[vc_row][vc_column width=”1/1″][vc_column_text]The Information Governance Initiative has prepared and submitted a public comment on the National Archives and Records Administration’s (NARA) draft automated Electronic Records Management (ERM) report and plan. Under the Section A3.1 of the Managing Government Records Directive which requires federal agencies to “manage all permanent electronic records in an electronic format,” NARA is to develop a plan outlining suitable options for automating ERM to reduce the burden associated with it. NARA requested comments on its draft report and plan. Click here for more details.

Given the importance of NARA’s efforts to preserve our nation’s historical record and provide access to that record, as well as IGI’s commitment to public advocacy for information governance, we decided to provide comments.

We believe NARA has taken a significant step forward in fulfilling Goal A3.1 through issuance of the Draft Plan dated March 10, 2014. First, NARA has recognized that the “processes and tools that agencies currently use to manage electronic records are not adequate to support consistent compliance with the Federal Records Act.” Second, NARA has further recognized that “most agencies are relying on individual staff members to capture and categorize their electronic records, if they are managing electronic records at all. The document goes on to note that “[e]nd users find it burdensome to manage their electronic records if that means touching each file and making a separate recordkeeping decision about each one.” Third, NARA recognizes that the availability of records management application software on the market “has not led to universal use of these tools in agencies even for types of records that RMAs can manage; the problem of achieving consistent management of all agency electronic records remains unsolved in spite of this technology.” Fourth, NARA has identified the fact that “[p ]romising tools for automation already exist,” and that “[t]he advanced search space, including machine learning or predictive coding as used in eDiscovery, is one of several promising areas for records management exploration.”

Each of the four points listed above represent an enlightened view of the challenges and opportunities present at the current time to optimal recordkeeping in the public sector space, and in our view, the Draft Plan therefore represents a signal achievement, indicating that much progress has been made in terms of the public policy discussion since issuance of the President’s 2011 Memorandum and the 2012 Directive itself.

– Excerpt from the Information Governance Initiative’s Comment on NARA’s Draft Automated ERM Report and Plan

The IGI also commented on the Draft Plan’s failure to adequately take into account the budgetary timelines faced by agencies facing deadlines for implementation, and urged NARA to revisit its timeline and accelerate it due to the urgent need for agencies to act. The IGI also advocated for more transparency in the commenting process to foster open dialogue about the various proposals. In addition, IGI recommended that more emphasis be placed on requesting views from the private sector, so that the government can benefit from private industry’s experience to more effectively tackle issues at the intersection of technology and public policy.

For a complete listing of IGI’s remarks, click here to view IGI’s comment drafted by Jason R. Baron (IGI Co-Chair).[/vc_column_text][/vc_column][/vc_row]