At the beginning of the year, we laid out a step-by-step roadmap for what Federal agencies need to do to comply with the deadline set by the National Archives and Records Administration (NARA) for managing all permanent electronic records electronically by December 31, 2019. With the recent expansion of these requirements to encompass all temporary records by 2022, it’s more important than ever that agencies ensure they’re on track.
Since publishing the roadmap, we’ve gone into more detail about several key steps, like assessing inventory and creating a records schedule. Another key question – and step #8 on our roadmap – is creating and implementing appropriate records management policies. Specifically, agencies need to ensure that they have policies in place to guide their staff in complying with NARA requirements.
But what does that mean in practice, and how can agencies determine if they’re on track with their policies?
1: Don’t neglect the policy aspect.
Hopefully this goes without saying, but don’t skim over policy-setting as part of the records management process. Though we’re already more than halfway to this year’s deadline, NARA’s requirements reflect an ongoing mandate, and there are still future deadlines on the horizon. It’s not too late to adjust policies, if needed, to facilitate meeting current and upcoming NARA requirements.
2: Don’t be intimidated by the prospect of drafting new policy.
Yes, it can be a time-consuming process, but it’s not as hard as it might seem. If the agency has already created an approved records schedule, they’re halfway there. NARA itself can also help: “The Records Management Policy and Outreach Program, under the Office of the Chief Records Officer for the U.S. Government, is responsible for developing Federal records management policies and guidance related to records creation, management, and disposition with an emphasis on electronic records.”
3: Start by auditing any existing records management policies.
Are any of them out of date? Do they align with all applicable and current requirements, guidance, and regulations? Ensure that policies address all key elements of records management, including record creation (both when, and when not, to create records), disposition, retention, security, retrieval, and destruction (again, both when, and when not, to destroy). Policies should also define roles: who has access to what records and who is responsible for what records management activities.
4: Remember that policies are for workers.
When drafting or updating policies, try to remember that they’re not for NARA or for the lawyers. They’re directives for workers on how to do their jobs correctly and legally. Thus, policies should be written to be human-readable (watch the legalese and government-speak) and instructive. That can help staff to be more efficient and effective in managing records and information.
5: Align policy with electronic records management tools and systems.
Users should be able to program their records management tools and technologies with their policies, so that the system can automatically enforce them. That way, the tool itself can prevent actions that are out of line with policy requirements while ensuring users follow proper protocols. For example, the tool should be able to enforce retention and disposal policies. We wrote about evaluating electronic records management tools here.
6: Review policy periodically.
The only constant is change, as NARA’s own recently issued new guidance illustrates. Policies can easily fall out of date and become less useful or, worse, counterproductive. Repeat #3 above – auditing policies – on at least an annual basis to ensure they remain relevant and compliant.
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