Records Management Questions
Every business or program must address well-defined objectives which will add value, either directly to the bottom line or toward the achievement of the organization's goals and objectives. Records management (RM) objectives usually fall into one of three categories:
- Service (effective and efficient),
- Profit (or cost-avoidance), and
- Social (moral, ethical and legal) responsibility.
Records management programs must manage organizational information so that it is timely, accurate, complete, cost-effective, accessible and useable. Better information, at the right time, makes better business.
Records management programs are not generally an organization's primary business, and even though RM programs don't usually generate income, the following are the most important reasons to set up a good records management program in your office anyway. (Adapted from Ten Business Reasons for Records Management in Information and Records Management: Document-based Information Systems, Robek, Brown, Stephens, 1995.)
- To Control the Creation and Growth of Records
Despite decades of using various non-paper storage media, the amount of paper in our offices continues to escalate. An effective records management program addresses both creation control (limits the generation of records or copies not required to operate the business) and records retention (a system for destroying useless records or retiring inactive records), thus stabilizing the growth of records in all formats.
- To Reduce Operating Costs
Recordkeeping requires administrative dollars for filing equipment, space in offices, and staffing to maintain an organized filing system (or to search for lost records when there is no organized system).
It costs $22 less per linear foot of records to store inactive records in the Federal Records Center versus in the office. [Multiply that by 30% to 50% of the records in an office that doesn't have a records management program in place], and there is an opportunity to effect some cost savings in space and equipment, and an opportunity to utilize staff more productively - just by implementing a records management program.
Usually, in an office that doesn't have a records program, 30-50% of the files could be stored off-site. In DOI, we average 25 feet of paper per person. In a 30 person office that could mean a savings of $7,000 annually!
- To Improve Efficiency and Productivity
Time spent searching for missing or misfiled records is non-productive. A good records management program can help any organization upgrade its recordkeeping systems so that information retrieval is enhanced, with corresponding improvements in office efficiency and productivity. A well designed and operated filing system with an effective index can facilitate retrieval and deliver information to users as quickly as they need it.
- To Assimilate New Records Management Technologies
A good records management program provides an organization with the capability to assimilate new technologies and take advantage of their many benefits. Investments in new computer systems don't solve filing problems unless current manual recordkeeping systems are analyzed (and occasionally, overhauled) before automation is applied.
- To Ensure Regulatory Compliance
In terms of recordkeeping requirements, the United States is the most heavily regulated country in the world. These laws can create major compliance problems for businesses and government agencies since they can be difficult to locate, interpret and apply. The only way an organization can be reasonably sure that it is in full compliance with laws and regulations is by operating a good records management program which takes responsibility for regulatory compliance, while working closely with the Office of General Counsel. Failure to comply with laws and regulations could result in severe fines, penalties or other legal consequences.
- To Minimize Litigation Risks
Business organizations implement records management programs in order to reduce the risks associated with litigation and potential penalties. This can be equally true in Government agencies. A consistently applied records management program can reduce the liabilities associated with document disposal by providing for their systematic, routine disposal in the normal course of business.
- To Safeguard Vital Information
Every organization, public or private, needs a comprehensive program for protecting its vital records and information from catastrophe or disaster, because every organization is vulnerable to loss. Operated as part of the overall records management program, vital records programs preserve the integrity and confidentiality of the most important records and safeguard the vital information assets according to a "Plan" to protect the records.
- To Support Better Management Decision Making
In today's business environment, the manager that has the relevant data first often wins, either by making the decision ahead of the competition, or by making a better, more informed decision. A records management program can help ensure that managers and executives have the information they need when they need it.
By implementing an enterprise-wide file organization, including indexing and retrieval capability, managers can obtain and assemble pertinent information quickly for current decisions and future business planning purposes.
- To Preserve the Corporate Memory An organization's files contain its institutional memory, an irreplaceable asset that is often overlooked. Every business day, you create the records which could become background data for future management decisions and planning. These records document the activities of the Agency which future scholars may use to research the workings of the Environmental Protection Agency in the 1990's.
- To Foster Professionalism in Running the Business
A business office with files askew, stacked on top of file cabinets and in boxes everywhere, creates a poor working environment. The perceptions of customers and the public, and "image" and "morale" of the staff, though hard to quantify in cost-benefit terms, may be among the best reasons to establish a good records management program.
Records include all books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the United States Government under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the Government or because of the informational value in them. (Taken from 44 U.S.C. Chapter 33, Sec. 3301)
Several key terms, phrases, and concepts in the statutory definition of records are defined as follows:
(Taken from the Code of Federal Regulations Part 1222, Subpart A, Sec. 1222.12)
- Documentary materials is a collective term for records, nonrecord materials, and personal papers that refers to all media containing recorded information, regardless of the nature of the media or the method(s) or circumstance(s) of recording.
- Regardless of physical form or characteristics means that the medium may be paper, film, disk, or other physical type or form; and that the method of recording may be manual, mechanical, photographic, electronic, or any other combination of these or other technologies.
- Made means the act of creating and recording information by agency personnel in the course of their official duties, regardless of the method(s) or the medium involved. The act of recording is generally identifiable by the circulation of the information to others or by placing it in files accessible to others.
- Received means the acceptance or collection of documentary materials by agency personnel in the course of their official duties regardless of their origin (for example, other units of their agency, private citizens, public officials, other agencies, contractors, Government grantees) and regardless of how transmitted (in person or by messenger, mail, electronic means, or by any other method). In this context, the term does not refer to misdirected materials. It may or may not refer to loaned or seized materials depending on the conditions under which such materials came into agency custody or were used by the agency. Advice of legal counsel should be sought regarding the ``record'' status of loaned or seized materials.
- Preserved means the filing, storing, or any other method of systematically maintaining documentary materials by the agency. This term covers materials not only actually filed or otherwise systematically maintained but also those temporarily removed from existing filing systems.
- Appropriate for preservation means documentary materials made or received which in the judgment of the agency should be filed, stored, or otherwise systematically maintained by an agency because of the evidence of agency activities or information they contain, even though the materials may not be covered by its current filing or maintenance procedures.
Every person who works for the Agency is responsible for Agency Records. Some people just spend more time at it than others, because they are in charge of a specific series of records (see Question 5).
If you create a document using a word processor, enter information into a database, file a document in a folder, answer an inquiry from the public, respond to a FOIA request, or do anything else that documents your activities for the DOI, you are a records custodian. You are responsible for ensuring the safety, timely availability, and proper retention and/or transfer of information in your custody.
If you are in charge of managing a specific series of records, you are responsible for organizing, maintaining and retiring those records.
Some of these responsibilites are laid out in 380 DM 1, Records Management Program and Responsibilities, as follows:
f. Agency managers are responsible for ensuring that their programs are properly documented and that records created by their programs are managed according to relevant regulations and policies.
g. Information system managers (program managers) are responsible for overseeing the creation and use of electronic records in keeping with federal regulations and Agency policy. This includes coordination with the records officer to establish recordkeeping requirements including a retention period and to implement authorized disposition instructions for system information and documentation. Systems managers also coordinate with records officers to develop specific information resource management plans to meet future system information needs.
h. ADP or Information Technology Managers are responsible for managing ADP resources, as well as notifying the systems managers and records officers of technology changes that would affect access, retention, or disposition of system records.
i. All Agency staff and agents of DOI shall:
- Conduct work in accordance with Federal records management regulations and the Agency's records management policy and procedures.
- Create and manage the records necessary to document their official activities. This includes creating appropriate records documenting meetings, conversations, electronic mail messages, telephone calls and other forms of communication that affect the conduct of official Agency business.
- Only destroy records in accordance with approved records disposition schedules and never remove records from the Agency without authorization.
- File personal papers and nonrecord materials separately from official Agency records.
What does your program do that needs to be documented? What types of records are created in your program? What are your mission critical records? What records document your decisions or are part of the audit trail? Examples might include permit files, project files, reports, publications, time cards, personnel files, contact files, and so on.
Look at each type of record and decide why it is created and maintained. Your program may be required to create and maintain records for a number of valid reasons including program administration, management reporting, statute, federal regulation, Agency policy or procedures.
Reference and personal convenience are valid reasons too. Frequently the only justifications for maintaining files are personal ones such as "I need the records for reference", "Joe wanted me to keep a copy," "somebody may ask for it", and "I don't trust anyone else to keep it." You will find that many of the series on the list for your office are working files, files maintained simply for convenience, or reference materials.
Put those aside for now, and concentrate on the files that directly support the agency mission or administration. These are your "corporate" records. without which your program could not function. They are the ones you need to control.
Identifying the list of corporate or mission critical records is the most important and the most difficult step in the process. It takes a little time, but the benefits are great and it will allow you to manage your information assets much more effectively and efficiently.
A series is the basic unit for organizing and controlling your files. Series are those file units or documents kept together because they relate to a particular subject or function, result from the same activity, document a specific type of transaction, take a particular physical form, or have some other relationship arising out of their creation, receipt, maintenance, or use.
The series concept is a flexible one, and programs should be careful to create series by organizing their documents in ways that facilitate management of the records throughout their life cycle.
Each record series should be located separately from all other records.
Each record series must be covered by a records disposition schedule (see Question 6).
A Records Disposition Schedule (schedule) constitutes the DOI's official policy for records and information retention and disposal. The schedule provides mandatory instructions for what to do with records (and nonrecord materials) no longer needed for current Agency business. Records retention and disposal should occur at regular intervals in the normal course of business of the Agency.
Other benefits of using the DOI Record Disposition Schedules are:
- Ensures that the important records are organized and maintained in such a way as to be easily retrieved and identifiable as evidence of the programs activities (especially in the event of an audit, a FOIA request or a discovery for a lawsuit).
- Conserves office space and equipment by using filing cabinets to house only active records.
- Saves money by the regular transfer of inactive files to less costly Federal Record Center (FRC) storage areas for subsequent disposition.
- Helps preserve those records that are valuable for historical or research purposes.
- Stabilizes the growth of records in offices through systematic disposition of unneeded records.
Based on careful analysis of the Agency's documentary materials, the schedules provide instructions for the retention and disposition of each record series or system and of nonrecord materials, and authorizes the systematic removal of unneeded records from offices.
10 COMMANDMENTS OF RECORDS MANAGEMENT
Records management responsibilities, as defined in statutes, regulations, and Agency policy, can be distilled down to the following ten tasks. The Agency, its Program Offices, Staff, and Agents must:
- Identify the functions and activities for which each program is responsible and determine what records are needed to document those activities and functions.
- Create sufficient records to document those activities and functions.
- Maintain those records in a way that allows all persons who need access to find and retrieve what they need.
- Remove or destroy records only with authorization; don't retain records authorized for destruction.
- Keep official records separate from non-record materials.
- Make someone responsible for the records program.
- Transfer records identified as permanent to the National Archives as required.
- Protect vital records appropriate to their value.
- Protect records that contain security classified, confidential business, or other types of sensitive information with appropriate safeguards.
- Do all of this in a manner that is as cost effective as possible.
This is all we "have to do" in records management.
Everything else is either:
Definition of terms Procedures for consistently carrying out those ten steps Sample best practices (don't reinvent the wheel).
The purpose of the 10 commandments exercise is to focus on what is really important and to simplify the message. Records management is an important management concept. It can be distilled down to a few basic ideas, but like any other resources management, there is regular repetitive work that has to be done, just as we need regular property inventories, regular employee evaluations, and regular financial accounting.
10 EASY WAYS TO IMPROVE RECORDS MANAGEMENT
Good records management can save:
Time Money Space
It isn't complicated -
Here are 10 easy things you can do to implement an effective records management program:
- Identify what documentation needs to be kept for each function you perform.
- Designate a record copy of each document, deliverable, product, or other record and keep it in an official file.
- Make someone responsible for the official file and put that responsibility in his or her performance standards.
- File records according to the Agency file plan.
- Break your files at the end of each year and start new files.
- File reference materials separately from official records.
- File on a regular basis.
- Hold records clean-up days at least once a year.
- Retire inactive records to off-site storage.
- Maintain an inventory of what records you have and where they are located.