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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