What would I like to learn from attending the ARMA International Conference in San Francisco?”

This was a question posed by one of my colleagues who will be attending the ARMA conference in November. Unfortunately, I will be unable to attend due to business commitments, but I will share my thoughts on sessions that I would attend based on past experience in attending this annual conference.

While I do attend many of the excellent educational sessions offered at conferences by knowledgeable professionals, I can usually be found talking with vendors and/or attending technology sessions in the Conference Exposition Hall. However, I would probably make sure to attend those sessions that are currently my favorite topics. For example:

• Sunday – 1:00-2:30pm: If I was new to the profession I would attend the session “Six Starting Points for a Records Management Rookie”, presented by Richard Smith, CRM. I have attended his poster session in the past and his session on basic RIM should be worthwhile.
• Monday – 8:-9:30am: I have found in the past that Laurie Carpenter, CRM, has a real grasp on marketing her records management program which would make her session “Motivating Through RIM Marketing” a must for anyone in the profession.
• Monday – 2:45-4:30pm: Training of the RIM professional is one of the areas I find lacking with most organizations that I have worked for as a consultant. One of the reasons given is a limited budget. So I would attend the “Employee RM Training on a Limited Budget”, presented by Richard Smith, CRM.
• Tuesday – 8:-9:30am: Hot Topic - The ARMA International Educational Foundation will have a session “The Impact of Social Networks on RIM” that will discuss the negative effects these tools have on an organization's ability to manage information.
• Tuesday – 1:-2:30pm: The session “Developing an Interactive RIM Training Program”, presented by Karon Teague may also be of interested to those who are trying to implement a RIM training program within their organization.

In addition there are many other sessions being presented by experts in the field of records and information management that would be worthwhile attending.

As I have written in past articles on attending conferences I need good visual stimulation to I need to fully understand the technology. In short, I need to see and hopefully touch what the written words have described to fully understand the process. That is one of the reasons I would attend the training sessions and visit the vendor booths that will be in the Expo Hall. I liken the visit to the Expo Hall as one visiting a candy store. It is the only time in the year that you get a chance to view new products, ask questions and hopefully attend an informational training session that makes you think how you could use the product.

I would also attend the Poster Sessions that will be located in the Expo Hall. I found some of the past poster sessions provided some very interesting approaches to management of a project, case studies, or marketing of a program. The poster sessions are less formal and provides the attendee a chance to talk directly with the presenter. You can review the posters on Sunday, November 7 and come back Monday afternoon, November 8, to ask questions of the presenter.

I urge members of our profession to continually seek out educational opportunities that are offered through our association and other associations that provide the training to keep up with the many changes in our profession.

How can we manage the social media phenomenon?

Question asked by a client during a question and answer session AT A RECENT SEMINAR.

Response:

This is an excellent question CONCERNING a real problem for those involved in the management of electronic information. A few decades ago most organizations (public and/or private) only had to worry about managing their paper records and microfilm. In a recent seminar I listed some of the different ways organizations maintain their information using today’s technology:

Paper
Optical Disks
Compact Discs (CD/DVD)
Cell Phones
Bar Coding
Flash Drives
Email Websites
IM (Instant Messaging)
Blogging
Social Networks (Wiki’s, Twitter, Facebook, etc.,)
Cloud Computing
Microfilm
Next New Technology?????

Unfortunately, technology has grown faster than our ability to adequately manage new technologies effectively from a records management standpoint. One only has to subscribe to a legal, records management, archives or technology listserv to see the confusion caused by our inability to proactively provide specific guidelines on “how to” manage the information. Some regulations are being changed to include the requirements for managing social media. The Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 10-06, which requires member firms to monitor and retain business related postings made using social networks. Other federal agencies are also updating their rules to include social media content. If you note, no one is prepared for the management of the new technology, and we, in the records management profession, are always placed in a reaction mode. In the case of social media everyone is a few years behind in the establishment of the rules to manage the information explosion.

Fortunately, there is some guidance using the FAQ’s (Frequently Asked Questions) on various records management websites and from NARA (National Archives & Records Administration). As of August 14, 2010 NARA has not posted guidance on their website so you should check later on their FAQ page reflected below. The following are some resources that can be reviewed in the development of a policy:

State of Washington: http://www.sos.wa.gov/_assets/archives/RecordsManagement/RMAdviceSheetBlogsTwitter.pdf

They also have a presentation on social media that may be of interest at: http://www.sos.wa.gov/archives/RecordsManagement/ElectronicRecordsManagementAdviceandResources.aspx

City of Seattle: http://www.seattle.gov/pan/SocialMediaPolicy.htm

NARA: http://www.archives.gov/records-mgmt/faqs/
U.S. Government – General Service Administration: http://www.gsa.gov/graphics/staffoffices/socialmediapolicy.pdf

A listing of various social media policies by governments and private organizations can be found at the Social Media Governance website: http://socialmediagovernance.com/policies.php

University of Washington: http://f2.washington.edu/fm/recmgt/

Financial Industry Regulatory Authority (FINRA: http://www.finra.org/Industry/Issues/Advertising/p006118

Although a policy is not currently available on the use of social media the University of Washington website is a great resource with their records management FAQ’s. If you are working in a college/university environment the website should definitely be on your favorites list.

In conclusion, while the use of social media for the dissemination of information is being rapidly adopted by government and private organizations, the legal ramifications on its use is currently in flux based on the lack of established legal precedence. The key thing to remember is that the information being created and maintained on social media sites may be considered a business document and the responsibility of the user to insure that the information is retained, if a legal requirement exists.

What Do You Know About Cloud Storage

Question asked by an information technology worker during a break at a recent meeting.

Response:

I told the individual asking this question that the use of Cloud Storage is a hot topic on the records management listserv with various articles discussing the pro’ and con’s of outsourcing storage of electronic records storage to the Cloud. Cloud storage is one of the latest “buzz words” being used by vendors to promote a service to organizations. Based on my review of current literature many organizations are looking into outsourcing their important business information to reduce the cost of their information technology functions. As records management professionals in an organization we are probably not included on the decision making team evaluating the use of the Cloud strategy. We are usually in the re-action phase and only thought of after the fact and/or when someone realizes the information that is being outsourced may have unforeseen consequences by being in the cloud environment in the event of a litigation, retention, retrieval, etc.

As reflected in the “Guidelines for Outsourcing Records Storage to the Cloud”, sold by ARMA International, 2010, Gartner defines Cloud Computing as “A style of computing where scalable and elastic IT-enabled capabilities are delivered as a service to external customers using Internet technologies”. The publication became available in late October in both paper and pdf format and should be a good resource regarding the use of Cloud technology for the RIM professional. The publication comes with checklist that can be used by an organization considering the use of the technology.

As mentioned earlier the main benefit for the use of Cloud computing is cost saving. The publication mentioned above and others list the risk factors. Some of the risks are:
• Accessibility – the ability to retrieve 24 hours a day/7 days a week
• Data Security - how to preserve and protect data to avoid problems in the retrieval process
• Data location – Where is it stored. There may be privacy and data protection issues.
• Data Segregation – How do they manage the segregation of the data for multiple owners sharing the same application and servers.
• Data Integrity – How do they manage backup, recovery and retention issues?
• Data Ownership – Requirement for solid contract with provider on ownership issues.

For further information on Cloud Computing/Storage I recommend the following articles:

“Cloud Computing: Can You Retrieve your Data?” published by CFOInnovationsAsia, October 2010. Article discusses worse case scenarios by an organization of the need to audit and/or litigation. . I’ve bookmarked this website for further review.
http://www.cfoinnovation.com/content/cloud-computing-can-you-retrieve-your-data

Other articles on Cloud Storage from this same resource:

“Cloud and the CFO Reality Check – Finance” published by CFOInnovationsAsia, 19 October 2010
http://www.cfoinnovation.com/content/cloud-and-cfo-reality-check-finance

“The CFO Cloud Computing Nightmare” published by CFOInnovationsAsia, 28 August 2010
http://www.cfoinnovation.com/content/cfos-cloud-computing-nightmare

“When Cloud Computing and Compliance Collide”, ComplianceWeek, 11 October 2010. Also read some of the comments from readers at the bottom of the article.
http://www.complianceweek.com/blog/kelly/2010/10/11/when-cloud-computing-and-compliance-collide/

“What’s The Problem With Cloud Security? There’s Too Much Of It…”, Rational Survivability, 17 October 2010. Article contains technical information with comments from readers on the Cloud structure methodology.
http://www.rationalsurvivability.com/blog/?p=2693

In closing, while I believe many organizations will take advantage of the benefits of Cloud storage, RIM professionals are tasked to be aware of the problems an organization may have if our employer implements Cloud Storage. I hope the resources outlined in this article will be useful to the RIM professional becoming aware of both the positive and negative points of use of this product .

We are Not Records Cops

I’ve heard of the expression “Records Cops. Is that what the records people do?

Asked by a student and a thread on the records management listserv.

Response:

Unfortunately, many employees within an organization look upon the records manager as “records cops” who destroy records belonging to departments within the organization. I would like to think this is a misconception but experience has shown that it unfortunately is true in many cases. I personally recall clients who did not trust the records group because they destroyed their records without the permission of the department.

Personally, I am not a big fan of records management assuming the role of ownership of company records. Sometimes the records management listserv has a thread on this subject and I notice that there are people on the listserv who believe they are both custodian and owner of the company records. While I take great pride in assuming the management of the business records, I find it difficult to assume that because the records may be in our custody we have the authority to actually destroy the records even if the records retention period has passed.

I prefer to think that the records and information manager is responsible for maintaining the reliability of the records within the organization by establishing, implementing and maintaining the records management program that involves the creation, distribution, maintenance, protection, control, storage and destruction of the records. I seem to remember this from our records management books discussing the “Life Cycle of a Record”?

I firmly believe the responsibility for approving the destruction of records within the organization should be the responsibility of the client as they may have knowledge of records that could be a destruction exception that is unknown to the records manager. Destruction of records by a records manager that were an exception could undermine the goodwill of the client. I’ve actually known departments who rented and stored their inactive records in local storage lockers rather than have the records managed by the records management staff. How many of you have the approval authority to destroy records? If you have the authority, do you destroyed the records of your directors, CEO, CFO, etc., without getting prior approval. My guess you would ask permission or be looking for a new position if you destroyed something without their approval.

Some organizations may have other functions (legal, Accounting, etc.,) in their destruction approval process. For some reason having other functions within the company reviewing the destruction notices seems cumbersome, especially if the organization is very large and with units at different locations. The department should be made aware by other functions if there is a legal hold, tax hold, etc., as part of their normal business processes.

I am a firm believer that a destruction notice be created, if at all possible, by departmental records coordinators, reviewed and sent to and signed by the department owner of the records. The destruction notice or letter accompanying the destruction notice should also ask if there is a reason (legal, financial or administrative) why the records should not be destroyed. Perhaps a hold has been placed on the records by litigation. Maybe the tax audit has not cleared. These reasons would be sufficient to place a hold on the records until the matter is closed. A suspense system should be in place to review holds/tax audit records being held beyond their retention period.

Records that are to be retained beyond the retention period for administrative reasons should be reviewed annually to determine if the established retention period is insufficient to meet the needs of the organization.

In closing, I am a firm believer that records management function should not assume the role of the “records policeman” and the responsibility for destruction approval rests with the department owner

Reviewing Records for Destruction

Do you have any tips on reviewing records for destruction?

Question was recently asked by an administrator during a review of their department’s filing system.

Response:

While an organization may have a good records management program on paper, with all the proper policies and procedures, there usually is something missing in the process; the lack of consistent and timely reviews of records past their retention period. I am sure that many of you can relate to this problem. As I have stated in previous articles, this is not unique to any one organization, private or public. Without a systematic approach and staff assigned and trained to manage the program your records will not be reviewed regularly.

Here are a few things that I have found that work effectively with any records review:

 If you have an existing records management database you can create a listing of records that are due for destruction for each client or department within your organization. Annotate those that may be over-due for review. If you suspect an error in the retention period, write a comment on the index that the record may require additional retention.
 If you use an outside vendor to manage your business records they probably have the ability to create listings of records due for destruction. The major vendors in my area have electronic systems that allow the customer to create and publish listings based on criteria established by the customer. Vendors will also create reports to your specifications for a fee.
 If your lists of records transferred to storage (transmittals) are in paper mode only, start by reviewing the transfer notices of the oldest boxes in storage to insure the information on the transmittal accurately describes the records within the boxes. I have found over the years that not all records shipped to storage were accurately described. I have encountered transfer notices that did not include the dates of the records within the boxes. Box contents on the transfer notices simply labeled “Projects”. Each box with missing or misleading information will require individual inspection to determine the contents and see if they can be destroyed or re-indexed with the proper information to identify the contents.
 As Ellie’s father said in the movie ‘Contact’; “Small moves Ellie, small moves”. The same goes with a records cleanup. Hopefully the client will review the listing and approve the destruction of the records. However, if you cannot get an approval of destruction of the collection, arrange to review them in small amounts. You will have a better chance of getting the cooperation of the reviewer if they are not overwhelmed by the task. The smaller the amount of records the client has to review the better.
 Secure a dedicated room to store and review the records so the client does not have clutter in his/her area. You probably already have the clutter in your own office. If you have a collection of records off-site at a commercial records center you may be able to arrange a room to view the records at their site. Generally there is a charge to using this viewing room. Try to have the client set aside specific time during the work day for review and management of their records. Emphasize the importance of time management. I had clients actually request I put a few records at a time in their chair every morning to review.
 If the actual owner of the records cannot or refuses to complete the review, you might have to find a person with the authority to approve the destruction and/or would be willing to have someone else who is knowledgeable perform the task.
 Try to secure a champion from upper management who will help promote an annual records review program so that is becomes a requirement, not an option.
 Review all boxes in storage to insure that they have an appropriate retention period. If your local or state agency within a state that has a formal records management program, use or create a destruction notice that meets the state’s guidelines. Once you have destroyed the backlog, the annual review should become much easier if done on a regular basis.
 If you have an onsite records center and/or special areas to store records, do not let them become a dumping ground for non-records. Insist on control of the environment to insure the protection of the records from unauthorized use and review. This is easy to say but a challenge to do. I have taken photographs of poorly managed storage areas and used them successfully in presentations to management staff to emphasize potential risk to their organizations.

The cleanup process is probably one of the more stressful parts of a records managers duties. However, when you have completed the cleanup of the backlog you should feel satisfaction for successfully accomplishing the task.