NATIONAL

ARCHIVES

Preserving Electronic

Records in an Era of

Rapidly Changing

Technology

United States General Accounting Office

GAO Report to the Chairman

Committee on Governmental Affairs

U.S. Senate

July 1999

GAO/GGD-99-94

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1

B-281101

July 19, 1999

The Honorable Fred Thompson

Chairman, Committee on Governmental Affairs

United States Senate

Dear Mr. Chairman:

Under the Federal Records Act, the National Archives and Records

Administration (NARA) is responsible for providing guidance and

assistance to federal agencies on the creation, maintenance, use, and

disposition of government records.1

 Federal agencies are responsible for

ensuring that their records are created and preserved in accordance with

the act. Records generated electronically, such as electronic mail (E-mail)

messages, word processing documents, CD ROMs, and World Wide Web

site pages, present an archival challenge for NARA and agencies because

these technologies are new and changing very rapidly. Also, the sheer

volume of these records is mushrooming.

At your request, we undertook an effort to identify issues that relate to

electronic records management (ERM), focusing specifically on the

preservation of electronic records. On February 4, 1999, we provided your

office with a briefing on our work. As your office agreed, this report

documents our oral briefing and provides additional information on (1) the

challenges that confront NARA and federal agencies as a result of their

increased reliance on electronic media; (2) the status of selected agencies’

and NARA’s implementation of ERM; and (3) the ERM policies and

procedures of selected other governments (state and foreign).

We conducted our work between August 1998 and June 1999 in

accordance with generally accepted government auditing standards.

Appendix I contains a discussion of our scope and methodology. On June

7, 1999, we provided a draft of this report to the Archivist, who heads

NARA, for review and comment. The Archivist’s comments are discussed

at the end of this letter and reprinted in appendix II.

NARA and federal agencies are faced with the substantial challenge of

preserving electronic records in an era of rapidly changing technology. In

addition to handling the burgeoning volume of electronic records, NARA

 

1

44 U.S.C. 2904.

Results in Brief
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and the agencies must address several hardware and software issues to

ensure that electronic records are properly created, permanently

maintained, secured, and retrievable in the future. Also, NARA’s and the

agencies’ ERM efforts are competing with other information technology

priorities, particularly the need to ensure that their computers are Year

2000 compliant.

NARA is responsible for providing guidance and assistance to agencies on

how to maintain their official government records and for archiving those

records once they are transferred to NARA. The agencies are responsible

for ensuring that records are created and preserved in accordance with the

Federal Records Act. No centralized source of information exists to

document the extent to which agencies are fulfilling their ERM

responsibilities under the act. On the basis of our discussions with officials

from NARA and four judgmentally selected agencies,2

 we found that plans

and capabilities for ERM vary greatly across agencies. Some agencies are

waiting for more specific guidance from NARA, while others are moving

forward on their own to implement ERM programs.

NARA has recently postponed a planned baseline survey that was intended

to obtain governmentwide information on agencies’ ERM programs

because NARA believes that it should first complete a business process

reengineering (BPR) effort. This BPR effort, which is intended to assess

and potentially alter NARA’s guidance to and interaction with agencies, is

expected to take 18 to 24 months. We believe that the baseline survey

information is critical to ensuring that the BPR results are relevant to the

current ERM situations at agencies and the survey should not be

postponed. Further, these baseline data are needed to meet one of NARA’s

stated strategic planning goals to “stay abreast of technologies in the

agencies.” We are making a recommendation in this report regarding the

baseline survey.

Even while planning its BPR effort, NARA is taking some immediate action

to address the agencies’ needs for ERM guidance and direction. NARA is

now revising its ERM guidance to address personal computers and the

resulting desktop management of electronic records. NARA’s efforts to

improve ERM include revising bulletins and other guidance as well as

forming a new group to help answer agencies’ immediate questions on

ERM issues. NARA has taken many of its actions as a result of a court

 2

We made limited contacts at the Environmental Protection Agency, the General Services

Administration, the National Aeronautics and Space Administration, and the Department of the

Treasury’s Office of Thrift Supervision.
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decision,3 which held that NARA’s guidance for the deletion of electronic

records exceeded its statutory authority.

The federal government is not alone in its quest to properly preserve and

maintain electronic records. State and foreign governments are addressing

similar challenges.4 From our limited judgmental sample of state and

foreign governments, it is clear that these governments and the federal

government often differ in (1) the organization of their archival activities,

(2) their philosophies on centralization versus decentralization of

recordkeeping responsibilities, and (3) their computer hardware and

software capabilities.

NARA’s mission is to ensure “ready access to essential evidence” for the

public, the President, Congress, and the courts. NARA is to make the

permanently valuable records of the government—in all media—available

for reference and research. In addition to the best known documents, such

as the Declaration of Independence, the Constitution, and the Bill of

Rights, NARA preserves billions of pages of textual documents and

numerous maps, photographs, videos, and computer records.

Each citizen has a right to access the official records of the government.

During fiscal year 1998, 2.6 million people (including genealogists,

historians, librarians, and veterans) visited NARA’s facilities to browse and

do research, and NARA received over 56 million “hits” on its Web site from

scholars, students, and other inquirers.

Records management is a statutory responsibility of the Archivist and

heads of the federal agencies. The Federal Records Act, comprising the

Records Disposal Act and other statutes, defines a record as

“all books, papers, maps, photographs, machine readable materials, or other documentary

materials, regardless of physical form or characteristics, made or received by an

agency...under federal law or in connection with the transaction of public business and

preserved or appropriate for preservation...as evidence of the organization, functions,

policies, decisions, procedures, operations, or other activities of the Government or

because of the informational value of data in them.”5

 

3

Public Citizen v. Carlin, 2 F. Supp. 2d 1 (D.D.C. 1997).

4

We interviewed officials from Florida, Oklahoma, Oregon, and Texas and reviewed public documents

from Australia, Canada, and the United Kingdom.

5

44 U.S.C. 3301.

Background
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NARA and agency staff work together to identify and inventory an agency’s

records to appraise the value of the records and determine how long they

should be kept and under what conditions. The formal approval of this

work is called scheduling. Agency records must be scheduled through

either records schedules specific to each agency or a general records

schedule (GRS), which is issued by the Archivist and authorizes disposal,

after a specified period of time, of records of a specified form or character

common to several or all federal agencies. Records of permanent value

(such as final budget submissions and calendars of senior staff) must be

preserved and eventually transferred to NARA for archival and research

purposes. Other records deemed of insufficient value to warrant their

preservation, such as payroll or travel, are considered temporary records

and must be preserved by the agency for only a specified length of time.

In addition to the Federal Records Act, several other laws, such as the

Paperwork Reduction Act, Privacy Act, Freedom of Information Act,

Electronic Freedom of Information Act, and Government Paperwork

Elimination Act, also address records management requirements for both

paper and electronic records. Also, the General Services Administration,

the Office of Management and Budget, and individual agencies issue

records management regulations.

NARA and federal agencies are confronted with many ERM challenges,

particularly technological issues. NARA must be able to receive electronic

records from agencies, store them, and retrieve them when needed.

Agencies must be able to create electronic records, store them, properly

dispose of them when appropriate, and send permanently valuable

electronic records to NARA for archival storage. All of this must be done

within the context of the rapidly changing technological environment.

As stated in NARA’s 10-year strategic plan covering the period of 1997 to

2007, NARA’s goals are to determine how to (1) preserve electronic

records that the nation will need, (2) manage change, (3) stay abreast of

technologies in federal agencies, and (4) use technologies to safeguard

valuable information and make it more readily accessible. NARA’s plan

also points out that it must meet the public’s need for “on-line” access to

information and work in partnership with other entities that are struggling

with the same problems.

According to our research and discussions with NARA officials and other

records management professionals, NARA is faced with a number of

challenges to ensure that federal records in electronic format are

preserved. NARA officials told us that NARA needs to expand its capacity

NARA and Federal

Agencies Face ERM

Challenges

NARA’s Challenges
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to accept the increasing volume of electronic records from the agencies.

Over the past quarter century, NARA has taken in approximately 90,000

electronic data files. NARA has estimated that federal agencies, such as the

Department of State and the Department of the Treasury, are individually

generating 10 times that many electronic records annually just in E-mail,

many of which may need to be preserved by NARA. One of the items in

NARA’s fiscal year 2000 budget request would allow NARA to begin

development of a system to save large volumes of E-mail messages and

other small data files that agencies are increasingly creating. Some of the

initial research and development for this system is being done in fiscal

year 1999.

In addition to the increasing volume, the increasing variety of electronic

records (e.g., word processing documents, E-mail messages, databases,

digital images, and Web site pages) complicate NARA’s mission to preserve

these records. NARA must address some definitional problems, such as

what is an electronic record, when is an E-mail message a record, or when

are Web site “virtual records” considered records. Also, electronic records

are generated as files that require compatible hardware playback devices

and the correct software for retrieving, viewing, and transmitting. Because

agencies follow no uniform hardware standards, NARA must be capable of

accepting various formats (hardware and software) from the agencies and

maintaining a continued capability to read those records.

The long-term preservation and retention of those electronic records is

also a challenge since providing continued access to archived records over

many generations of systems is difficult. The average life of a typical

software product is 2 to 5 years. There are currently only three alternatives

for maintaining accessibility over time, as follows: (1) maintain records in

a software-independent format, (2) reformat and migrate records to new

software systems, or (3) maintain the records in the original format and

maintain the necessary hardware and software to make them accessible.

Another concern is the deterioration of the storage media over time, and

NARA must consider the permanency of the formats used by agencies

(such as floppy disks and CD ROMs). These and other media that are used

now and that are being developed must remain readable over a long period

of time or be changed to a different media.

Finally, another challenge is NARA’s ability to offer guidance to the

agencies regarding the orderly management of electronic records,

especially relating to the authenticity and reliability of electronic records

that eventually will be transferred into NARA’s custody. Current electronic

security measures, encryption, and authentication techniques could
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increase the reliability and authenticity of electronic records; however,

there has been little analysis of the risk or the costs and benefits of

implementing those measures for agencywide systems. It is important to

note that a properly maintained electronic recordkeeping system provides

more security and accountability than a comparable paper-based system

because the electronic system can record details on access, revision, and

deletion.

Records management is initially the responsibility of the agency staff

member who creates a record, whether the record is paper or electronic.

Preservation of and access to that record then also becomes the

responsibility of agency managers and agency records officers.

Electronic records are now frequently created on a personal computer.

Electronic recordkeeping responsibilities are often overlooked by the staff

member who creates the record. The staff member should be made aware

of what constitutes an electronic record, how to save it, and how to

archive it for future use. Decentralized control over electronic documents

is changing the face of records management because records can easily be

deleted without records managers even being aware that the record

existed. The agencies are challenged with informing employees what is

required of them and how to accomplish their records management

responsibilities.

Agencies receive guidance from NARA, but they must put their own

recordkeeping systems in place. Some agencies continue to experience

confusion over what constitutes an electronic record and who has

responsibility for preserving the record. Questions also arise regarding

how to handle multiple copies or versions of documents and whether

drafts are official records.

Agencies’ employees send and receive huge volumes of E-mail in

performing their official duties and responsibilities. Agencies must

determine which of these E-mail messages are records. When E-mail

messages are determined to be official records, agencies must assign

records management responsibility, control multiple versions, and archive

the messages. Also, because much internal business deliberation is

conducted via E-mail, for privacy reasons, these messages must be

reviewed before being released to the public.

Agencies’ ERM efforts are competing for attention and resources with

other information technology priorities, particularly in those agencies

dealing with the Year 2000 problem. NARA officials believe that ERM

Agencies’ Challenges
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activities may be slowed by agencies’ concentration on other priorities,

such as systems’ upgrades and Year 2000 compliance. Regarding Year 2000

compliance, the old technology that created some electronic records might

not be Year 2000 compliant, and this noncompliance could cause future

retrieval difficulties for the agencies and NARA.

On the basis of our discussions with NARA officials and officials of the

four previously mentioned selected agencies and discussions at

governmentwide conferences on the subject of records management, we

learned that agencies vary in their records management programs and in

their capabilities to implement ERM. Some agencies are waiting for more

specific guidance from NARA, while others are moving forward by looking

for ways to better manage their electronic records.

However, there has been no recent governmentwide survey of agencies’

compliance with the archival provisions of the Federal Records Act or

agencies’ ERM activities. NARA is planning a BPR effort that will collect

limited information from some agencies but will not include a complete

governmentwide baseline survey. In the interim, NARA has begun to revise

its ERM guidance to provide some immediate guidance and direction for

the agencies.

Our discussions with NARA officials and officials from the four

judgmentally selected agencies indicated that agencies vary in how they

are implementing their ERM programs. NARA officials directed us to the

Department of Defense (DOD) as one of the agencies that is most

advanced in its ERM efforts. NARA has been working with DOD for several

years to develop DOD’s ERM software standard,6

 which is intended to help

DOD employees determine what are records and how to properly preserve

them.

NARA endorsed the DOD standard in November 1998 as a tool that other

agencies could use as a model until a final policy is issued by NARA. The

endorsement does not mandate that agencies use the DOD standard;

instead, NARA said that the standard conforms to the requirements of the

Federal Records Act and establishes baseline requirements for managing

electronic records. NARA also said that while the DOD standard is an

appropriate basis for records management, there might be other equally

valid ways to address ERM. The DOD standard is intended as a starting

 6

The DOD standard, Design Criteria Standard for Electronic Records Management Software

Applications, November 1997, was issued under the authority of DOD Directive 5015.2, Department of

Defense Records Management Program, April 11, 1997.

Agencies’ and NARA’s

Actions to Implement

ERM

Agencies Vary in Their

Implementation of ERM
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Page 8

point that must be tailored to a specific agency’s needs. NARA said that

each agency must still address ERM within the context of its own

computer and policy environments. The DOD standard is a tool that is

intended to help agencies develop automated systems to file, track, and

preserve or destroy its electronic records.

DOD’s standard has a series of requirements that are measurable and

testable and based on various laws and NARA regulations. The standard,

which is mandatory for all DOD components, provides implementation and

procedural guidance on the management of records in DOD. ERM

information systems that were in place before the approval of this

standard must comply with the standard by November 1999.

The DOD standard (1) sets forth baseline functional requirements for

records management application software that is used by DOD

components in the implementation of their records management programs;

(2) defines required system interfaces and search criteria to be supported

by records management application software; and (3) describes the

minimum records management requirements that must be met, based on

current NARA regulations. The DOD standard also requires that records

management software perform several functions, including the following:

• Assign each record a unique, computer-generated code that identifies the

document.

• Treat filed E-mail messages, including attachments, as records.

• Allow records to be searched, screened, and viewed on the basis of record

profiles.

• Identify records that can be sent to NARA for storage.

• Notify users when a document is eligible for destruction or transfer, and

destroy or transfer it after approval.

As of June 2, 1999, nine companies had records management application

products that were certified by DOD as meeting its standard. Some

products are ERM software, while others integrate their document

management or workflow products with ERM software from another

vendor.

Two agencies that are testing ERM software that meet the DOD standard

are the National Aeronautics and Space Administration (NASA) and the

Department of the Treasury’s Office of Thrift Supervision (OTS). NASA did

a limited test of an early version of one ERM product and found it difficult

to use and time-consuming to install. The software did not perform well

with NASA’s varying hardware and software platforms. According to an
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agency official, the NASA test did, however, give NASA a better

understanding of its requirements, including its records management

program in particular. NASA plans to evaluate a newer version of this

software later in fiscal year 1999.

OTS is testing ERM software that differs from the one NASA used. OTS’

test is meant primarily to organize its electronic files. According to OTS’

manager of its records branch, it is important that ERM software requires

users to make no more than two or three extra keystrokes, and that users

realize there is a benefit to this additional “burden.”

Even though NARA is aware of the efforts of DOD, NASA, OTS, and

various other agencies, it does not now have governmentwide data on the

records management capabilities and programs of all federal agencies.

NARA had planned to do a baseline assessment survey to collect such data

on all agencies by the end of fiscal year 2000. According to NARA officials,

this survey was needed to identify best practices at agencies and collect

data on (1) program management and records management infrastructure,

(2) guidance and training, (3) scheduling and implementation, and (4)

electronic recordkeeping. NARA had planned to determine how well

agencies were complying with requirements for retention, maintenance,

disposal, retrieval/accessibility, and inventorying of electronic records. In

the early results in the pilot test of the survey at a limited number of

agencies, NARA discovered that most of the pilot agencies lacked adequate

employee guidance regarding electronic records.

The Archivist has decided to put the baseline survey on hold primarily

because of what he believes are other higher priority activities, such as

NARA’s BPR effort, which could change NARA’s regulations and thereby

affect the data that NARA would need to acquire from the agencies.

NARA’s BPR effort to address its internal processes, as well as guidance to

and interactions with the agencies, is expected to begin before the end of

fiscal year 1999. This BPR effort should take 18 to 24 months. However,

NARA will now proceed without the rich baseline of information from

across the federal government that was originally planned.

NARA officials could not give us a time frame regarding when the survey

effort would be reinitiated. In the interim, according to a NARA Policy and

Communications official, NARA will continue to gather additional

information about the status of records management through a targeted

assistance program, which will focus on helping agencies that have the

most urgent records management needs. This effort, by definition, will not

provide a baseline across all agencies.

NARA Does Not Have

Governmentwide Data on

Agencies’ ERM Efforts
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Currently, NARA does in-depth studies of two to four agencies a year in

which it looks at the agencies’ records management policies and then

recommends areas for improvement. Since some individual agencies have

not been reviewed for several years, this method of collecting information

on agencies has not yielded a current governmentwide look at the

situation. Thus, this effort does not achieve NARA’s strategic planning goal

to “stay abreast of technologies in the agencies.”

Historically, NARA’s ERM guidance has been geared toward mainframes

and databases, not personal computers. In addition to NARA’s planned

BPR, NARA is taking some immediate action to revise its guidance to be

more appropriate in today’s workplace environment.

NARA’s electronic records guidance to agencies is found in the Code of

Federal Regulations,7 which establishes the basic requirements for

creation, maintenance, use, and disposition of electronic records. In 1972,

before the widespread use of personal computers in the government

workplace, NARA issued GRS 20 to provide guidance on the preservation

of electronic records. However, agency records officers, data processing

staff, and even NARA staff had trouble understanding and applying the

first version of GRS 20. Subsequently, GRS 20 had several major revisions,

culminating with the 1995 revision authorizing, among other things, that

after electronic records, which were created in an office automation

environment or computer centers, were placed in a recordkeeping

system—electronic, paper, or microfilm—the records could be deleted.

NARA’s ERM guidance under the 1995 version of GRS 20 was challenged in

a December 1996 lawsuit filed in the United States District Court for the

District of Columbia by a public interest group.8

 In an October 1997

decision, the court found that the Archivist exceeded the scope of his

statutory authority in promulgating GRS 20. First, the court stated that

GRS 20 did not differentiate between program records, which are possibly

subject to preservation, and administrative “housekeeping” records, which

the court found were the only records allowed to be disposed of through

GRSs. Second, the court found that electronic records did not lose their

status as program records once they were preserved on paper; they are

considered to be unique records and distinct from printed versions of the

same record.

 

7

36 CFR Part 1234.

8

Public Citizen v. Carlin, 2 F. Supp. 2d 1 (D.D.C. 1997).

NARA Is Revising Its ERM

Guidance
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The court also held that by categorically determining that no electronic

records have value, the Archivist failed to carry out his statutory duty to

evaluate the value of records for disposal. Moreover, the court determined

that GRS 20 violated the Records Disposal Act because it failed to specify a

period of time for retention of records that are to be disposed of through a

GRS. The court thus declared GRS 20 “null and void.” The government

filed an appeal of this ruling in December 1997. In March 1998, NARA

issued a bulletin informing agencies that NARA had established a working

group with a specific time frame to propose alternatives to GRS 20.

The same public interest group that initially challenged GRS 20 went back

to court when it realized that the Archivist was informing agencies that

they could continue to rely on GRS 20 even after the court had ruled it

“null and void.” The court, in a subsequent ruling, found that the Archivist

had “flagrantly violated” the court’s October 1997 order and ordered,

among other things, the NARA working group to have an implementation

plan to the Archivist by September 30, 1998.

In September 1998, on the basis of recommendations made by the NARAsponsored electronic records working group, the Archivist decided to take

several steps. Specifically, the Archivist agreed to (1) issue a NARA

bulletin to give guidance to agencies on how to schedule the retention of

program and unique administrative records in all formats; (2) modify other

GRSs to authorize the deletion of electronic source records for

administrative records after a recordkeeping copy has been produced; (3)

publish guidance on a new GRS for information technology records in the

Federal Register by March 15, 1999; and (4) form a follow-on group by

January 1999 to continue work on electronic recordkeeping guidance

issues.

On September 29, 1998, after the Archivist notified the court of NARA’s

intended actions, the court ordered that the Archivist was authorized to

state that agencies could continue to follow current disposition practices

for electronic records until they receive other disposition schedule

approval from NARA, notification by NARA that the government’s appeal

has been resolved and NARA has provided further guidance as a result of

the appellate court’s decision, or further order of the court. In response to

the court’s ruling, as of May 1999, NARA had taken the following actions:

• Issued NARA Bulletin 99-04 on March 25, 1999, to guide agencies on

scheduling how long to keep electronic records of their program activities

and certain administrative functions formerly covered under GRS 20.

Agencies have until February 1, 2000, to submit to NARA either new
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records schedules for their electronic copies or a detailed plan for

scheduling the records. Agencies that submit a plan must commit to

scheduling their electronic copies within 2 years, unless NARA approves a

different time frame. NARA is also offering no-cost training to agency

records officers to assist in developing schedules or plans.

• Issued a revision in the general records schedules on December 21, 1998,

to authorize agencies’ disposal of certain administrative records (such as

personnel, travel, and procurement) regardless of physical format, after

creating an official recordkeeping copy.

• Drafted a new general records schedule for certain administrative records

to document the management of information technology. NARA has

received comments from agencies on this draft, has made revisions, and

will send the draft out for agencies’ comments again. NARA plans to

incorporate the agencies’ comments and send the draft to OMB for

comment.

• Initiated a follow-on study group in January 1999—Fast Track Guidance

Development Project (FastTrack)—intended to answer the immediate

questions of agencies about ERM. FastTrack is intended to answer

agencies’ questions that can be resolved relatively quickly without major

research. FastTrack staff consists of NARA staff, agency officials, and

consultants. NARA’s plan is to disseminate information to agencies over its

Web site and include best practices and frequently asked questions.

Our review of the ERM activities in four states and three foreign

governments showed that approaches to ERM differ. These entities often

did things differently from each other and/or NARA.

Some state governments are making decisions regarding the same ERM

challenges that face NARA and federal agencies, while some are waiting to

see what works for other governments. Our interviews with officials from

four states (Florida, Oklahoma, Oregon, and Texas) revealed that these

states approach some issues differently than the federal government or

each other.9

In general, the four state archiving agencies provide centralized policies

and procedures that are described in either state law or administrative

 

9

Our descriptions of the requirements imposed by state laws and regulations are primarily based on our

interviews with state officials.

ERM Activities of

Selected State and

Foreign Governments

Some States Have

Centralized Policies but

Decentralized Custody of

Records
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rules. State archiving agencies that take physical custody of the actual

records do so when the records are no longer needed by the individual

agencies but are of archival value. In these cases, the states do not have

the capability to maintain the records in electronic format but require

nonelectronic copies. The four states have relied on record-tracking

systems, which allow them to determine where specific records are

located.

Two of the four states that we selected emphasized the use of the Internet

as a mechanism that allows both the archivist and the general public to

determine where records may be found. While the state officials indicated

that state law and the administrative rules that they issue guide their

records management requirements, they also interact with NARA and

other states to assist in determining their states’ policies.

The state archiving officials we interviewed were all aware, to varying

degrees, of the recent federal actions and activities dealing with the

archiving of electronic records. However, some of the states are moving

forward independently and have been doing so for several years. For

example, according to state officials, during the past 10 years, Texas has

continually revised its records management manual, records management

statutes, and administrative rules. Further, according to state officials,

Texas continues to study ways of providing better support to agencies’

records management programs. In November 1998, the Texas Electronic

Records Research Committee completed a legislatively directed report

that made several recommendations to help agencies manage their

electronic records as required and make state agency documents in

electronic formats readily available to the public. The committee’s

recommendations include guidelines to enable better coordination among

records management, archives, and information systems staff within

agencies. The recommendations to the Texas State Library and Archives

Commission and the Department of Information Resources included

• establishing administrative procedures and training to ensure that all staff

work together to identify and manage electronic records to meet retention

and archival preservation requirements,

• making library and archives standards applicable to all state records

maintained in electronic format,

• seeking a legislative change in the Local Government Records Act so that

the rules for managing electronic records can be amended to make these

standards applicable to all local government records maintained in

electronic format,
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• jointly establishing and publishing guidelines for using standard functional

requirements for electronic recordkeeping systems,

• studying the issues of retaining electronic records of enduring value for

historical and research purposes to identify available options and

associated costs with the intent of proposing legislative action,

• developing cost models for providing information to the public on-line, and

• working with the Office of the Attorney General to jointly establish rules

and guidelines for providing and managing access to publicly available

government information without compromising the privacy of citizens.

Similarly, according to state officials, Florida’s current records

management policy is based primarily on 10 to 15 years of legislatively

directed studies and reports on information management as well as

experience gained through Florida’s archive and historical records

program, which it has operated since 1967. In September 1998, a

consultant’s report on access to state government electronic information

of long-term or archival value recommended that, among other things, the

Florida State Archives take custody of electronic records when an agency

is defunct and has no successor agency or when the records of an ongoing

agency have archival value. The report also recommended that the Florida

State Archives (1) serve as a “locator” for information about archived

electronic records; (2) review the agencies’ annual reports on information

systems; (3) assist in detailed reviews of the records policies and

procedures of individual agencies; and (4) contract with an outside party

to maintain the electronic records, including storing, providing access, and

regularly migrating data to meet preservation requirements.

From our interviews with officials in the four states and review of

documentation, we learned that some states have arrived at decisions on

how to address ERM issues. For instance:

• Policies and Procedures. According to state officials, the state archives

agencies in the four states we surveyed generally provide centralized

policies and procedures, described in either state legislation or

administrative rules, that are the catalysts for policy development. Other

considerations mentioned by the state archives officials were federal laws,

recommendations made by internal and state auditors, observations of

other states and the federal government, and private business practices.

• Guidance. The records management regulations in Texas, Florida, and

Oregon provide specific guidance to state agencies. For example, Texas

provides guidance on (1) standardized definitions for terms related to

managing electronic records; (2) minimum requirements for the
B-281101

Page 15

maintenance, use, retention, storage, and destruction of electronic records;

(3) records management program administration that incorporates ERM

objectives into agency directives, ensures that training is provided, ensures

the development and maintenance of up-to-date electronic systems

documentation, and specifies the location and media on which electronic

records are maintained; (4) security of electronic records; and (5) public

access to electronic records. Although some differences exist in content or

approach, state code or administrative rules for Florida and Oregon

provide equally detailed, and often closely paralleled, guidance to state

agencies for managing electronic documents.

• Electronic records retention. State agencies in Texas, Florida, and

Oklahoma retain archiving responsibility and custody of electronic

records. When paper or microfilm records are no longer needed at the

agency level, those of archival value are transferred to a central storage

facility. In Texas, ERM and archiving system design are functions that are

decentralized to state agencies, while Florida establishes minimum

electronic recordkeeping requirements for all state agency records

management and archiving systems. Texas has implemented an automated

inventory tracking system to facilitate access to nonelectronic records

maintained by the archives. Florida is considering using a contractor to

develop and maintain storage and access for electronic archival records,

including migration and software requirements.

• Development of a governmentwide information locator system. While

Oregon and Oklahoma use what is basically a manual system to provide

the public with access to archived records, Texas and Florida have

developed Internet-accessible government information locator systems.

The Texas Record and Information Locator Service is an on-line resource

for accessing government information statewide—the next version will

identify, describe, and locate individual state government information

resources as well as print publications, individual documents, and

databases available to the public on the Internet. The Florida Government

Information Location System provides public Internet access to the

location of electronic and nonelectronic public records.

• Training. All four states sponsor organized records management training

programs or workshops for state employees.

• Enforcement of records management requirements. Authority to enforce

mandated records management requirements varies among the states. For

example, according to state officials, Oregon can impound records in

danger of being lost, and citizens of Florida can request a state attorney
B-281101

Page 16

investigation when they think that records may have been prematurely

destroyed. Florida is also currently considering a requirement for formal

statements of compliance from all state agencies. The Texas State Code

establishes requirements for state agencies to transfer archival records to

the State Archives or preserve them within the agency.

The National Historical Publications and Records Commission (NHPRC),

the grantmaking affiliate of NARA, provides funds to state and local

archives, colleges and universities, libraries and historical societies, and

other nonprofit organizations to help locate, preserve, and provide public

access to documents and other historical materials. NHPRC has made

several grants to states in recent years to assist them in their ERM efforts.

NARA is working with Australia, Canada, and the United Kingdom on

common ERM challenges. Our review of public documents showed that,

although these countries share common challenges, they each have taken

somewhat different approaches to making ERM decisions.

The Australian, Canadian, and United Kingdom governments differ from

each other, as well as NARA, in how they archive national records. For

example, Australia has strong central authority and decentralized custody.

Due to this decentralized custody, Australia must rely on a governmentmaintained information locator system to determine where the records are

located. Since agencies within the governments can have various software

systems, decentralized custody places the responsibility on the agencies,

not the national archives, to ensure that records are retrievable regardless

of any changes in hardware or software technology requirements. Use of

the Internet is being integrated into their systems for search, retrieval,

and/or requests for information. Australia has somewhat detailed records

retention guidance to which its agencies must adhere. Since it does not

have direct custody of electronic records, the Australian central archiving

agency has compliance audit authority to ensure that individual agencies

follow records management and archiving policies and laws.

Implementation of an automated records management software system is

under way.

Canada’s national archives takes a somewhat different approach. Canada

established “vision statements,” rather than specific policies, and the

individual agencies maintain their own electronic records until they have

no more operational need for them. At that point, records of archival value

are transferred to the national archives. Also, Canada offers use of the

Internet for searching, requesting, and retrieving pertinent records.

Some Foreign Governments

Are More Centralized and

Provide More Detailed

Guidance Than Others
B-281101

Page 17

The United Kingdom established broad guidelines, which are put into

practice by its individual agencies or departments in a partnership

arrangement with its national archives. These guidelines address all types

of records, including electronic records. Currently, the Public Record

Office has several study groups addressing management of electronic

records and overall strategy for E-mail and office desktop systems. Case

studies in five different departments are currently in progress to identify

alternative practices for electronic recordkeeping.

NARA is also part of two ongoing international initiatives that are to study

and make recommendations regarding ERM. The first effort—International

Research on Preservation of Authentic Records in Electronic Systems

(INTER PARES)—is made up of archivists from seven countries (United

States, Canada, Ireland, Italy, Netherlands, Sweden, and United Kingdom)

and six research teams (United States, Canada, Northern Europe, Italy,

Australia, and the Collaborative Electronic Notebook Systems

Association). INTER PARES first met in Washington, D.C., in June 1998.

The second effort is made up of English-speaking countries (United States,

United Kingdom, Australia, and Canada). This group first met in London,

England, in July 1998.

NARA and federal agencies are being challenged to effectively and

efficiently manage electronic records in an environment of rapidly

changing technology and increasing volume of electronic records. On the

basis of our discussions with officials from NARA and four judgmentally

selected agencies, we determined that ERM programs vary greatly across

agencies. NARA had planned to conduct a baseline survey intended to

obtain governmentwide information on agencies’ ERM programs, but

NARA has now postponed the survey because it believes that it should first

complete a BPR effort to improve guidance and assistance to agencies.

Considering that the BPR effort would more likely result in changes that

are practical and functional for the agencies if it included an assessment of

where the agencies are today in terms of ERM, the survey should not be

postponed.

In order for NARA to have the best information to make decisions during

its BPR effort and, thereby, improve ERM in the federal government, we

recommend that the Archivist, National Archives and Records

Administration, conduct a baseline assessment survey now and use the

information as input into the BPR effort, rather than postpone the survey

until after the effort is completed.

Conclusion

Recommendation
B-281101

Page 18

On June 7, 1999, we provided the Archivist with a draft of this report for

comment. We received his comments in a letter dated June 22, 1999, which

is reprinted in appendix II.

In commenting on our draft report, the Archivist said that we have ably

outlined significant electronic records challenges faced by NARA and

federal agencies. The Archivist also commented, however, that he did not

concur with our recommendation to conduct a baseline assessment survey

now and use the information as input into the BPR effort. The Archivist

stated that the survey has been put “on hold only temporarily,” and that he

is “committed to conducting it in a timely fashion, and in a way that

provides the greatest benefit to NARA and the agencies in improving

Federal records management programs.”

While there is general agreement that the baseline survey is needed and

should be done, we disagree with the Archivist over the timing of the

survey. During our review, we looked for justification for conducting the

survey before, during, or after the BPR effort. Conducting the baseline

survey now could provide valuable information for the BPR effort, while

also accomplishing the survey’s intended purpose of providing baseline

data on where agencies are with regard to records management programs.

Because agencies vary in their implementation of ERM programs, the

baseline survey would provide much richer data than the limited

information collection effort outlined by the Archivist in his response

letter and would fulfill an agency strategic goal. NARA would also be in a

better position in later years to assess the impacts of its BPR effort, as well

as to assess progress toward achieving its long-range performance targets

as outlined in the Archivist’s letter.

Finally, we are concerned about how long it may take to complete the

baseline survey if it is put on hold until after the BPR effort. Given that this

effort is expected to take 18 to 24 months after it is started and the

baseline survey is expected to take about 2 years, the baseline of

governmentwide records management programs may not be established

until perhaps sometime in calendar year 2003. There is also the possibility

that the baseline survey would be further delayed while the BPR initiatives

have a chance to gain a foothold throughout the government. For these

reasons, we continue to believe that the baseline survey should be done

now, as the BPR effort gets under way.

Agency Comments and

Our Evaluation
B-281101

Page 19

We are sending copies of this report to the Honorable Joseph Lieberman,

Ranking Minority Member of this Committee, and the Honorable John W.

Carlin, Archivist of the National Archives and Records Administration. We

will make copies available to others upon request.

Major contributors to this report are acknowledged in appendix III. If you

have any questions, please call me on (202) 512-8676.

Sincerely yours,

Laurie E. Ekstrand

Associate Director, Federal Management

 and Workforce Issues
Page 20 GAO/GGD-99-94 Preserving Electronic Records

Contents

1 Letter

Appendix I 22

Scope and

Methodology

Appendix II 24

Comments From the

National Archives and

Records

Administration

Appendix III 26

GAO Contacts and

Staff

Acknowledgments

Abbreviations

BPR business process reengineering

DOD Department of Defense

EPA Environmental Protection Agency

ERM electronic records management

GRS general records schedule

GSA General Services Administration

INTER PARES International Research on Preservation of Authentic Records in

Electronic Systems

NARA National Archives and Records Administration

NASA National Aeronautics and Space Administration

NHPRC National Historical Publications and Records Commission

OMB Office of Management and Budget

OTS Office of Thrift Supervision
Page 21 GAO/GGD-99-94 Preserving Electronic Records
Appendix I

Scope and Methodology

Page 22 GAO/GGD-99-94 Preserving Electronic Records

To obtain information on the challenges that confront the National

Archives and Records Administration (NARA) and federal agencies as a

result of their increased reliance on electronic media, we interviewed

NARA and agency officials from four judgmentally selected agencies—the

Environmental Protection Agency (EPA), the General Services

Administration (GSA), the National Aeronautics and Space Administration

(NASA), and the Department of the Treasury’s Office of Thrift Supervision

(OTS). We also (1) interviewed other electronic records management

(ERM) professionals from educational institutions and records managers’

organizations and (2) reviewed documents and papers written on the

subject by these professionals and others. We also attended ERM

seminars, conferences, and meetings where NARA and many agencies

were represented, and these challenges were discussed.

To obtain information on the status of agencies’ and NARA’s

implementation of ERM, we made limited contacts at the previously

mentioned agencies to obtain information on their policies and

procedures. We interviewed records management officials at these

agencies and reviewed pertinent documentation. We selected EPA

because they have an active, progressive records management program;

we selected GSA because they have oversight records management

responsibilities in addition to operating their own records management

program. We chose NASA and OTS because they are piloting ERM

software to help them manage electronic records. We also obtained and

reviewed the Department of Defense’s (DOD) ERM software standard.1

 In

addition, we interviewed NARA staff and reviewed NARA’s guidance and

oversight responsibilities. We also interviewed an official of the Office of

Management and Budget (OMB) to determine how OMB assists NARA in

providing guidance to agencies.

To obtain information on ERM policies and procedures of some other

governments (state and foreign), we judgmentally selected three states

(Florida, Oregon, and Texas) on the basis of recommendations from

records management professionals who said that these states are

considered leaders in ERM. We also contacted another state near our

Dallas Field Office that was not mentioned by these professionals

(Oklahoma). At the four states, we interviewed officials and reviewed

documentation of their policies and procedures. (See footnote 9 in this

report.)

 1

Design Criteria Standard for Electronic Records Management Software Applications, November 1997,

issued under the authority of DOD Directive 5015.2, Department of Defense Records Management

Program, April 11, 1997.
Appendix I

Scope and Methodology

Page 23 GAO/GGD-99-94 Preserving Electronic Records

In addition, we obtained policies, procedures, and other public

documentation from the Internet Web sites of three judgmentally selected

foreign countries (Australia, Canada, and the United Kingdom) that

records management professionals identified as being advanced in ERM.

These three countries also work with NARA on various ERM initiatives.
Appendix II

Comments From the National Archives and

Records Administration

Page 24 GAO/GGD-99-94 Preserving Electronic Records
Appendix II

Comments From the National Archives and Records Administration

Page 25 GAO/GGD-99-94 Preserving Electronic Records
Appendix III

GAO Contacts and Staff Acknowledgments

Page 26 GAO/GGD-99-94 Preserving Electronic Records

Michael W. Jarvis, (202) 512-6363

James H. Burow

James W. Turkett

Warren Smith

James L. Rose

James M. Rebbe

David F. Plocher

Carol M. Hillier

GAO Contacts

Acknowledgments
Page 27 GAO/GGD-99-94 Preserving Electronic Records
Page 28 GAO/GGD-99-94 Preserving Electronic Records
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