Compliance makes a poor, if obvious, cudgel

Information Week published an article at the end of May on the federal government’s efforts to meet the 2012 Managing Government Records Directive regarding the management of records in electronic form. One quotation, from the Nuclear Regulatory Commission’s Deborah Armentrout discussing calls to justify the expense of an electronic records management program caught my eye.

“‘So I say it’s not about compliance. Let’s talk about the fact that the staff needs mission-related records [note: it is the word missions that make me relieved I don’t work for the Nuclear Regulatory Commission], quick access to the correct records anytime, anywhere in order to complete mission-related tasks.’”

What struck me about Armentrout’s point should be obvious to archivists and records managers, but perhaps not to other stakeholders in a strong records management program. I recall, as a library school student (which was not so long ago, although it feels that way), thinking why can’t records managers just use the compliance with the law and the threat of legal action as a cudgel to bend people to their will? And of course the answer is, because even if decision makers in an organization take the concept of compliance seriously, they could easily take any of a number of nominal actions—throw a blanket retention period on general types of records, invest in an expensive EDRMS, pay a consultant for a brief period of time, etc.—actions that show they’ve taken steps but not solved any of the underlying issues.

I think the above is an all too common occurrence. I’m familiar with more than one institution that blanket put a seven year retention period on all financial records, despite the fact that, like other record types, not all financial records are the same. Like many things in life, the path that seems most obvious at first is very possibly not the best. Armentrout sells her records management program on based on the necessity staff have to find information with efficiency. An institution of higher learning may opt to go for an argument that accentuates upholding the tradition of the institution and its history. A small to mid-size business might go for an argument that compares the cost of a records management program to the cost of storing every piece of paper and every byte that enters the domain of the business on the off chance that it will be useful one day. Different tacts are appropriate for different stakeholders. The point is, there are many arguments to engage stakeholders, and a smart records manager or archivist will find the one best suited to their organization and pursue it doggedly.

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