Responding to President Obama’s Memorandum on Government Records: 5 Steps to Get You There

By: In: Federal Government Records On: Mar 08, 2012
Responding to President Obama’s Memorandum on Government Records: 5 Steps to Get You There

Federal records managers are racing against a ticking clock to respond to a Nov. 28, 2011 Presidential Memorandum calling for the improvement of their records management practices. Records and information management has been thrust into the national spotlight as a means to cut government costs and make information more transparent to its citizenry. Records managers are excited to see their world, historically a “behind the scenes” function in any organization, elevated into the limelight.

But this enthusiasm is tempered by the enormity of the challenge – and the short amount of to complete a response. As they assess their situation and consider solutions, federal records managers can look to the information management practices of private industry, where mature programs have been developed in response to the risks of regulatory compliance and litigation.

President Obama’s Presidential Memorandum for Managing Government Records directs all branches of government to reform records management policies and practices. Each agency is instructed to modernize its records management policies to minimize costs, operate more efficiently, and promote openness and accountability – the backbone of Obama’s Open Government Directive.

Agencies have until March 27 to assess current practices and make recommendations for improvement.  Their challenge is not small, and improvement means reconciling issues that include:

  • Information overload: Every agency is challenged with managing all information under a single policy to account for, and properly organize, a deluge of data in all formats (paper, electronic, audio, video, tweets, Facebook posts, etc.) and knowing what should be considered a record.
  • Lack of resources and awareness: Constrained funding makes it hard to find the required staff to manage information properly. Additionally, employees may not understand their role in following and reinforcing proper information management practices.
  • Keeping everything is not the best policy: In most agencies, 5-10 percent of records are deemed permanent, with the balance considered “temporary” and requiring management through their lifecycle based on retention schedules (rather than kept forever) to realize opportunities for cost savings and compliance.
  • Decentralization: Widely dispersed organizations are likely to have trouble establishing an enterprise-wide policy; individual locations may have their own habits, processes and tools that need to be reconciled or even eliminated.
  • Solve for today and tomorrow: Regardless of agency function, most employees are record creators (and record-keepers) and should be prepared to help implement and enforce policy – for today and tomorrow. The amount of information is only going to increase; flexibility and adaptation is imperative to the present and future success of records management.
  • Maturity and expense: Each agency is at a different stage in their records management process, creating and receiving different kinds of records (dependent on their role), making it difficult to adopt a universal records management prescription. They also need to able to understand – and anticipate – what their unique business needs are. And shrinking budgets place a premium on precious dollars needed to store and manage information.

 

With these issues in mind, government agencies face fundamental hurdles in implementing and enforcing plans to modernize records and information management programs. Fortunately, there is a blueprint for responding to President Obama’s call to action – one proven out by private industry. Here are some fundamental records and information management areas that – properly addressed – can equip organizations to respond to the Memorandum and enable sound information management.

Step #1: Determine staffing & governance

Determine who is ultimately responsible for records and information management– success starts from the top down. Assign a full-time records manager – with knowledge of the intricate ways federal organizations access and use information – to work alongside the agency’s IT, legal, and Continuity of Operations (COOP) partners. Collaboration is crucial to a compliant and efficient program.

Step #2: Understand & organize around your information priorities

Not all records are created equal. Government agencies should determine their risk profiles – what information is vital or likely required to meet compliance and legal needs like the Freedom of Information Act (FOIA), litigation requirements, or to comply with the National Archives and Records Administration (NARA)’s Code of Federal Regulations (CFR).  Agencies can then create a prioritized and phased strategic plan allowing for the organization, storing and secure destruction of paper records, and adhere to NARA requirements for long-term preservation, including digitization, conversion to micro-film or a climate-controlled records center. If needed, seek outside expertise to help with this process.

Step #3: Make it strategic

Records management has historically been regarded as a “lights-on” function, often managed by the facilities team. Leading organizations a corporate records manager’s value as a strategic business partner to legal, IT, compliance, FOIA Officers, and more – someone who can help the organization get better use from their information. Records and information management should be a strategic priority, and the records manager empowered to create, implement and enforce a culture of policy compliance.

Step #4: Change – or create – the records management culture

Policies and strategies aren’t enough, however; you need to train and create the right culture to effect true organizational change. Common hindrances to effective policy are organizational ennui (aka the “this is how we’ve always done it” syndrome).

Whether busting old habits or creating new ones, policy enforcement first begins with education. A successful records and information management plan involves teaching employees about key aspects (retention, disaster recovery, information access, etc.) and continually marketing and communicating the value of compliance.

Step #5: Exercise Audit & Accountability

When it comes to records and information management, most public agencies – like the private sector – have tight budgets and strict regulations with which to contend with and lack the opportunity to weigh their options (e.g., the March 27 Memorandum deadline or the recently passed Jan. 12 HIPAA deadline). Government agencies are expected to understand where records are created, stored and accessed throughout the organization, and to be able to establish a consistent audit and maintenance routine, creating a roadmap for compliance.

Following these steps will contribute to the timely access of information regardless of location or format; greater employee awareness and adherence to policies and procedures; consistent methods for managing all record formats; confident responses to discovery and FOIA requests; and the ability to confidently and securely destroy records once retention requirements are met. The guidelines above are designed to satisfy the March 27 response deadline and help build a solid foundation for sustainable records and information management programs for years to come.

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About the author

Sue Trombley

Sue Trombley, Managing Director of Thought Leadership at Iron Mountain, has more than 25 years of information governance consulting experience. Prior to her current role, Trombley led Iron Mountain’s Consulting group responsible for business development, managing a team of subject matter experts, and running large engagements. Trombley holds a Master’s degree in Library and Information Science and recently was certified as an Information Government Professional. She sits on the AIIM Board, the University of Texas at Austin of School of Information Advisory Council, and is VP of the Boston ARMA chapter. She is Iron Mountain’s representative on the newly formed Information Governance Initiative and is frequent speaker at association events.