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NARA e-mail standards (fwd)
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From mordor.cs.du.edu!eff.org!owner-eff-activists Mon Apr 18 18:09:55 1994
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Date: Mon, 18 Apr 1994 20:18:06 -0400 (EDT)
From: "Richard F. Strasser" <[email protected]>
Subject: NARA e-mail standards (fwd)
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To: [email protected] (eff-activists mailing list)
I thought that list members might be interested in this note, which was
posted on another list.
Richard F. Strasser <[email protected]>
---------- Forwarded message ----------
Date: Mon, 18 Apr 94 10:40:51 EDT
From: Florey/AAIQ <[email protected]>
To: [email protected]
Subject: NARA e-mail standards
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To: [email protected]
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!
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