From: Jeff Davis <eagle@deeptht.armory.com>
Date: Mon, 18 Apr 94 18:41:39 PDT
To: cypher <cypherpunks@toad.com>
Subject: NARA e-mail standards (fwd)
Message-ID: <9404181841.aa21954@deeptht.armory.com>
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From mordor.cs.du.edu!eff.org!owner-eff-activists Mon Apr 18 18:09:55 1994
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Date: Mon, 18 Apr 1994 20:18:06 -0400 (EDT)
From: "Richard F. Strasser" <rfs@maestro.com>
Subject: NARA e-mail standards (fwd)
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To: eff-activists@eff.org (eff-activists mailing list)

I thought that list members might be interested in this note, which was
posted on another list.

Richard F. Strasser <rfs@maestro.com>



---------- Forwarded message ----------
Date: Mon, 18 Apr 94 10:40:51 EDT
From: Florey/AAIQ <florey@saf3.hq.af.mil>
To: ace-mg@esusda.gov
Subject: NARA e-mail standards

--------- The following is a converted OFFICEPOWER mail message ----------

                                                                              
       To:  ace-mg@esusda.gov                                                 
                                                                              
       CC:                                                                    
                                                                              
                                                                              
  Subject:  NARA e-mail standards            New [*]       Codes:  [        ] 
  Message:  Hi, ACE'ers.  I'm not sure just who y'all are, but you're surely  
            interested in government records, so you must be OK.  I'm an Air  
            Force colonel in the Admin Comm and Records Mgt Div of HQ USAF    
            Information Management.  We have been conducting a functional     
            process improvement (FPI) effort on records management since last 
            summer in DoD. Air Force is executive agent.  I'll pass my        
                                                                              
 Priority:  2                Delivery Acknowledge [ ]    View Acknowledge [ ] 
                                                                              
     From:  Florey/AAIQ            By:  florey@saf3            Attachment [*] 

-------------------------------- ATTACHMENT ------------------------------








         thoughts to you on the questions you asked.  They fit right into 
         our study because the constant undercurent of our FPI was a 
         solution to the problem of uncontrolled electronic records--those
         often created in e-mail that never find their way into the 
         official recordkeeping system.  I'll be happy to talk to any of 
         you on the phone about the topic and have some real experts who 
         work for me that can get deep into records in a hurry.  I'm in the 
         Pentagon at 703-697-4501.
         a. What's a federal record?  As defined in public law--44 US Code
         3301.  "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 United States Government under federal law or 
         in connection with the transaction of public business and 
         preserved for appropriate 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 informal value of data in 
         them."
         As you can see, virtually any official interchange of information 
         dealing with government business is considered a record to be 
         preserved by the agency for varying periods of time.  The National 
         Archives and Records Administration approves that length of time 
         for every record in the government thru the agency records 
         managers.  E-mail is most often an official record because it 
         deals with government business; few e-mails are so personal that 
         they fail to qualify as a record.
         b. Implications of managing e-mail records like paper records?  
         You bet.  See above--"regardless of physical form..."  A record is 
         a record, regardless of media.  The content of the information is 
         the key.  We are required to manage e-mail records, but truthfully
         no one is really doing so in the government today.  Big problem.
         There's a court case involving the White House on e-mail records 
         created there.  The overall situation was at the heart of our 
         motivation for doing the FPI.  We are checking off-the-shelf 
         software that will allow us to manage e-mail records to the same 
         standards we have for paper (or physical) records.  
         c. Is there a possibility that we may have to print out e-mail
         records just for the requirement of controlling them as records?
         Well, we gotta do something.  All of us are technically breaking 
         the law by not controlling e-mail records.  E-mail is official 
         mail; transactions over e-mail fit the definition of a record far 
         more times than not.  But what a waste to get all this 
         sophisticated equipment, fire electrons all over the world at a 
         touch of a key, and then have to print out the results on paper
         just for the record.  The answer is to load electronic 
         recordkeeping software onto any e-mail system.  The software 
         captures the record into the official system just as if a record 
         were paper and put in its proper place in the filing cabinet.  Big
         cultural change involved.  Action officers who create e-mail now 
         have to stop and do their filing chores to put the e-mail into the 
         system.  The software does it in a rather painless fashion, but 
         nevertheless it will be a step that none of us are having to 
         endure now.
         In our FPI, we developed 46 requirements that any automated 
         recordkeeping system would have to meet.  We have a multi-service 
         technical team looking at available software in the marketplace;
         the team spoke with vendors and then with users at their work 








         sites to include industry in Atlanta and Boston and the Canadian 
         government in Toronto.  To our surprise, 43 of the requirements
         are available now--only a couple of artificial intelligence type 
         requirements to make the filing absolutely transparent to the 
         action officer are not yet available.  We are on the verge of 
         floating a policy document to the near summit of DoD that states,
         "no computer system (read LAN and e-mail producers) may be 
         acquired that does not have electronic recordkeeping software.
         Legacy systems must be so equipped in a couple of years--or such
         a reasonable time."  Our master plan is to acquire the capability 
         to control e-mail type records in an automated fashion without
         having to convert them to paper.  Retrieval, transfer, and 
         eventual destruction of records will be fully automated and never 
         involve paper. In fact, we will want virtually all conventional 
         records (not films, video, and physical records) to be in the 
         electronic system--we want to eliminate tha paper system as much 
         as possible.  Records created on a PC are already electronic--
         paper mail that will be retained as a record will be scanned into 
         the electronic system.  By doing this, we can have fewer and 
         longer retention periods.  There will not be the constant stress 
         to move paper records to larger storage facilities where the costs 
         are less than in an office.  (such as federal records centers)  
         Retrievable data will be kept on-site for much longer periods of 
         time. 
         Now, a word about the NARA standards.  We are getting together as 
         a DoD on 12 May to discuss them, and DoD is hosting an interagency 
         conference on the standards on 19 May.  Our (Air Force) position 
         going in is that yes indeed electronic records should be 
         controlled to the same standards as paper records, which sadly 
         we're not doing now, but which the new software will allow us to 
         do.  However, we bristle at the suggestion that electronic records 
         should be maintained at a higher level of sophistication than 
         paper records.  We disagree that there needs to be an audit trail 
         of when electronic records were read, further dispatched, etc.
         We have never done that for paper and don't want to start such
         unnecessary requirements for electronic.  We have no idea if 
         someone looks at a paper document in a filing cabinet--we should 
         not be required to keep records (and unfortunately that's what 
         they would be in a seemingly never-ending escalation of creation)
         of when electronic records are viewed.  We presently have that 
         standard only for Top Secret information.  The courts are pushing 
         the higher standards because the technology makes it possible and 
         to make it easier to determine "what the President knew and when 
         did he know it?"  For the everyday office, this extra creation of 
         records is both excessive and expensive--and not worth the value 
         added.  Hopefully, we government records managers can get together 
         to refine the NARA guidelines to an appropriate and workable 
         level.
         So, if you're not yet blind from reading all of this, I hope 
         my thoughts were helpful.  NARA will take the commentary from the 
         corners of government, study them, and publish the final standards 
         within a few months.  Then we'll really know how to attack the 
         problem of controlling e-mail type records.  




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PGP PUBLIC KEY via finger!  JAFEFFM  Speaking & Thinking For Myself!
 
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