Be businesslike about archiving electronic records, NARA says
- By Christopher J. Dorobek
- Jul 27, 1998
NARA is not going
to tell agencies
in detail what to do, Miller said.
The National Archives and Records Administration is recommending that
agencies use an electronic record-keeping system only if it makes business sense.
NARA last week published in the Federal Register its latest proposal on archiving
electronic records. The proposal is a revision of the initial recommendations that NARA
issued last month [GCN, June 29, Page 67].
The proposal responds to the November 1997 U.S. District Court ruling that overturned
NARAs General Records Schedule 20, which let agencies delete electronic records once
they had copied them to paper or saved them in another format. The Federal Register
posting came days after the Justice Department, on behalf of NARA, filed an appeal of the
If the question is, What do we do with electronic documents and what do we
do with electronic records? my view on this is that there is no single answer. The
real question is going to be, What are your needs? said Michael
Miller, director of NARAs Modern Records Program, at a records management conference
in Washington last week.
There is no simple answer, said Miller, who is also chairman of NARAs Electronic
Records Workgroup. He added that NARA is not going to tell agencies in detail what to do.
Agencies must figure out how to determine if electronic documents are government
records and then how to save them, Miller said. Agencies dont necessarily have to
automate the process, he said. Some agencies dont need electronic record-keeping
systems, Miller said, especially agencies that rely on paper documents to conduct the
majority of their business and have little e-mail traffic.
The latest policy proposal instructs agencies how to handle electronic source records,
which NARA has defined as the electronic versions of documents that track the flow of
Millers workgroup recommended a three-part approach for managing the storage and
disposal of electronic source records:
The NARA proposal is available on the Web at http://www.nara.gov/records/grs20.
In its appeal of the ruling that struck down GRS-20, the Justice Department called the
ruling fundamentally flawed and said it reflects a misunderstanding of GRS-20.
The district courts invalidation of GRS-20 second-guessed the archivists
policy choice for resolving a difficult problem, Justice attorney Matthew M. Collette
noted in the appeal.
Agencies must delete electronic records from their live systems to avoid
overload, Collette said. Accordingly, GRS-20 directs agencies to preserve
these electronic records in record-keeping systems that preserve their structure, content
and context, and then delete the versions that remain on the live system, once they are no
longer needed for updating or revision.
A hearing on the appeal is scheduled for October.