By Priscilla Emery
Ed.'s Note: This article is excerpted from the Records Management Report, published by CMS Watch.
To some, managing records represents one of the most boring and onerous business
functions that anyone could possibly undertake within an organization. Of course,
most people don’t even understand what records management is -- making it
easy to malign an activity that is so misunderstood.
Indeed records management crosses numerous disciplines. Did you know…
- That categorization and indexing are two elements that are critical to
the success of a records management program? Sounds a little like knowledge
management.
- That vital records preservation is one of the key steps in developing a
disaster recovery plan? Sounds like infrastructure management.
- That by ignoring records management policies employees and their companies
can potentially end up facing criminal penalties? Sounds like a legal profession.
- What led to Arthur Andersen’s downfall? Shredding — inappropriate
shredding — shredding of records that should have been retained according
to the policies of both Andersen and Enron.
Despite what people may say, what you don’t know can hurt you and, in the
case of records management, what you choose to ignore can cripple you and your
organization.
Recent dramatic headlines have made it quite apparent that records management
(or the lack thereof) is an essential activity to ascertain and confirm the
credibility of many business transactions and government activities. The proliferation
of electronic documents (especially e-mails) and the potential litigation exposure
that they cause are becoming the bane of legal advisors and records managers
in many corporations and government agencies. Microsoft, Texaco and other Fortune
500 companies have taken hits from “runaway” e-mails introduced
as evidence in high stakes cases.
But, to records managers e-mail is just another record type in the scheme
of things (not a trivial record type but a record type just the same). They
know that in fact, “smoking guns” can come in many different guises,
including: paper, electronic image files, video tape, voice recordings, etc.
It’s all potential evidence and therefore potential deposition fodder.
Making sure that all the relevant information is accessible in a timely fashion,
should an organization need to defend itself in a lawsuit, is also what records
managers are responsible for.
These days a records manager’s job is anything but boring, and in many
organizations there aren’t enough of them to handle the increased compliance
laws and regulations that have cropped up in recent months.
Not surprisingly, then, many companies are looking at records management software
as a way to get a better grip on the increased volume of all kinds of records.
Although that approach can help, a basic understanding of what records management
is and its concomitant practices are required before even looking at any software
product. If you don’t have a records management policy in place along
with the appropriate retention and destruction rules for the records, the software
will be useless.
What is Records Management?
There are many different definitions of records management but one that I
like the best is,
“A professional discipline that is primarily concerned with the management
of document-based information systems. The application of systematic and scientific
controls to recorded information required in the operation of an organization’s
business. The systematic control of all organizational records during the
various stages of their life cycle: from their creation or receipt, through
their processing, distribution, maintenance and use, to their ultimate disposition.
The purpose of records management is to promote economies and efficiencies
in recordkeeping, to assure that useless records are systematically destroyed
while valuable information is protected and maintained in a manner that facilitates
its access and use.”
Some people have the mistaken impression that records management is about hoarding
everything that comes across one’s desk in the course of doing business.
In some highly regulated industries it may seem that is the case. But in most
cases it’s not only making sure that what needs to be kept as a record is
retained but also prescribing how long it should be kept, where it should be stored,
who has access to it and when it should be destroyed (if ever).
There is even an ISO standard for developing a records management program
(
ISO 15489). However, even though records retention practices are considered
systematic and scientific, deciding what is a record and how long it should
be retained is a combination of both prescribed practice and a certain amount
of subjectivity depending on the actual documents in question. Just defining
what is a record can get somewhat confusing to people.
What is a Record?
According to the
Federal
Records Act a record is, “recorded information, regardless of medium
or characteristics, made or received by an organization that is evidence of
its operations and has value requiring its retention for a specific period of
time.”
According to the National Archives and Records Administration (NARA)
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 U. S. 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 of the data in them.”
Got it?
This can be confusing for non-governmental organizations that don’t
believe that these definitions necessarily apply to them so a more generic definition
would be that records are recorded information, regardless of physical form,
that are generated or received and used while conducting business, and preserved
because of their informational value or as evidence of an organization’s
functions, policies, decisions, procedures, operations, mission, programs, projects,
and activities.
This is why there is no real cookie-cutter approach to defining a records
retention program for every document out there — every company has to
look at its own business operations and examine what should be considered a
record and then decide what retention rules to apply against them. Again, the
government and other industry regulators may help in that decision by defining
exactly what they expect to see if they have to do an audit or investigation,
but audits and investigations aren’t the only reasons to have a records
management program.
There are other ways to determine if an information item should be considered
a record or not:
- Does the information document your daily business process?
- Does the information provide input to a mission-critical business decision?
- Does the information provide evidence as to whcy a business decision was
made?
- Is the information required for legal, fiscal, audit, or tax purposes?
"Vital Records" contain unique or irreplaceable information and
require special protection, such as articles of incorporation, annual reports
and shareholder records. These should be defined as an integral part of a disaster
recovery plan or operation.
RM Programs, RM Software
Essential elements of a records management program include a records retention
policy and a set of procedures where records are classified, retention periods
are defined and destruction procedures are prescribed. Classification of records
and then maintaining them with the appropriate metadata are necessary so that
this information can be retrieved quickly when required.
Record integrity depends on three attributes: content, context, and the structure
of the original record. Authenticity is very important to determining if a piece
of information is the “true” record of an event or business transaction,
which is why the management of electronic records, most especially e-mails, web
pages and instant messages, is so problematic. The ability to generate larger
volumes of records in a shorter period of time has increased the productivity
of many organizations but that productivity gain can be lost if essential records
can’t be found during the course of doing business or, in even more critical
procedures such as when an audit takes place or a legal discovery of evidence
is required. Finding lost records costs money in terms of lost productivity and
in more the substantial costs of fines, court costs and lawsuit settlement costs.
Hence the need for records management software that aid in the record repository
management activities of many organizations. These products help users:
- manage retention schedules,
- store records in their appropriate classifications along with the prescribed
metadata,
- search for records when required,
- destroy records according to prescribed schedules,
- put holds on records so they don’t get destroyed while the company
goes through an audit or investigation, and
- track the access of the record over its active and in-active life cycle.
In many cases these systems track not only electronic documents but also other
record objects such as paper, boxes and tapes...
Amid all the focus on key records management features such as record declaration and
standards certification, one key factor sometimes gets lost in the shuffle. Records
management is a core activity within many different business processes within the
organization itself. It is in and of itself not meant to be the core application. Just like filing is
an adjunct activity to one's work, records management must fit into the core business process
in order to be truly effective.
Therefore, technological elegance shouldn't be the focus -- integration with core business
processes is more important. Ability to support and integrate with key business applications
and be imbedded as an activity within a workflow should become more important evaluation
criteria in the long run.