National Archives: Preserving Electronic Records in an Era of Rapidly
Changing Technology (Letter Report, 07/19/1999, GAO/GGD-99-94).
Records generated electronically, such as electronic mail, word
processing documents, CD ROMS, and web pages, present a preservation
challenge for the National Archives and Records Administration (NARA)
and other agencies because of the changing nature of these new
technologies and because the sheer volume of these records is
mushrooming. This report discusses issues relating to electronic records
management, focusing on the preservation of electronic records. GAO
provides information on (1) the challenges that confront NARA and
federal agencies as a result of their growing reliance on electronic
media; (2) the status of selected agencies' and NARA's implementation of
electronic records management; and (3) the policies and procedures used
by other governments, state and foreign, for electronic records
management.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-99-94
TITLE: National Archives: Preserving Electronic Records in an Era
of Rapidly Changing Technology
DATE: 07/19/1999
SUBJECT: Archives
Federal records management
Reengineering (management)
Electronic publications
Strategic information systems planning
Comparative analysis
Foreign governments
State governments
Surveys
IDENTIFIER: NARA International Research on Preservation of Authentic
Records in Electronic Systems
NARA Fast Track Guidance Development Project
Florida
Oklahoma
Oregon
Texas
Australia
Canada
United Kingdom
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United States General Accounting Office GAO Report to
the Chairman Committee on Governmental Affairs U.S. Senate July
1999 NATIONAL ARCHIVES Preserving Electronic Records in an
Era of Rapidly Changing Technology GAO/GGD-99-94 United States
General Accounting Office
General Government Division Washington, D.C. 20548 B-281101 July
19, 1999 The Honorable Fred Thompson Chairman, Committee on
Governmental Affairs United States Senate Dear Mr. Chairman: Under
the Federal Records Act, the National Archives and Records
Administration (NARA) is responsible for providing guidance and
assistance to federal agencies on the creation, maintenance, use,
and disposition of government records.1 Federal agencies are
responsible for ensuring that their records are created and
preserved in accordance with the act. Records generated
electronically, such as electronic mail (E-mail) messages, word
processing documents, CD ROMs, and World Wide Web site pages,
present an archival challenge for NARA and agencies because these
technologies are new and changing very rapidly. Also, the sheer
volume of these records is mushrooming. At your request, we
undertook an effort to identify issues that relate to electronic
records management (ERM), focusing specifically on the
preservation of electronic records. On February 4, 1999, we
provided your office with a briefing on our work. As your office
agreed, this report documents our oral briefing and provides
additional information on (1) the challenges that confront NARA
and federal agencies as a result of their increased reliance on
electronic media; (2) the status of selected agencies' and NARA's
implementation of ERM; and (3) the ERM policies and procedures of
selected other governments (state and foreign). We conducted our
work between August 1998 and June 1999 in accordance with
generally accepted government auditing standards. Appendix I
contains a discussion of our scope and methodology. On June 7,
1999, we provided a draft of this report to the Archivist, who
heads NARA, for review and comment. The Archivist's comments are
discussed at the end of this letter and reprinted in appendix II.
NARA and federal agencies are faced with the substantial challenge
of Results in Brief preserving electronic
records in an era of rapidly changing technology. In addition to
handling the burgeoning volume of electronic records, NARA 144
U.S.C. 2904. Page 1 B-281101 and the agencies must address several
hardware and software issues to ensure that electronic records are
properly created, permanently maintained, secured, and retrievable
in the future. Also, NARA's and the agencies' ERM efforts are
competing with other information technology priorities,
particularly the need to ensure that their computers are Year 2000
compliant. NARA is responsible for providing guidance and
assistance to agencies on how to maintain their official
government records and for archiving those records once they are
transferred to NARA. The agencies are responsible for ensuring
that records are created and preserved in accordance with the
Federal Records Act. No centralized source of information exists
to document the extent to which agencies are fulfilling their ERM
responsibilities under the act. On the basis of our discussions
with officials from NARA and four judgmentally selected agencies,2
we found that plans and capabilities for ERM vary greatly across
agencies. Some agencies are waiting for more specific guidance
from NARA, while others are moving forward on their own to
implement ERM programs. NARA has recently postponed a planned
baseline survey that was intended to obtain governmentwide
information on agencies' ERM programs because NARA believes that
it should first complete a business process reengineering (BPR)
effort. This BPR effort, which is intended to assess and
potentially alter NARA's guidance to and interaction with
agencies, is expected to take 18 to 24 months. We believe that the
baseline survey information is critical to ensuring that the BPR
results are relevant to the current ERM situations at agencies and
the survey should not be postponed. Further, these baseline data
are needed to meet one of NARA's stated strategic planning goals
to "stay abreast of technologies in the agencies." We are making a
recommendation in this report regarding the baseline survey. Even
while planning its BPR effort, NARA is taking some immediate
action to address the agencies' needs for ERM guidance and
direction. NARA is now revising its ERM guidance to address
personal computers and the resulting desktop management of
electronic records. NARA's efforts to improve ERM include revising
bulletins and other guidance as well as forming a new group to
help answer agencies' immediate questions on ERM issues. NARA has
taken many of its actions as a result of a court 2We made limited
contacts at the Environmental Protection Agency, the General
Services Administration, the National Aeronautics and Space
Administration, and the Department of the Treasury's Office of
Thrift Supervision. Page 2 B-281101 decision,3 which held that
NARA's guidance for the deletion of electronic records exceeded
its statutory authority. The federal government is not alone in
its quest to properly preserve and maintain electronic records.
State and foreign governments are addressing similar challenges.4
From our limited judgmental sample of state and foreign
governments, it is clear that these governments and the federal
government often differ in (1) the organization of their archival
activities, (2) their philosophies on centralization versus
decentralization of recordkeeping responsibilities, and (3) their
computer hardware and software capabilities. NARA's mission is to
ensure "ready access to essential evidence" for the Background
public, the President, Congress, and the courts. NARA is to make
the permanently valuable records of the government-in all media-
available for reference and research. In addition to the best
known documents, such as the Declaration of Independence, the
Constitution, and the Bill of Rights, NARA preserves billions of
pages of textual documents and numerous maps, photographs, videos,
and computer records. Each citizen has a right to access the
official records of the government. During fiscal year 1998, 2.6
million people (including genealogists, historians, librarians,
and veterans) visited NARA's facilities to browse and do research,
and NARA received over 56 million "hits" on its Web site from
scholars, students, and other inquirers. Records management is a
statutory responsibility of the Archivist and heads of the federal
agencies. The Federal Records Act, comprising the Records Disposal
Act and other statutes, defines a record as "all books, papers,
maps, photographs, machine readable materials, or other
documentary materials, regardless of physical form or
characteristics, made or received by an agency...under federal law
or in connection with the transaction of public business and
preserved or appropriate for preservation...as evidence of the
organization, functions, policies, decisions, procedures,
operations, or other activities of the Government or because of
the informational value of data in them."5 3Public Citizen v.
Carlin, 2 F. Supp. 2d 1 (D.D.C. 1997). 4We interviewed officials
from Florida, Oklahoma, Oregon, and Texas and reviewed public
documents from Australia, Canada, and the United Kingdom. 544
U.S.C. 3301. Page 3 B-281101 NARA and agency staff work together
to identify and inventory an agency's records to appraise the
value of the records and determine how long they should be kept
and under what conditions. The formal approval of this work is
called scheduling. Agency records must be scheduled through either
records schedules specific to each agency or a general records
schedule (GRS), which is issued by the Archivist and authorizes
disposal, after a specified period of time, of records of a
specified form or character common to several or all federal
agencies. Records of permanent value (such as final budget
submissions and calendars of senior staff) must be preserved and
eventually transferred to NARA for archival and research purposes.
Other records deemed of insufficient value to warrant their
preservation, such as payroll or travel, are considered temporary
records and must be preserved by the agency for only a specified
length of time. In addition to the Federal Records Act, several
other laws, such as the Paperwork Reduction Act, Privacy Act,
Freedom of Information Act, Electronic Freedom of Information Act,
and Government Paperwork Elimination Act, also address records
management requirements for both paper and electronic records.
Also, the General Services Administration, the Office of
Management and Budget, and individual agencies issue records
management regulations. NARA and federal agencies are confronted
with many ERM challenges, NARA and Federal particularly
technological issues. NARA must be able to receive electronic
Agencies Face ERM records from agencies, store them, and
retrieve them when needed. Agencies must be able to create
electronic records, store them, properly Challenges
dispose of them when appropriate, and send permanently valuable
electronic records to NARA for archival storage. All of this must
be done within the context of the rapidly changing technological
environment. As stated in NARA's 10-year strategic plan covering
the period of 1997 to NARA's Challenges 2007, NARA's goals are
to determine how to (1) preserve electronic records that the
nation will need, (2) manage change, (3) stay abreast of
technologies in federal agencies, and (4) use technologies to
safeguard valuable information and make it more readily
accessible. NARA's plan also points out that it must meet the
public's need for "on-line" access to information and work in
partnership with other entities that are struggling with the same
problems. According to our research and discussions with NARA
officials and other records management professionals, NARA is
faced with a number of challenges to ensure that federal records
in electronic format are preserved. NARA officials told us that
NARA needs to expand its capacity Page 4 B-281101 to accept the
increasing volume of electronic records from the agencies. Over
the past quarter century, NARA has taken in approximately 90,000
electronic data files. NARA has estimated that federal agencies,
such as the Department of State and the Department of the
Treasury, are individually generating 10 times that many
electronic records annually just in E-mail, many of which may need
to be preserved by NARA. One of the items in NARA's fiscal year
2000 budget request would allow NARA to begin development of a
system to save large volumes of E-mail messages and other small
data files that agencies are increasingly creating. Some of the
initial research and development for this system is being done in
fiscal year 1999. In addition to the increasing volume, the
increasing variety of electronic records (e.g., word processing
documents, E-mail messages, databases, digital images, and Web
site pages) complicate NARA's mission to preserve these records.
NARA must address some definitional problems, such as what is an
electronic record, when is an E-mail message a record, or when are
Web site "virtual records" considered records. Also, electronic
records are generated as files that require compatible hardware
playback devices and the correct software for retrieving, viewing,
and transmitting. Because agencies follow no uniform hardware
standards, NARA must be capable of accepting various formats
(hardware and software) from the agencies and maintaining a
continued capability to read those records. The long-term
preservation and retention of those electronic records is also a
challenge since providing continued access to archived records
over many generations of systems is difficult. The average life of
a typical software product is 2 to 5 years. There are currently
only three alternatives for maintaining accessibility over time,
as follows: (1) maintain records in a software-independent format,
(2) reformat and migrate records to new software systems, or (3)
maintain the records in the original format and maintain the
necessary hardware and software to make them accessible. Another
concern is the deterioration of the storage media over time, and
NARA must consider the permanency of the formats used by agencies
(such as floppy disks and CD ROMs). These and other media that are
used now and that are being developed must remain readable over a
long period of time or be changed to a different media. Finally,
another challenge is NARA's ability to offer guidance to the
agencies regarding the orderly management of electronic records,
especially relating to the authenticity and reliability of
electronic records that eventually will be transferred into NARA's
custody. Current electronic security measures, encryption, and
authentication techniques could Page 5 B-281101 increase the
reliability and authenticity of electronic records; however, there
has been little analysis of the risk or the costs and benefits of
implementing those measures for agencywide systems. It is
important to note that a properly maintained electronic
recordkeeping system provides more security and accountability
than a comparable paper-based system because the electronic system
can record details on access, revision, and deletion. Records
management is initially the responsibility of the agency staff
Agencies' Challenges member who creates a record, whether the
record is paper or electronic. Preservation of and access to that
record then also becomes the responsibility of agency managers and
agency records officers. Electronic records are now frequently
created on a personal computer. Electronic recordkeeping
responsibilities are often overlooked by the staff member who
creates the record. The staff member should be made aware of what
constitutes an electronic record, how to save it, and how to
archive it for future use. Decentralized control over electronic
documents is changing the face of records management because
records can easily be deleted without records managers even being
aware that the record existed. The agencies are challenged with
informing employees what is required of them and how to accomplish
their records management responsibilities. Agencies receive
guidance from NARA, but they must put their own recordkeeping
systems in place. Some agencies continue to experience confusion
over what constitutes an electronic record and who has
responsibility for preserving the record. Questions also arise
regarding how to handle multiple copies or versions of documents
and whether drafts are official records. Agencies' employees send
and receive huge volumes of E-mail in performing their official
duties and responsibilities. Agencies must determine which of
these E-mail messages are records. When E-mail messages are
determined to be official records, agencies must assign records
management responsibility, control multiple versions, and archive
the messages. Also, because much internal business deliberation is
conducted via E-mail, for privacy reasons, these messages must be
reviewed before being released to the public. Agencies' ERM
efforts are competing for attention and resources with other
information technology priorities, particularly in those agencies
dealing with the Year 2000 problem. NARA officials believe that
ERM Page 6 B-281101 activities may be slowed by agencies'
concentration on other priorities, such as systems' upgrades and
Year 2000 compliance. Regarding Year 2000 compliance, the old
technology that created some electronic records might not be Year
2000 compliant, and this noncompliance could cause future
retrieval difficulties for the agencies and NARA. On the basis of
our discussions with NARA officials and officials of the Agencies'
and NARA's four previously mentioned selected agencies and
discussions at Actions to Implement governmentwide
conferences on the subject of records management, we learned that
agencies vary in their records management programs and in ERM
their capabilities to implement ERM. Some agencies are waiting for
more specific guidance from NARA, while others are moving forward
by looking for ways to better manage their electronic records.
However, there has been no recent governmentwide survey of
agencies' compliance with the archival provisions of the Federal
Records Act or agencies' ERM activities. NARA is planning a BPR
effort that will collect limited information from some agencies
but will not include a complete governmentwide baseline survey. In
the interim, NARA has begun to revise its ERM guidance to provide
some immediate guidance and direction for the agencies. Our
discussions with NARA officials and officials from the four
Agencies Vary in Their judgmentally selected agencies indicated
that agencies vary in how they Implementation of ERM are
implementing their ERM programs. NARA officials directed us to the
Department of Defense (DOD) as one of the agencies that is most
advanced in its ERM efforts. NARA has been working with DOD for
several years to develop DOD's ERM software standard,6 which is
intended to help DOD employees determine what are records and how
to properly preserve them. NARA endorsed the DOD standard in
November 1998 as a tool that other agencies could use as a model
until a final policy is issued by NARA. The endorsement does not
mandate that agencies use the DOD standard; instead, NARA said
that the standard conforms to the requirements of the Federal
Records Act and establishes baseline requirements for managing
electronic records. NARA also said that while the DOD standard is
an appropriate basis for records management, there might be other
equally valid ways to address ERM. The DOD standard is intended as
a starting 6The DOD standard, Design Criteria Standard for
Electronic Records Management Software Applications, November
1997, was issued under the authority of DOD Directive 5015.2,
Department of Defense Records Management Program, April 11, 1997.
Page 7 B-281101 point that must be tailored to a specific agency's
needs. NARA said that each agency must still address ERM within
the context of its own computer and policy environments. The DOD
standard is a tool that is intended to help agencies develop
automated systems to file, track, and preserve or destroy its
electronic records. DOD's standard has a series of requirements
that are measurable and testable and based on various laws and
NARA regulations. The standard, which is mandatory for all DOD
components, provides implementation and procedural guidance on the
management of records in DOD. ERM information systems that were in
place before the approval of this standard must comply with the
standard by November 1999. The DOD standard (1) sets forth
baseline functional requirements for records management
application software that is used by DOD components in the
implementation of their records management programs; (2) defines
required system interfaces and search criteria to be supported by
records management application software; and (3) describes the
minimum records management requirements that must be met, based on
current NARA regulations. The DOD standard also requires that
records management software perform several functions, including
the following: * Assign each record a unique, computer-generated
code that identifies the document. * Treat filed E-mail messages,
including attachments, as records. * Allow records to be
searched, screened, and viewed on the basis of record profiles. *
Identify records that can be sent to NARA for storage. * Notify
users when a document is eligible for destruction or transfer, and
destroy or transfer it after approval. As of June 2, 1999, nine
companies had records management application products that were
certified by DOD as meeting its standard. Some products are ERM
software, while others integrate their document management or
workflow products with ERM software from another vendor. Two
agencies that are testing ERM software that meet the DOD standard
are the National Aeronautics and Space Administration (NASA) and
the Department of the Treasury's Office of Thrift Supervision
(OTS). NASA did a limited test of an early version of one ERM
product and found it difficult to use and time-consuming to
install. The software did not perform well with NASA's varying
hardware and software platforms. According to an Page 8 B-281101
agency official, the NASA test did, however, give NASA a better
understanding of its requirements, including its records
management program in particular. NASA plans to evaluate a newer
version of this software later in fiscal year 1999. OTS is testing
ERM software that differs from the one NASA used. OTS' test is
meant primarily to organize its electronic files. According to
OTS' manager of its records branch, it is important that ERM
software requires users to make no more than two or three extra
keystrokes, and that users realize there is a benefit to this
additional "burden." Even though NARA is aware of the efforts of
DOD, NASA, OTS, and NARA Does Not Have various other
agencies, it does not now have governmentwide data on the
Governmentwide Data on records management capabilities and
programs of all federal agencies. Agencies' ERM Efforts NARA
had planned to do a baseline assessment survey to collect such
data on all agencies by the end of fiscal year 2000. According to
NARA officials, this survey was needed to identify best practices
at agencies and collect data on (1) program management and records
management infrastructure, (2) guidance and training, (3)
scheduling and implementation, and (4) electronic recordkeeping.
NARA had planned to determine how well agencies were complying
with requirements for retention, maintenance, disposal,
retrieval/accessibility, and inventorying of electronic records.
In the early results in the pilot test of the survey at a limited
number of agencies, NARA discovered that most of the pilot
agencies lacked adequate employee guidance regarding electronic
records. The Archivist has decided to put the baseline survey on
hold primarily because of what he believes are other higher
priority activities, such as NARA's BPR effort, which could change
NARA's regulations and thereby affect the data that NARA would
need to acquire from the agencies. NARA's BPR effort to address
its internal processes, as well as guidance to and interactions
with the agencies, is expected to begin before the end of fiscal
year 1999. This BPR effort should take 18 to 24 months. However,
NARA will now proceed without the rich baseline of information
from across the federal government that was originally planned.
NARA officials could not give us a time frame regarding when the
survey effort would be reinitiated. In the interim, according to a
NARA Policy and Communications official, NARA will continue to
gather additional information about the status of records
management through a targeted assistance program, which will focus
on helping agencies that have the most urgent records management
needs. This effort, by definition, will not provide a baseline
across all agencies. Page 9 B-281101 Currently, NARA does in-depth
studies of two to four agencies a year in which it looks at the
agencies' records management policies and then recommends areas
for improvement. Since some individual agencies have not been
reviewed for several years, this method of collecting information
on agencies has not yielded a current governmentwide look at the
situation. Thus, this effort does not achieve NARA's strategic
planning goal to "stay abreast of technologies in the agencies."
Historically, NARA's ERM guidance has been geared toward
mainframes NARA Is Revising Its ERM and databases, not personal
computers. In addition to NARA's planned Guidance
BPR, NARA is taking some immediate action to revise its guidance
to be more appropriate in today's workplace environment. NARA's
electronic records guidance to agencies is found in the Code of
Federal Regulations,7 which establishes the basic requirements for
creation, maintenance, use, and disposition of electronic records.
In 1972, before the widespread use of personal computers in the
government workplace, NARA issued GRS 20 to provide guidance on
the preservation of electronic records. However, agency records
officers, data processing staff, and even NARA staff had trouble
understanding and applying the first version of GRS 20.
Subsequently, GRS 20 had several major revisions, culminating with
the 1995 revision authorizing, among other things, that after
electronic records, which were created in an office automation
environment or computer centers, were placed in a recordkeeping
system-electronic, paper, or microfilm-the records could be
deleted. NARA's ERM guidance under the 1995 version of GRS 20 was
challenged in a December 1996 lawsuit filed in the United States
District Court for the District of Columbia by a public interest
group.8 In an October 1997 decision, the court found that the
Archivist exceeded the scope of his statutory authority in
promulgating GRS 20. First, the court stated that GRS 20 did not
differentiate between program records, which are possibly subject
to preservation, and administrative "housekeeping" records, which
the court found were the only records allowed to be disposed of
through GRSs. Second, the court found that electronic records did
not lose their status as program records once they were preserved
on paper; they are considered to be unique records and distinct
from printed versions of the same record. 736 CFR Part 1234.
8Public Citizen v. Carlin, 2 F. Supp. 2d 1 (D.D.C. 1997). Page 10
B-281101 The court also held that by categorically determining
that no electronic records have value, the Archivist failed to
carry out his statutory duty to evaluate the value of records for
disposal. Moreover, the court determined that GRS 20 violated the
Records Disposal Act because it failed to specify a period of time
for retention of records that are to be disposed of through a GRS.
The court thus declared GRS 20 "null and void." The government
filed an appeal of this ruling in December 1997. In March 1998,
NARA issued a bulletin informing agencies that NARA had
established a working group with a specific time frame to propose
alternatives to GRS 20. The same public interest group that
initially challenged GRS 20 went back to court when it realized
that the Archivist was informing agencies that they could continue
to rely on GRS 20 even after the court had ruled it "null and
void." The court, in a subsequent ruling, found that the Archivist
had "flagrantly violated" the court's October 1997 order and
ordered, among other things, the NARA working group to have an
implementation plan to the Archivist by September 30, 1998. In
September 1998, on the basis of recommendations made by the NARA-
sponsored electronic records working group, the Archivist decided
to take several steps. Specifically, the Archivist agreed to (1)
issue a NARA bulletin to give guidance to agencies on how to
schedule the retention of program and unique administrative
records in all formats; (2) modify other GRSs to authorize the
deletion of electronic source records for administrative records
after a recordkeeping copy has been produced; (3) publish guidance
on a new GRS for information technology records in the Federal
Register by March 15, 1999; and (4) form a follow-on group by
January 1999 to continue work on electronic recordkeeping guidance
issues. On September 29, 1998, after the Archivist notified the
court of NARA's intended actions, the court ordered that the
Archivist was authorized to state that agencies could continue to
follow current disposition practices for electronic records until
they receive other disposition schedule approval from NARA,
notification by NARA that the government's appeal has been
resolved and NARA has provided further guidance as a result of the
appellate court's decision, or further order of the court. In
response to the court's ruling, as of May 1999, NARA had taken the
following actions: * Issued NARA Bulletin 99-04 on March 25,
1999, to guide agencies on scheduling how long to keep electronic
records of their program activities and certain administrative
functions formerly covered under GRS 20. Agencies have until
February 1, 2000, to submit to NARA either new Page 11 B-281101
records schedules for their electronic copies or a detailed plan
for scheduling the records. Agencies that submit a plan must
commit to scheduling their electronic copies within 2 years,
unless NARA approves a different time frame. NARA is also offering
no-cost training to agency records officers to assist in
developing schedules or plans. * Issued a revision in the general
records schedules on December 21, 1998, to authorize agencies'
disposal of certain administrative records (such as personnel,
travel, and procurement) regardless of physical format, after
creating an official recordkeeping copy. * Drafted a new general
records schedule for certain administrative records to document
the management of information technology. NARA has received
comments from agencies on this draft, has made revisions, and will
send the draft out for agencies' comments again. NARA plans to
incorporate the agencies' comments and send the draft to OMB for
comment. * Initiated a follow-on study group in January 1999-Fast
Track Guidance Development Project (FastTrack)-intended to answer
the immediate questions of agencies about ERM. FastTrack is
intended to answer agencies' questions that can be resolved
relatively quickly without major research. FastTrack staff
consists of NARA staff, agency officials, and consultants. NARA's
plan is to disseminate information to agencies over its Web site
and include best practices and frequently asked questions. Our
review of the ERM activities in four states and three foreign ERM
Activities of governments showed that approaches to
ERM differ. These entities often Selected State and did
things differently from each other and/or NARA. Foreign
Governments Some state governments are making decisions regarding
the same ERM Some States Have challenges that face
NARA and federal agencies, while some are waiting to Centralized
Policies but see what works for other governments. Our
interviews with officials from Decentralized Custody of four
states (Florida, Oklahoma, Oregon, and Texas) revealed that these
Records states approach some issues
differently than the federal government or each other.9 In
general, the four state archiving agencies provide centralized
policies and procedures that are described in either state law or
administrative 9Our descriptions of the requirements imposed by
state laws and regulations are primarily based on our interviews
with state officials. Page 12 B-281101 rules. State archiving
agencies that take physical custody of the actual records do so
when the records are no longer needed by the individual agencies
but are of archival value. In these cases, the states do not have
the capability to maintain the records in electronic format but
require nonelectronic copies. The four states have relied on
record-tracking systems, which allow them to determine where
specific records are located. Two of the four states that we
selected emphasized the use of the Internet as a mechanism that
allows both the archivist and the general public to determine
where records may be found. While the state officials indicated
that state law and the administrative rules that they issue guide
their records management requirements, they also interact with
NARA and other states to assist in determining their states'
policies. The state archiving officials we interviewed were all
aware, to varying degrees, of the recent federal actions and
activities dealing with the archiving of electronic records.
However, some of the states are moving forward independently and
have been doing so for several years. For example, according to
state officials, during the past 10 years, Texas has continually
revised its records management manual, records management
statutes, and administrative rules. Further, according to state
officials, Texas continues to study ways of providing better
support to agencies' records management programs. In November
1998, the Texas Electronic Records Research Committee completed a
legislatively directed report that made several recommendations to
help agencies manage their electronic records as required and make
state agency documents in electronic formats readily available to
the public. The committee's recommendations include guidelines to
enable better coordination among records management, archives, and
information systems staff within agencies. The recommendations to
the Texas State Library and Archives Commission and the Department
of Information Resources included * establishing administrative
procedures and training to ensure that all staff work together to
identify and manage electronic records to meet retention and
archival preservation requirements, * making library and archives
standards applicable to all state records maintained in electronic
format, * seeking a legislative change in the Local Government
Records Act so that the rules for managing electronic records can
be amended to make these standards applicable to all local
government records maintained in electronic format, Page 13 B-
281101 * jointly establishing and publishing guidelines for using
standard functional requirements for electronic recordkeeping
systems, * studying the issues of retaining electronic records of
enduring value for historical and research purposes to identify
available options and associated costs with the intent of
proposing legislative action, * developing cost models for
providing information to the public on-line, and * working with
the Office of the Attorney General to jointly establish rules and
guidelines for providing and managing access to publicly available
government information without compromising the privacy of
citizens. Similarly, according to state officials, Florida's
current records management policy is based primarily on 10 to 15
years of legislatively directed studies and reports on information
management as well as experience gained through Florida's archive
and historical records program, which it has operated since 1967.
In September 1998, a consultant's report on access to state
government electronic information of long-term or archival value
recommended that, among other things, the Florida State Archives
take custody of electronic records when an agency is defunct and
has no successor agency or when the records of an ongoing agency
have archival value. The report also recommended that the Florida
State Archives (1) serve as a "locator" for information about
archived electronic records; (2) review the agencies' annual
reports on information systems; (3) assist in detailed reviews of
the records policies and procedures of individual agencies; and
(4) contract with an outside party to maintain the electronic
records, including storing, providing access, and regularly
migrating data to meet preservation requirements. From our
interviews with officials in the four states and review of
documentation, we learned that some states have arrived at
decisions on how to address ERM issues. For instance: * Policies
and Procedures. According to state officials, the state archives
agencies in the four states we surveyed generally provide
centralized policies and procedures, described in either state
legislation or administrative rules, that are the catalysts for
policy development. Other considerations mentioned by the state
archives officials were federal laws, recommendations made by
internal and state auditors, observations of other states and the
federal government, and private business practices. * Guidance.
The records management regulations in Texas, Florida, and Oregon
provide specific guidance to state agencies. For example, Texas
provides guidance on (1) standardized definitions for terms
related to managing electronic records; (2) minimum requirements
for the Page 14 B-281101 maintenance, use, retention, storage, and
destruction of electronic records; (3) records management program
administration that incorporates ERM objectives into agency
directives, ensures that training is provided, ensures the
development and maintenance of up-to-date electronic systems
documentation, and specifies the location and media on which
electronic records are maintained; (4) security of electronic
records; and (5) public access to electronic records. Although
some differences exist in content or approach, state code or
administrative rules for Florida and Oregon provide equally
detailed, and often closely paralleled, guidance to state agencies
for managing electronic documents. * Electronic records
retention. State agencies in Texas, Florida, and Oklahoma retain
archiving responsibility and custody of electronic records. When
paper or microfilm records are no longer needed at the agency
level, those of archival value are transferred to a central
storage facility. In Texas, ERM and archiving system design are
functions that are decentralized to state agencies, while Florida
establishes minimum electronic recordkeeping requirements for all
state agency records management and archiving systems. Texas has
implemented an automated inventory tracking system to facilitate
access to nonelectronic records maintained by the archives.
Florida is considering using a contractor to develop and maintain
storage and access for electronic archival records, including
migration and software requirements. * Development of a
governmentwide information locator system. While Oregon and
Oklahoma use what is basically a manual system to provide the
public with access to archived records, Texas and Florida have
developed Internet-accessible government information locator
systems. The Texas Record and Information Locator Service is an
on-line resource for accessing government information statewide-
the next version will identify, describe, and locate individual
state government information resources as well as print
publications, individual documents, and databases available to the
public on the Internet. The Florida Government Information
Location System provides public Internet access to the location of
electronic and nonelectronic public records. * Training. All four
states sponsor organized records management training programs or
workshops for state employees. * Enforcement of records
management requirements. Authority to enforce mandated records
management requirements varies among the states. For example,
according to state officials, Oregon can impound records in danger
of being lost, and citizens of Florida can request a state
attorney Page 15 B-281101 investigation when they think that
records may have been prematurely destroyed. Florida is also
currently considering a requirement for formal statements of
compliance from all state agencies. The Texas State Code
establishes requirements for state agencies to transfer archival
records to the State Archives or preserve them within the agency.
The National Historical Publications and Records Commission
(NHPRC), the grantmaking affiliate of NARA, provides funds to
state and local archives, colleges and universities, libraries and
historical societies, and other nonprofit organizations to help
locate, preserve, and provide public access to documents and other
historical materials. NHPRC has made several grants to states in
recent years to assist them in their ERM efforts. NARA is working
with Australia, Canada, and the United Kingdom on Some Foreign
Governments common ERM challenges. Our review of public documents
showed that, Are More Centralized and although these
countries share common challenges, they each have taken Provide
More Detailed somewhat different approaches to making ERM
decisions. Guidance Than Others The Australian,
Canadian, and United Kingdom governments differ from each other,
as well as NARA, in how they archive national records. For
example, Australia has strong central authority and decentralized
custody. Due to this decentralized custody, Australia must rely on
a government- maintained information locator system to determine
where the records are located. Since agencies within the
governments can have various software systems, decentralized
custody places the responsibility on the agencies, not the
national archives, to ensure that records are retrievable
regardless of any changes in hardware or software technology
requirements. Use of the Internet is being integrated into their
systems for search, retrieval, and/or requests for information.
Australia has somewhat detailed records retention guidance to
which its agencies must adhere. Since it does not have direct
custody of electronic records, the Australian central archiving
agency has compliance audit authority to ensure that individual
agencies follow records management and archiving policies and
laws. Implementation of an automated records management software
system is under way. Canada's national archives takes a somewhat
different approach. Canada established "vision statements," rather
than specific policies, and the individual agencies maintain their
own electronic records until they have no more operational need
for them. At that point, records of archival value are transferred
to the national archives. Also, Canada offers use of the Internet
for searching, requesting, and retrieving pertinent records. Page
16 B-281101 The United Kingdom established broad guidelines, which
are put into practice by its individual agencies or departments in
a partnership arrangement with its national archives. These
guidelines address all types of records, including electronic
records. Currently, the Public Record Office has several study
groups addressing management of electronic records and overall
strategy for E-mail and office desktop systems. Case studies in
five different departments are currently in progress to identify
alternative practices for electronic recordkeeping. NARA is also
part of two ongoing international initiatives that are to study
and make recommendations regarding ERM. The first effort-
International Research on Preservation of Authentic Records in
Electronic Systems (INTER PARES)-is made up of archivists from
seven countries (United States, Canada, Ireland, Italy,
Netherlands, Sweden, and United Kingdom) and six research teams
(United States, Canada, Northern Europe, Italy, Australia, and the
Collaborative Electronic Notebook Systems Association). INTER
PARES first met in Washington, D.C., in June 1998. The second
effort is made up of English-speaking countries (United States,
United Kingdom, Australia, and Canada). This group first met in
London, England, in July 1998. NARA and federal agencies are being
challenged to effectively and Conclusion efficiently manage
electronic records in an environment of rapidly changing
technology and increasing volume of electronic records. On the
basis of our discussions with officials from NARA and four
judgmentally selected agencies, we determined that ERM programs
vary greatly across agencies. NARA had planned to conduct a
baseline survey intended to obtain governmentwide information on
agencies' ERM programs, but NARA has now postponed the survey
because it believes that it should first complete a BPR effort to
improve guidance and assistance to agencies. Considering that the
BPR effort would more likely result in changes that are practical
and functional for the agencies if it included an assessment of
where the agencies are today in terms of ERM, the survey should
not be postponed. In order for NARA to have the best information
to make decisions during Recommendation its BPR effort and,
thereby, improve ERM in the federal government, we recommend that
the Archivist, National Archives and Records Administration,
conduct a baseline assessment survey now and use the information
as input into the BPR effort, rather than postpone the survey
until after the effort is completed. Page 17 B-281101 On June 7,
1999, we provided the Archivist with a draft of this report for
Agency Comments and comment. We received his comments in a letter
dated June 22, 1999, which Our Evaluation is
reprinted in appendix II. In commenting on our draft report, the
Archivist said that we have ably outlined significant electronic
records challenges faced by NARA and federal agencies. The
Archivist also commented, however, that he did not concur with our
recommendation to conduct a baseline assessment survey now and use
the information as input into the BPR effort. The Archivist stated
that the survey has been put "on hold only temporarily," and that
he is "committed to conducting it in a timely fashion, and in a
way that provides the greatest benefit to NARA and the agencies in
improving Federal records management programs." While there is
general agreement that the baseline survey is needed and should be
done, we disagree with the Archivist over the timing of the
survey. During our review, we looked for justification for
conducting the survey before, during, or after the BPR effort.
Conducting the baseline survey now could provide valuable
information for the BPR effort, while also accomplishing the
survey's intended purpose of providing baseline data on where
agencies are with regard to records management programs. Because
agencies vary in their implementation of ERM programs, the
baseline survey would provide much richer data than the limited
information collection effort outlined by the Archivist in his
response letter and would fulfill an agency strategic goal. NARA
would also be in a better position in later years to assess the
impacts of its BPR effort, as well as to assess progress toward
achieving its long-range performance targets as outlined in the
Archivist's letter. Finally, we are concerned about how long it
may take to complete the baseline survey if it is put on hold
until after the BPR effort. Given that this effort is expected to
take 18 to 24 months after it is started and the baseline survey
is expected to take about 2 years, the baseline of governmentwide
records management programs may not be established until perhaps
sometime in calendar year 2003. There is also the possibility that
the baseline survey would be further delayed while the BPR
initiatives have a chance to gain a foothold throughout the
government. For these reasons, we continue to believe that the
baseline survey should be done now, as the BPR effort gets under
way. Page 18 B-281101 We are sending copies of this report to the
Honorable Joseph Lieberman, Ranking Minority Member of this
Committee, and the Honorable John W. Carlin, Archivist of the
National Archives and Records Administration. We will make copies
available to others upon request. Major contributors to this
report are acknowledged in appendix III. If you have any
questions, please call me on (202) 512-8676. Sincerely yours,
Laurie E. Ekstrand Associate Director, Federal Management and
Workforce Issues Page 19 Contents 1 Letter 22 Appendix I Scope and
Methodology 24 Appendix II Comments From the National Archives and
Records Administration 26 Appendix III GAO Contacts and Staff
Acknowledgments Abbreviations BPR business process
reengineering DOD Department of Defense EPA
Environmental Protection Agency ERM electronic
records management GRS general records schedule GSA
General Services Administration INTER PARES International
Research on Preservation of Authentic Records in Electronic
Systems NARA National Archives and Records
Administration NASA National Aeronautics and Space
Administration NHPRC National Historical Publications
and Records Commission OMB Office of Management and
Budget OTS Office of Thrift Supervision Page 20
GAO/GGD-99-94 Preserving Electronic Records Page 21 GAO/GGD-99-
94 Preserving Electronic Records Appendix I Scope and Methodology
To obtain information on the challenges that confront the National
Archives and Records Administration (NARA) and federal agencies as
a result of their increased reliance on electronic media, we
interviewed NARA and agency officials from four judgmentally
selected agencies-the Environmental Protection Agency (EPA), the
General Services Administration (GSA), the National Aeronautics
and Space Administration (NASA), and the Department of the
Treasury's Office of Thrift Supervision (OTS). We also (1)
interviewed other electronic records management (ERM)
professionals from educational institutions and records managers'
organizations and (2) reviewed documents and papers written on the
subject by these professionals and others. We also attended ERM
seminars, conferences, and meetings where NARA and many agencies
were represented, and these challenges were discussed. To obtain
information on the status of agencies' and NARA's implementation
of ERM, we made limited contacts at the previously mentioned
agencies to obtain information on their policies and procedures.
We interviewed records management officials at these agencies and
reviewed pertinent documentation. We selected EPA because they
have an active, progressive records management program; we
selected GSA because they have oversight records management
responsibilities in addition to operating their own records
management program. We chose NASA and OTS because they are
piloting ERM software to help them manage electronic records. We
also obtained and reviewed the Department of Defense's (DOD) ERM
software standard.1 In addition, we interviewed NARA staff and
reviewed NARA's guidance and oversight responsibilities. We also
interviewed an official of the Office of Management and Budget
(OMB) to determine how OMB assists NARA in providing guidance to
agencies. To obtain information on ERM policies and procedures of
some other governments (state and foreign), we judgmentally
selected three states (Florida, Oregon, and Texas) on the basis of
recommendations from records management professionals who said
that these states are considered leaders in ERM. We also
contacted another state near our Dallas Field Office that was not
mentioned by these professionals (Oklahoma). At the four states,
we interviewed officials and reviewed documentation of their
policies and procedures. (See footnote 9 in this report.) 1Design
Criteria Standard for Electronic Records Management Software
Applications, November 1997, issued under the authority of DOD
Directive 5015.2, Department of Defense Records Management
Program, April 11, 1997. Page 22
GAO/GGD-99-94 Preserving Electronic Records Appendix I Scope and
Methodology In addition, we obtained policies, procedures, and
other public documentation from the Internet Web sites of three
judgmentally selected foreign countries (Australia, Canada, and
the United Kingdom) that records management professionals
identified as being advanced in ERM. These three countries also
work with NARA on various ERM initiatives. Page 23
GAO/GGD-99-94 Preserving Electronic Records Appendix II Comments
From the National Archives and Records Administration Page 24
GAO/GGD-99-94 Preserving Electronic Records Appendix II Comments
From the National Archives and Records Administration Page 25
GAO/GGD-99-94 Preserving Electronic Records Appendix III GAO
Contacts and Staff Acknowledgments Michael W. Jarvis, (202) 512-
6363 GAO Contacts James H. Burow Acknowledgments James W.
Turkett Warren Smith James L. Rose James M. Rebbe David F. Plocher
Carol M. Hillier Page 26 GAO/GGD-99-
94 Preserving Electronic Records Page 27 GAO/GGD-99-94
Preserving Electronic Records Page 28 GAO/GGD-99-94 Preserving
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