Bruce,

I feel like there are two different issues.

1) The example you mention of "political appointees and senior government
officials... using personal email to conduct government business" with the
*intention* to "to get around FOIA and other recordkeeping laws". Yeah - I
agree that short of giving NARA some kind of enforcement authority this is
a hard (political) nut to crack.

2) The problem of "shadow IT" where employees just find it easier to get
their core business done using tools outside of those provided by the
agency. This is the problem that I feel like RM professionals can address.
Working with agency IT staff to make tools easier and more intuitive to use
is a big first step. The second step is training - both on how to use
communication and RM tools, but also informing staff of the risks (both
organizational and personal) inherent in using outside tools for agency
work.

I feel like 22 USC 2911 gives me as an RM professional the legal support I
need to handle the second problem. The rules are clear enough to handle
emergency exceptions. The trick always to convince those in the highest
positions that the same rules apply to everyone, from records-clerk to head
of the agency and above.

Christopher Ferry, CRM
Boston, MA
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