My apologies if this is a duplicate message. This is an attempt to end
automated rejections of what appears to be duplicate postings.
Bill Manago, CRM
Director, Records Management Practice
CA, Information Governance
Tel: +1-954.482.2977
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of Manago, William M
Sent: Monday, May 25, 2009 9:41 AM
To: [log in to unmask]
Subject: Re: Everything is a record until it is not - clarafication
In my humble opinion, GAO is, in effect, managing ESI as records.
Non-record as well as record worthy documents are profiled and assigned
to a category with retention at the point of creation. Once a folder or
case file reaches cutoff or is closed, the user is given the opportunity
to eliminate the non-record materials from the folder. So, until the
folder is closed, non-record ESI is managed as records and is available
for FOIA and discovery. I believe that this approach is an information
governance practice and not a records management practice. I posed my
question to the members of this list to test the temperature of the
water - is it time for record managers to embrace and take on the
challenge of managing ESI as well as records? I believe that this is
what the forward thinking records managers at GAO have accomplished.
This should not be a debate on the definition of a record. Rather it
should be a discussion on broadening the traditional role of record
managers to include responsibility for managing ESI that are not
records.
Bill Manago, CRM
Director, Records Management Practice
CA, Information Governance
Tel: +1-954.482.2977
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of Larry Medina
Sent: Saturday, May 23, 2009 12:17 AM
To: [log in to unmask]
Subject: Re: Everything is a record until it is not
>
> I don't think Bill was suggesting that all ESI is a record, rather
seeking
> input on the approach of treating all ESI as a record for a short,
specific
> period. (snip)
> Or is that just an "ignorant approach" as well?
Are you asking for a direct answer to that? =)
Okay, as has been said with respect to information created and stored in
electronic forms (and I'm not ignoring paper or saying that this isn't
also
applicable to paper, but that isn't the subject ESI is) and it;s been
said
repeatedly here, if an organization HAS a RM Policy, and that policy
clearly
defines what constitutes a record for the organization, anything that is
NOT
A RECORD should not be stored within the organizational repositories.
Once it has met it's purposes or if it is a draft or working paper (a
transitory record with a maximum set retention period of x days,
typically
not to exceed 180) and the valued content has been moved to a final
document
hat meets the definition of a record, then it should be destroyed, not
stored, so it is no longer ESI after that period.
And YES while it exists as a draft or working paper, if a legal action
is
filed (FOIA requests are different, and because all States and other
entities subject to them have different rules,no sense in getting into
that
here either) they ARE subject to discovery and must be declared in your
data
map *IF* the subject matter is what the action is related to. BUT, if
non-record information is discarded and transitory records are held for
fixed periods, what constitutes ESI in an organizations repositories ARE
records and should be subject to discovery.
The object is to have a policy, save ONLY records for as long as your
retention schedule states they must be held, and eliminate all other
"information" as soon as it's value has diminished... and eliminate ALL
non-records in the course of normal business rather than save them at
all.
I don't know how I feel about the approach yet - gotta think about it
some
> more. But to call it "the same ignorant approach" really does a
disservice
> to the request and to the other organizations (including, apparently,
the
> GAO) who are considering that approach. I certainly don't believe it's
an
> "ignorant approach" at all.
It's NOT RECORDS MANAGEMENT... which is why "saving everything" (a'la
email
'archiving') is ignorant... it's not consistent with policy and
practice.
Bill's question was about treating ALL ESI as records, not about what
GAO
was doing... if you read his question he said clearly he wasn't talking
about the practices of using the Big Bucket Theory, so no one was
apparetly
or otherwise making reference to what the GAO was doing.
While I appreciate the postings about the Big Bucket Theory, my question
was directed at the practice of managing all ESI as records for
discovery and FOIA purposes, regardless of your definition of a record.
Is that a sound/necessary practice?
I guess some folks have the luxury of thinking about an approach to
doing
things, while others are busy actually doing them and creating policies
and
training staff to follow practices that are consistent with them to
ensure
the volume of ESI that exists are limited to records so when/if a data
request or FOIA or other call is issued, the environment and volume of
records required to be searched and produced is much more limited and
the
risk to the organization is also smaller. Practicing Records Management
Professionals are at a great advantage in that they only have to respond
to
real world scenarios and not to postulate on theoretical approaches to
treating electronic records any differently that physical forms of
records.
Larry
--
Larry Medina
Danville, CA
RIM Professional since 1972
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