I thought that list members might be interested in this note, which was posted on another list. Richard F. Strasser <rfs@maestro.com> ---------- Forwarded message ---------- Date: Mon, 18 Apr 94 10:40:51 EDT From: Florey/AAIQ <florey@saf3.hq.af.mil> To: ace-mg@esusda.gov Subject: NARA e-mail standards --------- The following is a converted OFFICEPOWER mail message ---------- To: ace-mg@esusda.gov CC: Subject: NARA e-mail standards New [*] Codes: [ ] Message: Hi, ACE'ers. I'm not sure just who y'all are, but you're surely interested in government records, so you must be OK. I'm an Air Force colonel in the Admin Comm and Records Mgt Div of HQ USAF Information Management. We have been conducting a functional process improvement (FPI) effort on records management since last summer in DoD. Air Force is executive agent. I'll pass my Priority: 2 Delivery Acknowledge [ ] View Acknowledge [ ] From: Florey/AAIQ By: florey@saf3 Attachment [*] -------------------------------- ATTACHMENT ------------------------------ thoughts to you on the questions you asked. They fit right into our study because the constant undercurent of our FPI was a solution to the problem of uncontrolled electronic records--those often created in e-mail that never find their way into the official recordkeeping system. I'll be happy to talk to any of you on the phone about the topic and have some real experts who work for me that can get deep into records in a hurry. I'm in the Pentagon at 703-697-4501. a. What's a federal record? As defined in public law--44 US Code 3301. "Records include all books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the United States Government under federal law or in connection with the transaction of public business and preserved for appropriate preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the Government or because of the informal value of data in them." As you can see, virtually any official interchange of information dealing with government business is considered a record to be preserved by the agency for varying periods of time. The National Archives and Records Administration approves that length of time for every record in the government thru the agency records managers. E-mail is most often an official record because it deals with government business; few e-mails are so personal that they fail to qualify as a record. b. Implications of managing e-mail records like paper records? You bet. See above--"regardless of physical form..." A record is a record, regardless of media. The content of the information is the key. We are required to manage e-mail records, but truthfully no one is really doing so in the government today. Big problem. There's a court case involving the White House on e-mail records created there. The overall situation was at the heart of our motivation for doing the FPI. We are checking off-the-shelf software that will allow us to manage e-mail records to the same standards we have for paper (or physical) records. c. Is there a possibility that we may have to print out e-mail records just for the requirement of controlling them as records? Well, we gotta do something. All of us are technically breaking the law by not controlling e-mail records. E-mail is official mail; transactions over e-mail fit the definition of a record far more times than not. But what a waste to get all this sophisticated equipment, fire electrons all over the world at a touch of a key, and then have to print out the results on paper just for the record. The answer is to load electronic recordkeeping software onto any e-mail system. The software captures the record into the official system just as if a record were paper and put in its proper place in the filing cabinet. Big cultural change involved. Action officers who create e-mail now have to stop and do their filing chores to put the e-mail into the system. The software does it in a rather painless fashion, but nevertheless it will be a step that none of us are having to endure now. In our FPI, we developed 46 requirements that any automated recordkeeping system would have to meet. We have a multi-service technical team looking at available software in the marketplace; the team spoke with vendors and then with users at their work sites to include industry in Atlanta and Boston and the Canadian government in Toronto. To our surprise, 43 of the requirements are available now--only a couple of artificial intelligence type requirements to make the filing absolutely transparent to the action officer are not yet available. We are on the verge of floating a policy document to the near summit of DoD that states, "no computer system (read LAN and e-mail producers) may be acquired that does not have electronic recordkeeping software. Legacy systems must be so equipped in a couple of years--or such a reasonable time." Our master plan is to acquire the capability to control e-mail type records in an automated fashion without having to convert them to paper. Retrieval, transfer, and eventual destruction of records will be fully automated and never involve paper. In fact, we will want virtually all conventional records (not films, video, and physical records) to be in the electronic system--we want to eliminate tha paper system as much as possible. Records created on a PC are already electronic-- paper mail that will be retained as a record will be scanned into the electronic system. By doing this, we can have fewer and longer retention periods. There will not be the constant stress to move paper records to larger storage facilities where the costs are less than in an office. (such as federal records centers) Retrievable data will be kept on-site for much longer periods of time. Now, a word about the NARA standards. We are getting together as a DoD on 12 May to discuss them, and DoD is hosting an interagency conference on the standards on 19 May. Our (Air Force) position going in is that yes indeed electronic records should be controlled to the same standards as paper records, which sadly we're not doing now, but which the new software will allow us to do. However, we bristle at the suggestion that electronic records should be maintained at a higher level of sophistication than paper records. We disagree that there needs to be an audit trail of when electronic records were read, further dispatched, etc. We have never done that for paper and don't want to start such unnecessary requirements for electronic. We have no idea if someone looks at a paper document in a filing cabinet--we should not be required to keep records (and unfortunately that's what they would be in a seemingly never-ending escalation of creation) of when electronic records are viewed. We presently have that standard only for Top Secret information. The courts are pushing the higher standards because the technology makes it possible and to make it easier to determine "what the President knew and when did he know it?" For the everyday office, this extra creation of records is both excessive and expensive--and not worth the value added. Hopefully, we government records managers can get together to refine the NARA guidelines to an appropriate and workable level. So, if you're not yet blind from reading all of this, I hope my thoughts were helpful. NARA will take the commentary from the corners of government, study them, and publish the final standards within a few months. Then we'll really know how to attack the problem of controlling e-mail type records. -- PGP PUBLIC KEY via finger! JAFEFFM Speaking & Thinking For Myself! * eagle@deeptht.armory.com email info@eff.org * *** O U T L A W S On The E L E C T R O N I C F R O N T I E R **** ***** Committed to Free Public Internet Access for World Peace *****