A few agencies need to up their game on records

Most agencies are following the path toward electronic records management laid out by the White House in a 2012 directive, but more work is needed, according to a new report from the Government Accountability Office.

The Obama administration has ordered agencies to preserve all email records electronically by the end of 2016, and to preserve all records that were generated electronically in usable, retrievable formats by the end of 2019. As was detailed in the revelations about former Secretary of State Hillary Clinton's use of a private email server during her time in office, agencies have varying rules and levels of technical accomplishment when it comes to capturing the records of senior officials.

Many agencies maintain the practice of simply printing out and retaining emails deemed to be records. But these pre-digital practices are being phased out. The directive set up a series of processes designed to get agencies in position to meet the records management goals. GAO found that by and large agencies are complying, but there are a few trouble spots.

The policy required agencies to designate a senior agency official at the assistant secretary level to oversee records management policy. Per the GAO report, the Department of Veterans Affairs and the Office of Personnel Management did not select officials for this role at the appropriate level of authority. This diminution of the SAO role, the report suggests, shows a lack of commitment or priority placed on the records management function.

Since the GAO report was released for agency review, OPM designated its CIO Donna Seymour for the SAO role. In its reply comments, VA indicated that it would give the SAO role to its CIO, but delegate day-to-day operational responsibility to Associate Deputy Assistant Secretary for Policy, Privacy and Incident Response John Oswalt.

CIOs at the departments of Homeland Security, Energy, Commerce, Labor and Transportation, as well as EPA, NASA, the Export-Import Bank and the Federal Energy Regulatory Commission serve in the SAO role. At DoD, Principal Deputy CIO Dave DeVries serves as SAO. Per the White House directive, the SAO must have authority to "make adjustments to agency practices, personnel, and funding as may be necessary to ensure compliance and support the business needs of the department or agency."

The directive also has requirements for the training and certification by the National Archives and Records Administration of records officers. Three agencies told GAO that they would not be able to fulfill this requirement until the end of fiscal 2015. The Office of Management and Budget has a role to play as well. The next revision of the A-130 circular on information resource management will require for agencies to build records management functions into cloud-based application services or storage. That update is expected to be finalized by the end of 2015.

GAO found that NARA's guidance for the transfer of electronic records was lacking requirements for metadata associated with those records. "Until NARA establishes a time frame for and, accordingly, takes steps to include metadata requirements in its revised guidance, agencies will remain unaware of all of the information they need to provide when transferring electronic records to NARA," the report points out. In its reply comments NARA agreed, although did not indicate when such guidance would be forthcoming.

GAO's review of agency records management policies found some targets for improvement. The report recommends that the Department of Transportation, the National Science Foundation and the General Services Administration take stock of permanent records that are at least 30 years old for transfer to NARA, as is the typical practice for civilian agencies. Additionally the NSF is asked to set a deadline for completing its records management plan, and complete the inventory of its unscheduled records.