A Record Center is Not an Archives: Some thoughts from an interview

So, some context: one of my employees (I won’t name her here unless she sees this and asks me to) is currently pursuing her MLIS from SJSU. A recent assignment for one of her classes was to interview a practicing Archivist and/or Records Manager about the “qualified practices” of the profession and write up a paper/presentation/something else summarizing and analyzing it. Did she happen to know anyone like that in her immediate circle? As it happens, she did!

I think a lot of professionals on the archives/RM border have done these interviews, because we are still (somehow) an anomaly to MLS/MIS graduate students. Which, fair enough! I didn’t really even realize records management was a thing until I was already in the program. So some of the questions she asked me were pretty bog-standard… but then some of them were very insightful, particularly asking me to talk about the intersections and differences between the Archives and Records Management professions. Because of the vagaries of our schedules, she asked me to write the answers to the questions rather than conducting an interview per se… So, having written those, I said to myself, “I bet I could repurpose these somehow.” And so, following her permission now that she’s submitted these for credit, I have! Below the jump, a selection of her questions and my answers (lightly edited for the purposes of this blog). In addition to the discussion of intersections, there’s some hints at what I am trying to do to improve the archival component of the City’s records program (to be elaborated on further in a later blog post).

Am I blowing smoke about how the professions fit together? Do you disagree with my assessment of how the profession is changing? Let me know on Twitter or in the comments!

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A Records Center is not an Archives: Transfer Forms!

[Note: This was a forum post to the Records Management Section list on SAA’s site that got a little out of hand. Rather than clog everyone’s mailbox, I decided to post it here. The fact that I can add Futurama GIFs to posts here, and not on SAA Connect, had absolutely nothing to do with this decision (he said, unconvincingly.)

For your reference, the original question:]

I’m interested in ANY AND ALL advice you’ll give me on forms and procedure for transferring records to a Record Center.

Our Records Center is revising the information that we ask for from our departments when they transfer records to us for storage, scanning, and/or destruction. I’m interested in seeing your version of a Records Center transfer form.

Do you ask for information at the box level, file level, or both? Do you require a full inventory of each box transferred? Why or why not?

With complex records policies, I’m concerned about overwhelming our customers with another complex form. What methods have you used to educate your users on how to transfer records to your facility? 

Thanks for your help!

Holly

Upcoming Hangout: Institutional Placement Survey — Records Management and Archival Services

Mark your calendars for the next Records Management Section Google Hangout!

On Monday, December 4 at noon Eastern, the Records Management Section will be hosting a hangout with Jackie Esposito from Penn State University. She will be talking about the report on her Institutional Placement Survey — Records Management and Archival Services.

Institutional archives and records management programs provide such a wide variety of services that institutions often “struggle to fit” them within administrative offices.

From July to December 2016, Jackie conducted a study on where records management and archival services are located within universities. She developed an online survey and visited all fifteen Big Ten Academic Alliance universities for on-site interviews with a variety of stakeholders. They discussed the needs, issues, successes, and failures for different models of placement.

Review the report and be sure to tune in live to ask questions or watch later at your convenience. You can view the Hangout here.

We will be accepting questions for our speaker from you. If you have a question or topic for discussion please leave it as a comment here or use the #saarms hashtag on Twitter.  We will also monitor the comments on the YouTube live streaming page.

 

Transparency and its Discontents

The denizens of Twitter like to dump on Matt Yglesias, blogger and executive editor at Vox.com, but said dumping is not always warranted. Tendencies to oversimplify and be contrarian for the sake of it aside, he does write not a few pieces that do provide some good insight into the political environment. His latest piece, “Against Transparency”, ain’t one of those, however:

Treating email as public by default rather than private like phone calls does not serve the public interest. Rather than public servants communicating with the best tool available for communication purposes, they’re communicating with an arbitrary legal distinction in mind.

[…]

Government secrecy can be, and in some ways is, out of control. But a private conversation to facilitate a frank exchange of ideas is not the same as a secret bombing campaign in Cambodia. We need to let public officials talk to each other — and to their professional contacts outside the government — in ways that are both honest and technologically modern.

God bless the internet.

As Eira Tansey, who graciously looked this post over for me (Thanks Eira!), points out, this is just the latest in a subtle, but real, trend among contrarian-type thinkpiece authors, in which  the era of open government is lamented as impeding government from functioning properly. (See this recent article in The Atlantic for another example of this genre; mourning the demise of party machines is a nice touch.) This one, however, hits a bit more home, for obvious reasons. For more explication of why this article raises my records management hackles, follow me past the jump.

Retention schedules and research records: Necessary challenges

This post is the second in a series on research data management presented by the Records Management Roundtable. 

Submitted on behalf of Anita Vannucci, Records Manager at Emory University.

In the fall of 2015, I began a review and update to the research data portion of my institution’s retention schedule. The catalyst for this work came from a campus task force looking at the evolution of research data at academic institutions and anticipating increased interest following the February 2013 White House Office of Science and Technology Policy memo. One recommendation the task force made was to revise the retention schedule.

The 30 series retention schedule was last updated in 2008, long before my arrival. Several challenges became clear when I started my review. Some series were based on federal statutes that had been repealed, or cited code that had no clear connection to the series. Some “series” were actually record types. For clinical records, a records series existed for each stage of research (Phase I, Phase II, Phase III, Phase IV) rather than a single series based on the point the research closed.

I began researching federal and state code, best practices, and the policies of peer institutions. Federal guidance varied from agency to agency, so many of the institutions I surveyed relied on contract language, rather than a centralized retention schedule, to set requirements.

Another challenge was identifying a focus group of subject matter experts. In fiscal year 2015, my institution received 2,923 sponsored awards. While I spoke to people doing research and managing the information created from it, it was impossible to get a representative sample, so I chose to talk to their central monitoring department, the Office of Compliance. It was Compliance who helped me solidify the information I’d gathered into concrete series based on four types of research: behavioral, treatment, FDA-regulated, and non-FDA regulated. Unfortunately, the retention requirements aren’t as straight forward as that finite group of series would lead you to believe.

I began meeting monthly with the deputy chief compliance officer, working through my draft of the schedule. He provided feedback and insight along the way, while I learned about everything from the differences between dangerous drugs and controlled substances to retention requirements around sealed versus non-sealed sponsored study contracts. In the process, we tackled two major challenges:

1. Can we create big buckets? Risk analysis is a big part of creating a big bucket schedule. We discussed when keeping information longer than required through a simplified schedule posed a greater risk than the value gained by making the schedule easier to use. For example, alleged misconduct investigations involving federally-funded research must be retained for seven years. There’s more flexibility around privately funded research, so in instances where a complaint is determined to be unfounded, there was a desire to dispose of the information sooner. By keeping misconduct investigations of privately-funded research according to the federally-funded requirements, we’d lose the ability to destroy unfounded complaints and retain spurious or potentially libelous information longer than necessary. We decided to settle this issue on a series-by-series basis after considering the volume of records involved and potential risk for each series.
2. How simple can we make the retention requirement? Retention periods set out in code are rarely simple. (Take a look at 21 CFR 58.195 if you don’t believe me.) We discussed the value of using those retention periods word-for-word versus simplifying and risking the loss of nuances. In this instance, making the schedule user friendly won out. We decided to simplify the language but also link to each citation.

The schedule isn’t quite done yet, but it will be ready to go in time for the launch of a new fiscal year and a new round of awards.

Anita Vannucci

Records Manager

Emory University

Research data management and University records management: Collaborative crossroads

This post is the first in a series on research data management presented by the Records Management Roundtable. 

One service area of the University Library System (ULS) I was not initially expecting to become involved with when I became University Records Manager at the University of Pittsburgh was research data management (RDM). However, my participation with a ULS specialist track focused on RDM quickly made it clear that this domain is one that records managers throughout higher education should be tuned into.

Research records and data output from various projects, studies, and trials are both created and managed by departments and disciplines across Universities in huge quantities. While RDM may conjure visions of statistical tables, sprawling spreadsheets, and raw computational models, research output is more often a hybrid of record types. Lab notebooks, clinical information and waivers, computational displays, large data sets, XML exports, artifacts, audio-visual materials, proprietary software output, field notes, and grant and administrative materials vary by discipline and format. Thus, records management is a clear fit with other RDM pursuits.

The ULS “tracks”, or groups of specialists, are charged with specific areas of responsibility, such as instructional design or scholarly communications. The ULS’s RDM track evolved out of a working group and over the past year began forming a three-tiered service delivery model for providing RDM resources and outreach to the University research community. Consisting of digital scholarship specialists, a metadata librarian, an archivist, several liaison librarians, and myself, the RDM track’s goal is to provide guidance, resources, and instruction to researchers on how to best manage their records and data throughout the research lifecycle.

The RDM track has tailored resources surrounding some of the following topics: how to create a data management plan using DMPTool; understanding funder mandates; describing your data; choosing sustainable formats; locating data and disciplinary repositories; and open data sharing. Discussion is often framed by communicating the importance of RDM in terms of time, resources, funding agency and publisher mandates, and research integrity.

Service and outreach are conveyed through resources including a Libguide, website, and FAQS which outline service topics; consultations with faculty to better understand their needs; training sessions for ULS staff, academic departments, and research groups; advertisements throughout campus to promote said services; and a series of instructional modules focused on a specific facet of RDM, such as research records and data retention, freely available on the ULS RDM Libguide.

My involvement with the RDM track has raised important questions: where do research records and data management fit into a higher education RM program? Certainly records management principles and policies apply to research records and data. Although somewhat dated, Pitt maintains a Guidelines for Managing Research Data policy on record, in addition to general and financial retention schedules that loosely address such record types.  Furthermore, as a “state-related” University, most research conducted at the University is not subject to state or federal open record laws.

The question of just how effective records management outreach to the research community can be arises. Departments, research groups, and principle investigators often keep their research output close to the chest (read: attribution), storing it on personal websites, databases, external hard drives, or in departmental or personal storage. Management issues, migration and preservation challenges, and open data conundrums crop up. Additionally, the adoption of enterprise software like Electronic Lab Notebooks only increase issues of ownership, management, and preservation of University research content.

Researchers are advised to consider records management at all stages of the research lifecycle:

• What types and formats of research records will be created?
• How, and who, will manage those records throughout the course of the project?
• Is electronic research output being generated in proprietary systems?
• How can this data be migrated?
• What are the applicable research records retention periods?
• What University records retention policies should I be aware of?
• Where will I deposit research records following the end of my study?
• How will I preserve these records over time?

The RDM track’s mission provides the perfect platform for spotlighting how records management practices can and should positively support research data management in the research community at Pitt. As the RDM track moves forward with faculty consultations this summer, I’m interested to learn the ways (and formats) in which researchers are creating records, where they are being stored, what oversight and policies are governing their work, and how they perceive University records management affecting their workflows.

I’ll be working to determine the volume of research records – along with type and importance –that departments and research teams store at the University’s off-site storage vendor, examining how and when content should be exported from ELN’s and deposited or stored elsewhere, and potentially attempting to embed myself with a research group for a term to understand their methods, workflows, and records management considerations.

Records managers in higher education should definitely be engaged with the research community at their respective institutions. However, with limited time and resources (there is one of me!), it’s often difficult to consistently and successfully engage stakeholders. Finding collaborative commonalities with other service providers and information professionals, like the RDM track, is one way to make a records management program more visible to the research community.

Alex J. Toner

University Records Manager

University of Pittsburgh

Records Managers: Not Making This Stuff Up, Part the Billionth

So! The Office of the Inspector General released its report on Hillary Clinton’s emails today. Perhaps you’d heard about it.

The report itself is here (Warning: major TL;DR alert). It reads like a litany of “everything that can go wrong with a digital records management program”–poor communication, lack of executive buy-in, technology not up to the job of meeting requirements– and my plan is to break down the whole thing at some point to take a closer look at what happened from a purely records management standpoint. But in light of Eira’s excellent post on institutional silences and the digital dark ages, I wanted to quickly hit one paragraph that jumped out at me:

Two staff in S/ES-IRM reported to OIG that, in late 2010, they each discussed their concerns about Secretary Clinton’s use of a personal email account in separate meetings with the then-Director of S/ES-IRM. In one meeting, one staff member raised concerns that information sent and received on Secretary Clinton’s account could contain Federal records that needed to be preserved in order to satisfy Federal recordkeeping requirements. According to the staff member, the Director stated that the Secretary’s personal system had been reviewed and approved by Department legal staff and that the matter was not to be discussed any further. As previously noted, OIG found no evidence that staff in the Office of the Legal Adviser reviewed or approved Secretary Clinton’s personal system. According to the other S/ES-IRM staff member who raised concerns about the server, the Director stated that the mission of S/ES-IRM is to support the Secretary and instructed the staff never to speak of the Secretary’s personal email system again.

Holy moly. I am simultaneously astonished and not at all surprised that this conversation happened. Without attempting to divine the source of this supposed gag order or the motivation behind it, there is at minimum a failure to communicate happening here, and in all likelihood a deeply ingrained culture of subordination. Two employees, rightly concerned that use of a personal email account posed a recordkeeping and security risk, were specifically told that they were there “to support the Secretary”, and as a result questioning her use of personal email was anathema. That is really an incredible directive, if substantiated. I would argue that pointing out vulnerabilities in information security and governance IS supporting the Secretary (by, say, helping her avoid a prolonged investigation into her email management practices during an election year), but that’s just me.

And yet… what do you even DO in this case as a records manager? In a lot of institutions records managers are so far down the totem pole that there’s not a lot of pushing back to be done if a C-level staffer doesn’t want to follow records management directives to the letter. It’s easier to stand up to your negligent or reluctant official if you’re based out of the Legal department (and even easier if you are yourself a lawyer), but for a records manager based out of an administrative department, or the library? How do you make the case for good records practices when you have been explicitly told not to pursue it? How far do you stick your neck out for the sake of the historical record and transparency, vs. the short-term interests of your institution? Particularly if, as in so many cases, the records law which you are following has no real penalty for non-compliance other than the hypothetical/tangential “you might get sued”?

I don’t have an answer to any of the above questions. I’ve struggled with the right level of aggressiveness in pursuing records of high-level officials at my own institution, and have almost certainly lost some key electronic records being kept on a personal hard drive or in an email account because of it. (Elsewhere in the report records staff reports “not feeling comfortable” directing the Secretary to use the internal records system and looking for an automatic system to capture the records; I feel this anxiety acutely.) In this *particular* case Secretary Clinton released (most of) the emails after the fact, so the damage to transparency and the historical record is perhaps not as great as it could have been. In other cases? Who knows what’s being lost because the records manager is not as much in control as he/she would like to be.

These are the kinds of questions that keep me up at night, because I am an enormous nerd and am kept awake by records management questions. (Well, that and a one-year-old baby.)

Save the dates for two upcoming RMRT events!

The Records Management Roundtable (RMRT) is pleased to share with you two upcoming events.

Save the date for the next installment of RMRT’s Virtual Hangout series, airing Wednesday, May 4 at 10:00AM PDT (1:00PM EDT).

Join the project team from ePADD as they talk about their open source and freely downloadable software that harnesses machine learning, including natural language processing and named entity recognition, to support the appraisal, processing, discovery, and delivery of email archives.

Watch the ePADD for Email Archives broadcast live here. We’ll also update the blog with links to the archived YouTube video.

The RMRT Steering Committee is also hosting a webinar with the Sacramento State and San Jose State University SAA student chapters. Eira Tansey, Digital Archivist/Records Manager at the University of Cincinnati, will be talking about support and careers in records management. Eira is also the Student Committee coordinator for the RMRT Steering Committee.

Join the live discussion Sunday, May 1 at 4:00 PM PDT (7:00 PM EDT): https://goo.gl/udrNoe

Listen to the recording: https://goo.gl/yX2CTa

Hope you will be able to tune in!

Documenting Records Destruction in a Decentralized World

Last year, our university implemented a new procedure for documenting in-office records destruction. As the one year benchmark approaches, I have been thinking about our organizational approach to documenting records destruction, especially in a decentralized environment.

Procedures for documenting records destruction may depend on state laws, regulations, and institutional polices. For some organizations, declaring that employees are following records policies, including those requiring records destruction, may be enough to adequately “document” the destruction of records. 

Latest Edition of SAA’s The Records Manager newsletter, Winter 2016 issue is published

Dear RMRT Members:

Here are the Highlights from the Winter 2016 issue of The Records Manager, newsletter of the SAA Records Management Roundtable:

• In the Winter 2016 issue, Bethany Cron talks about the Next Virtual Hangout: Processing Capstone Email Using Predictive Coding on March 3.
• Brad Houston also covers how to  desensationalize Public Records reporting
• Hillary Gatlin reaches out through a Records Management Program.
• A new series about managing Patients’ Health Records is introduced and explained by a Patients’ Health Records Manager.