The challenges of analog records management

Each year, the National Archives and Records Administration releases its Federal Agency Records Management (FARM) report.  The 2017 version, released in August 2018, shows that agencies are mostly on track for meeting upcoming records management deadlines that will shift the government towards a more modernized, digitally inclusive state.

Despite their progress, agencies still have room for improvement when it comes to governing the lifecycle of their records. As NARA moves toward a paperless 2022, agencies must take a holistic approach to ensure they have the necessary tools for managing their records effectively, with a focus on having a plan for their analog records.

The need for a comprehensive strategy is apparent when examining some of the figures from the FARM report. One of the most apparent issues was the rate at which agencies are transferring their permanent records (in any format) to NARA. “Even though 96% of agencies said they are aware of the requirement to formally request permission from NARA to retain permanent records beyond their eligibility to transfer them to NARA, there was little or no change in the number of agencies transferring permanent records in any format," NARA said in the latest FARM report. "Compared to the last two years, the figure remains around 50%. More concerted efforts are needed to ensure permanent records are transferred when eligible.”

The report also found that:

• 50 percent of agencies transferred non-electronic records to NARA in 2017.
• 41 percent of agencies have records that are 30 years or older that are not being stored with NARA, meaning they are being held in offices or facilities.
• Only 22 percent of agencies transferred electronic records to NARA in 2017.

As NARA stated, the overwhelming majority of agencies are aware that they should be coordinating with NARA when storing permanent records past their original lifecycle, yet only half -- at best -- have actually followed through on this requirement. If agencies are already struggling to transfer permanent records in any format today, what will happen when they can only submit records to NARA in electronic formats?

Transferring electronically is and will continue to be essential, but another pressing problem is that 46 percent of agencies indicated they were bound to observe legal requirements for hard-copy records for multiple reasons, including the need to have a physical copy for backup, for example.  That statistic, considering the digitization goals of NARA’s 2022 plan, underscores the need for agencies to have a comprehensive plan for both digital and hard copy records.

So what steps should agencies be taking now to ensure the integrity of their information management capabilities heading into 2022 and beyond?

Mapping the information landscape

The first step for agencies is to ensure they have a current, accurate inventory of where their information resides and exactly what requirements govern each record. From there, they should classify those records into the following sub-categories:

• Records that are required to stay in analog format beyond 2022.
• Records that can be digitized and managed electronically beyond 2022.
• Records on retention schedules that require dispositioning prior to 2022.

These three classifications will help organize the specific action plans agencies must include in their overall information management strategy. Records that fall under the latter two categories will either be transferred electronically to NARA after 2022 or will have reached the end of their lifecycle by that timeframe. Given NARA’s plan to no longer accept analog records past 2022, the real issue is what will  agencies do with records that fall into the first category?

Establishing an analog plan

Agencies must implement their own strategies for managing those analog records in the most efficient way possible, both financially and operationally. This will require extra focus on implementing better search and tracking capabilities, given that “slightly less than half of agencies said that all records and information were easily retrievable and accessible when needed for agency business,” according to the 2017 FARM report. NARA acknowledged this “is an area of concern and bears watching over the next several years.”

When developing these plans, agencies should be aware of underemployed approaches, such as utilizing commercial records storage facilities that can function as an alternative to NARA Federal Records Centers, both before and after 2022. The FARM report revealed that only 25 percent of agencies are currently storing inactive temporary and/or permanent records in a commercial records storage facility. Such facilities can help agencies to free up time, resources and valuable physical office and onsite storage space while still retaining full control and access to records when needed. It is very possible to not only achieve cost savings, but also enhance records operations at the same time. In fact, accessibility is often dramatically improved when records are moved from agency staging or holding areas because records are centralized and subjected to rigorous tracking and chain-of-custody requirements. Finally, agencies may be able to leverage cost savings gained from streamlining analog records management to fund digitization initiatives in order to prepare for 2022 and further strengthen their overall information governance posture.

The FARM report has shown that many agencies still have work to do regarding their lasting information management plans, especially as it pertains to their analog records and NARA’s 2022 digitization goals. In order to create comprehensive information governance plans that incorporate records management, agency officials must understand what they have and where, and then develop specific plans for the various types of records. Agencies need focused strategies for their hard copy records soon, and officials cannot afford to overlook the cost-saving, accessibility and compliance benefits of third-party storage.