Elements of Records Management
by ssmith ~ June 19th, 2008A record is a document or other electronic or physical entity in an organization that serves as evidence of an activity or transaction performed by the organization and that requires retention for some time period. Records management is the process by which an organization:
Determines what types of information should be considered records.
Determines how active documents that will become records should be handled while they are in use, and determines how they should be collected once they are declared to be records.
Determines in what manner and for how long each record type should be retained to meet legal, business, or regulatory requirements.
Researches and implements technological solutions and business processes to help ensure that the organization complies with its records management obligations in a cost-effective and non-intrusive way.
Performs records-related tasks such as disposing of expired records, or locating and protecting records related to external events such as lawsuits.
Determining which documents and other physical or electronic items in your organization are records is the responsibility of corporate compliance officers, records managers, and lawyers. By carefully categorizing all enterprise content in your organization, they can help you ensure that documents are retained for the appropriate period of time. A well-designed records management system helps protect an organization legally, helps the organization demonstrate compliance with regulatory obligations, and increases organizational efficiency by promoting the disposition of out-of-date items that are not records.
A records management system includes the following elements:
A content analysis that describes and categorizes content in the enterprise that may become records, provides source locations, and describes how the content will move to the records management application.
A file plan describing, for each type of record in the enterprise, where they should be retained as records, the policies that apply to them, how they need to be retained, how they should be disposed of, and who is responsible for managing them.
A compliance requirements document defining the rules that the organization’s IT systems must adhere to in order to ensure compliance, along with the methods used to ensure the participation of enterprise team members.
A method for collecting records that are no longer active from all record sources, such as collaboration servers, file servers, and e-mail systems.
A method for auditing records while they are active.
A method for capturing records’ metadata and audit histories and retaining them.
A process for holding records (suspending their disposition) when events such as litigations occur.
A system for monitoring and reporting on the handling of records to ensure that employees are filing, accessing, and managing them according to defined policies and processes.
The practice of records management involves:
Creating, approving, and enforcing records policies, including a classification system and a records retention policy
Developing a records storage plan, which includes the short and long-term housing of physical records and digital information
Identifying existing and newly created records, classifying them, and then storing them according to standard operating procedures
Coordinating access and circulation of records within and even outside of an organization
Executing a retention policy to archive and destroy records according to operational needs, operating procedures, statutes, and regulations.
Often, a records management system helps to aid in the capture, classification, and ongoing management of records throughout their lifecycle. Such a system may be paper based (such as index cards as used in a library), or may be a computer system, such as an electronic records management application.
ISO 15489:2001 states that records management includes:
setting policies and standards;
assigning responsibilities and authorities;
establishing and promulgating procedures and guidelines;
providing a range of services relating to the management and use of records;
designing, implementing and administering specialized systems for managing records; and
integrating records management into business systems and processes.
Managing Physical Records
Managing physical records involves a variety of diverse disciplines. At the simplest, physical records must be organized and indexed. In more complex environments, records management demands expertise in forensics, history, engineering, and law. Records management then resolves to being a coordination of many experts to build and maintain the system.
Records must be identified and authenticated. In a business environment, this is usually a matter of filing business documents and making them available for retrieval. However, in many environments, records must be identified and handled much more carefully.
Identifying records. If an item is presented as a record, it must be first examined as to its relevance, and it must be authenticated. Forensic experts may need to examine a document or artifact to determine that it is not a forgery, or if it is genuine, that any damage, alterations, or missing content is documented. In extreme cases, items may be subjected to a microscope, x-ray, radiocarbon dating or chemical analysis to determine their authenticity and prior history. This level of authentication is rare, but requires that special care be taken in the creation and retention of the records of an organization.
Storing records. Records must be stored in such a way that they are both sufficiently accessible and are safeguarded against environmental damage. A typical contract or agreement may be stored on ordinary paper in a file cabinet in an office. However, many records file rooms employ specialized environmental controls including temperature and humidity. Vital records may need to be stored in a disaster-resistant safe or vault to protect against fire, flood, earthquakes and even war. In extreme cases, the item may require both disaster-proofing and public access, which is the case with the original, signed US Constitution. Even civil engineers must be consulted to determine that the file room can effectively withstand the weight of shelves and file cabinets filled with paper; historically, some military vessels were designed to take into account the weight of their operating procedures on paper as part of their ballast equation (modern record-keeping technologies have transferred much of that information to electronic storage). In addition to on-site storage of records, many organizations operate their own off-site records centers or contract with commercial records centers.
Circulating records. Records are stored because they may need to be retrieved at some point. Retrieving, tracking the record while it is away from the file room, and then returning the record, is referred to as circulation. At its simplest, circulation is handled by manual methods such as simply writing down who has a particular record, and when they should return it. However, most modern records environments use a computerized records management system that includes the ability to employ bar code scanners for better accuracy, or radio-frequency identification technology (RFID) to track movement of the records from office to office, or even out of the office. Bar code and RFID scanners can also be used for periodic auditing to ensure that unauthorized movement of the record is tracked.
Dispositioning of records. Disposition of records does not always mean destruction. Disposition can also include transfer of records to a historical archive, to a museum, or even to a private party. When physical records are destroyed, the records must be authorized for destruction by law, statute, regulation, and operating procedure. Once approved, the record must be disposed of with care to avoid inadvertent disclosure of information to unauthorized parties. The process to dispose of records needs to be well-documented, starting with a records retention schedule and policies and procedures that have been approved at the highest level of an organization. An inventory of the types of records that have been disposed of must be maintained, including certification that the records have been destroyed. Records should never simply be discarded as any other refuse. Most organizations use some form of records destruction including pulverization, paper shredding or incineration.
Managing Electronic Records
The general principles of records management apply to records in any format. Digital records (almost always referred to as electronic records) raise specific issues however. It is more difficult to ensure that the content, context and structure of records is preserved and protected when the records do not have a physical existence. Guidance on the management of electronic records can be found on the websites of National and State Archives authorities listed below.
Unlike physical records electronic records cannot be managed without a computer or other machine. Functional requirements for computer systems that can be used to manage electronic records have been produced by the US Department of Defense DoD 5015.2, the National Archives of England & Wales [1] and the European Commission MoREQ. It is noteworthy that the Moreq specification has been translated into at least twelve languages [2] and is used beyond the borders of Europe. Development of MoReq was initiated by the DLM Forum, funded by the European Commission.
Particular concerns exist about the ability to retain and still be able to access and read electronic records over time. Electronic records require appropriate combinations of software versions and operating systems to be accessed, and so are at risk because of the rate at which technological changes occur. A considerable amount of research is being undertaken to address this issue, under the heading of digital preservation. The Public Record Office Victoria (PROV)[3] located in Melbourne, Australia published the Victorian Electronic Records Strategy (VERS) which includes a standard for the preservation, long-term storage and access to permanent electronic records. The VERS standard has been adopted by all Victorian Government departments. A digital archive has been established by PROV to enable the general public to access permanent records.
Current Issues in Records Management
As of 2005, records management has increased interest among corporations due to new compliance regulations and statutes. While government, legal, and healthcare entities have a strong, historical records management discipline, general record-keeping of corporate records has been poorly standardized and implemented. In addition, scandals such as the Enron/Andersen scandal, and more recently records-related mishaps at Morgan Stanley, have renewed interest in corporate records compliance, retention period requirements, litigation preparedness, and related issues. Statutes such as the US Sarbanes-Oxley Act have created new concerns among corporate “compliance officers” that result in more standardization of records management practices within an organization. Most of the 90s has seen discussions between records managers and IT managers, and the emphasis has expanded to include the legal aspects, as it is now focused on compliance and risk.
Privacy, data protection, and identity theft have become issues of interest for records managers. The role of the records manager to aid in the protection of an organization’s records has often grown to include attention to these concerns. The need to ensure that certain information about individuals is not retained has brought greater focus to records retention schedules and records destruction.
The most significant issue is implementing the required changes to individual and corporate culture to derive the benefits to internal and external stakeholders. Records management is often seen as an unnecessary or low priority administrative task that can be performed at the lowest levels within an organization. Publicized events have demonstrated that records management is in fact the responsibility of all individuals within an organization and the corporate entity.