determination.
Another similar comment that makes no sense is: ” …NARA’s general records team is creating a records schedule to cover social media outlet records.” There is no need or logic in having a schedule related to ‘social media content’ for the same reason cited above… it;s the CONTENT that you schedule. This would be as illogical as making a retention schedule for databases or spreadsheets without giving consideration to the content.
There may be some logic to making a general condition similar to that in Part 1236 of 36CFR on Electronic Records for Email on “transitory records” saying they can be left in the native application for up to 180 days and then deleted, but even here the requirement is IF THEY ARE A RECORD, they must be moved to a records management application and scheduled based on their content.
I certainly hope that after waiting decades to make improvements, NARA doesn’t make a knee-jerk reaction and attempt to respond so quickly they issue guidance that is of questionable value, or that attempts to respond to issues they haven’t fully evaluated the impacts of.