Scheduling the Ephemeral: Creating and Implementing Records Management Policy for Social Media
Bethany Cron, “Creating Records Management Policy and Guidance for Federal Government Agencies”
Kristen Albrittain, “Implementing Agency-wide Social Media Records Management Across 100+ Enterprise Accounts”
Laura Larrimore, “Communications and Content Creator Perspective on Social Media Records Management”
Link to the PowerPoint presentation with presenters’ notes here.
- Do not delete content from live sites.
- If you do have to delete content, have a documented process in place.
- Have (and share publicly) a Comments Policy.
Beth, Kristen, and Laura presented a program in which they each brought their unique perspective to the management of social media as records within the Federal Government. By doing so, they effectively demonstrated how vital cross-team collaboration really is, and how clear policy informs good practice.
I’d like to begin the session recap by focusing on Laura’s presentation, as hers is a perspective many archivists and records managers may not have heard before.
Communications and Content Creator Perspective on Social Media Records Management
Laura is a social media person who creates content. She shared insight into her daily workflow, which is running agency social media accounts such as @USPTO and @CommerceGov, as well as the accounts of individual leaders, such as the Secretary of Commerce. Laura works closely with leadership in communicating their priorities as heads of the agency and the agency’s priorities. She also works with leaders to assess how the public received the content sent out, and what the leaders might want to say next.
A week before the 2016 election, Laura was brought in on a 6-month detail to the Secretary of Commerce’s office to help with the presidential transition, focusing on website and social media. Like many other cabinet leaders, the secretary had a named account in addition to the agency accounts. One of her main tasks was to retire the outgoing Secretary of Commerce’s presences, and stand up the presence for the incoming Secretary of Commerce.
There was no precedent for this. This was the first presidential transition in the social media age. So, she collaborated with other staff to do what they could with what they had.
The transition team looked at how the Department of Commerce (DOC) had handled changes to the website, and adapted that model to fit their needs. DOC had a history of taking a screenshot of the site right before it changes in a major way and then making it available as an online searchable archive. They do this with various redesigns and when a new Secretary is confirmed. This allowed DOC to make changes to the website, but direct the public to old content in as close to its original state as possible.
The Secretary of Commerce’s official government account used her real name as her Twitter handle when it was set up.
You should always ID the leader’s position in the handle, so that it is clear the account is a function of their position. By doing this, the leader can keep their name for personal use, and so that it is intuitive that when the person’s time in that role ends, so does the use of their official government account. Laura likened handles to a company car – it helps you do company business, but once you leave the company, you do not get to keep using the car.
Since the team had this naming issue, they had to work with Twitter to move the followers and content to a new account. In doing so, they would be able to release the @PennyPritzker handle back to former Secretary Penny Pritzker.
The team indicated on the @SecPritzker that is was an archived account and inactive.
Snapshots are good, but they won’t capture deleted tweets. Another day-to-day aspect of records management is having a protocol for if, when and how you might delete tweets. It makes sense to determine if your agency would ever delete anything, for what reasons, and develop a protocol for this prior to such time as you actually need it. For example:
- Take a screenshot of the error tweet
- Save it in the ‘deleted tweets’ folder
- Write up why it was deleted and how to improve/avoid the issue in future
- Email screenshot and description to leadership
- The social media people and records people need to communicate and have a plan BEFORE a big change occurs.
- The idea of dealing with records can be more intimidating than actually doing it.
Creating Records Management Policy and Guidance for Federal Government Agencies
During her presentation, Beth talked about NARA’s high-level requirements and best practices for capturing records created when Federal agencies use social media. This guidance utilizes principles that can be adopted by a variety of institutions, not just Federal agencies.
NARA’s policies are social media include:
- NARA Bulletin 2015-02: Guidance on managing electronic messages
- NARA Bulletin 2014-02: Guidance on managing social media records
- Best Practices for Social Media White Paper
- Recent Records Express post on social media and electronic records
Beth identified not a few substantial challenges in managing social media as records.
While one can consult the Federal definition of records as defined in the Federal Records Act (44 U.S.C. 3301), some questions to ask yourself include:
- Does it contain evidence of an agency’s policies, business, or mission?
- Is the information only available on the social media site?
- Does the agency use the tool to convey official agency information?
- Is there a business need for the information?
If you have answered yes to any of these questions, then there is a chance that these records meet the definition of Federal records. However, are comments part of the official record? Should they be?
Social media posts are ephemeral in nature may not hold ephemeral value. Due to how quickly the social media environment shifts, the process of appraising, capturing, and bringing social media under intellectual control is incredibly challenging.
Where is the social media post of record located? Who owns that post? While a copy can be found on the platform it was distributed through, but perhaps there is a screenshot of the post saved on an office shared drive somewhere. Perhaps an automated tool is capturing the posts. Since there are so many copies….
…scheduling social media through either a general records schedule or a programmatic schedule is needed.
Negotiating public expectations
Since social media is considered a public space, there is an expectation that all posts will remain public and available, preferably in its native format, including any content that has been deleted or altered in some way.
The Federal Electronic Records Modernization Initiative complements NARA Bulletin 14-2.
Implementing Agency-wide Social Media Records Management Across 100+ Enterprise Accounts
Currently, social media is unscheduled, so NARA has been treating everything as if it’s permanent. Staff spend a great deal of time evaluating social media platforms to determine whether posts are original, substantive content or are mainly being used to point followers to more substantial content. Staff also evaluate how content users are using the platform – appraisal is not only about what is being communicated, but also a question of who and why.
NARA’s Corporate Records Management team ultimately decided to take a Capstone approach, designating records as either permanent or temporary based on the content owner. They focus their energy on original content created by senior executives (or their representatives) in the course of their work.
nota bene Content created by all other offices is temporary. Kristen emphatically stressed the following: disposition dictates that COPIES of the content should be deleted/destroyed after three (3) years. Copies, not the original social media post, which in this case is considered the non-recordkeeping copy. DO NOT DELETE YOUR LIVE SOCIAL MEDIA POSTS.
Market Research Lessons Learned
In September 2017, a one-year subscription to the social media records management tool, PageFreezer, was purchased. PageFreezer maintains a record of all NARA-created content on Facebook, Twitter, Instagram, YouTube, Tumblr, and WordPress blog channels, as well as user-generated content posted to NARA-owned pages. At the moment it’s capturing 122 separate channels across those six platforms. The system works by connecting with the platform APIs and capturing data as often as each tool allows, which means it’s as close to real-time as possible.
Authenticity, Integrity, and Completeness
One of the key benefits that an automatic capture tool like PageFreezer has over previous manual approaches is that it can ensure the authenticity, integrity, and completeness of the records.
PageFreezer preserves original content, including responses, with its original look and feel.
Benefits for FOIA and E-Discovery
PageFreezer’s digital signatures, history audits, and complete metadata satisfy Open Records requirements such as FOIA, ensuring that records meet legal requirements for e-discovery.