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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Mon, 22 Apr 2013 14:27:26 -0700
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On Mon, Apr 22, 2013 at 12:14 PM, Lisa De Luca <[log in to unmask]
> wrote:

> Wanted to provide some color/context on this since the survey was
> underwritten by Iron Mountain.
>
> The 34% response is not a typo. The question in the survey, asked to 100
> Records Managers, was "What percentage of your agency’s records must be
> kept permanently?  (Range 0% to 100% available to choose). The average of
> 34% is the aggregate based on their responses.There were eight "Unsure"
> responses. The balance of responses ranged literally from 0% to 100% and a
> wide range of responses in between. The most replied percentage noted
> was "10%" (19 responses), followed by "100%," "25%" and "0%" at 9
> responses; 28 people responded "50%" or more as a percentage.
>
> NARA's definition of a permanent record, from their Schedule of Permanent
> Records on the website "Disposition of Federal Records: A Records
> Management Handbook" (http://www.archives.gov/records-
> mgmt/publications/disposition-of-federal-records/chapter-
> 6.html#VI.PermanentRecords), is: "Permanent records are those determined by
> NARA to have sufficient historical or other value to warrant continued
> preservation by the Federal Government, generally as part of the National
> Archives, unless otherwise agreed to by NARA."
>
> Interestingly enough, in another question of the survey, "What steps would
> enable your agency to better manage records?  Please select the top three
> steps,"  the top response was 43% responding "Better trained records
> management personnel," followed by more funding at 33% and more support
> from agency leadership at 32%. NARA has a great educational opportunity to
> educate agencies on definitions and proper records retention from the top
> down now that the new Senior Agency Officials have been appointed, as long
> as these SAOs look at education and training as an opportunity as well. We
> will see if at least two of the top three can be addressed.
>
> Lisa De Luca
> Director, Federal Marketing
> Iron Mountain
>
>
Nice to know the source, explains a lot about the quality and value of the
data I think.

Guess a lot depends on what level these respondents were at- were they
staff employees or heads of Departments/Agencies that evaluated records and
made disposition decisions?  If they weren't, and they weren't AROs, then
for them to respond to these questions means they gave their opinions, not
the Agency's decision.

And while that link provides access to a set of "GUIDANCE" for how to
develop a Records Management Program and the "Disposition of Federal
Records"... it doesn't really tell you how to determine what records are
Permanent. To determine what records are Permanent in an Agency, you need
to first look at the definition of Permanent in 36CFR:

 http://preview.archives.gov/about/regulations/part-1220.html#1220.18

Permanent record means any Federal record that has been determined by NARA
to have sufficient value to warrant its preservation in the National
Archives of the United States, even while it remains in agency custody.
Permanent records are those for which the disposition is permanent on SF
115, Request for Records Disposition Authority, approved by NARA on or
after May 14, 1973. The term also includes all records accessioned by NARA
into the National Archives of the United States.

Then you need to assess the records, by series, and determine after
reviewing the General Retention Schedules

http://www.archives.gov/records-mgmt/grs/

on a Schedule by Schedule, Series by Series basis which records, based on
the content, meet the requirement to be managed as Permanent.   As
examples, in GRS 3, 4, 5, 7 and 8  thare is NOT ONE series that is required
to be retained as Permanent.  The closest anything comes is "when
superseded or obsolete", and if something is NEVER superseded or obsolete,
well then, you cold infer that it must be retained in perpetuity, but it is
NOT "Scheduled as Permanent".

And SAO's being appointed is one step in the process, but since that time,
we have seen the impacts of sequestration, furloughs and budget reductions
and under these financial conditions, the care and feeding of the records
management program is NOT HIGH on the agenda of Agencies cutting staff and
reducing the number of Contract workers boots on the ground doing
day-to-day work.  And as often as we've seen CIOs change in agencies,
expect a similar revolving door for SAOs.  SAOs aren't new hires or
additions to staff, it's a duty assigned to someone already on existing
staff and a "new hat" being added on top of others.

If those surveyed really understood how things work, they would have placed
the HIGHEST percentage on "more support form leadership" because until you
have that, you can't get "better trained records management personnel," or
"more funding".  These things all go hand-in-hand after the leadership has
agreed to support the function.

Larry
[log in to unmask]



-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972...*

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