A little over a year ago, I posted an article on the AIIM Community explaining why I no longer supported the DoD 5015.2 Electronic Records Management Standard. The article generated a great deal commentary and follow-on posts by other records management professionals. Since that original post we’ve seen a number of Federal agencies embroiled in very public, very expensive records management scandals. The biggest of which – at the Internal Revenue Service and the Environmental Protection Agency – are still making major headlines today.
Make no mistake, these scandals were the result of information lifecycle management policies based in part or entirely on the DoD 5015.2 model of enterprise records management. Policies that have failed to resolve the Federal government’s exploding records management challenges.
And yet a great deal of progress has been made, as well. Federal agencies have begun to openly question their records management practices. Private sector organizations, many of whom had lifecycle management solutions based on the DoD 5015.2 model, started to look into different, more forward-thinking practices. And product vendors, most of whom had long histories with products based on the DoD Standard, began to bring new, far more innovative approaches to the market.
All this progress culminated, I believe, in the National Archives and Records Administration’s release of its March 10th draft of the Automated Electronic Records Management Report and Plan. In this paper, NARA acknowledges solutions based on the DoD 5015.2 model have failed to provide Federal agencies with a means of “achieving consistent management of all agency electronic records.” Not a staggering commendation, but still, this is a significant milestone. NARA has endorsed the DoD Standard for over 16 years. And while the paper doesn’t specifically retract that endorsement, it makes it clear that NARA no longer believes the DoD model is a viable, long-term solution that they can recommend to their Federal agency customers.
Any way you look at it, the DoD 5015.2 model of enterprise records is steadily losing credibility as a solution to the information lifecycle management dilemma virtually every organization is facing today.
So if the DoD Standard model is no longer valid, the question becomes this: What does post-DoD 5015.2 Standard records management look like?
I believe there will be a number of substantial changes in a post-DoD Standard world. Changes that will revolutionize the way records management is practiced and finally turn the tide in our collective struggle to eliminate the unsustainable chaos that the explosive growth of information has caused.
Here is what I believe we can expect to see:
- The long-running and ultimately pointless debate over whether any given piece of information is a “record” or a “non-record” will end. All recorded information across the entire enterprise will become subject to retention and disposition policies. In today’s environment, all information is discoverable, all information is costly to maintain, and all information retained beyond its useful business value is a liability to the organization. Defensible disposition of all recorded information will be the primary objective of every post-DoD Standard records management solution.
- As more and more information traditionally created in an unstructured format moves into databases, the lifecycle requirements of structured information will become a greater records management focus. For example, an invoice, managed digitally as a PDF file, with a “Hold for 7 Years after Invoice Payment and Destroy” retention policy, does not lose those same information lifecycle requirements simply by transferring the information from a PDF to a database item. The requirements on that information remain the same whether it is presented in an unstructured PDF file or a structured item in a database. Post-DoD 5015.2 records management solutions will manage all information without consideration of its structure.
- The notion of a perfect information lifecycle management solution, where nothing is retained longer than necessary and nothing is destroyed prior to meeting its universally accepted retention requirements, will be totally discredited. Organizations will recognize that things will occasionally fall through the cracks, but they will also understand that the courts can never sanction a party for following its normal record retention and destruction policies and that solutions implemented according to documented organizational policies and managed and maintained in good faith, while not perfect, are good enough.
- Massive simplification will sweep through virtually every information lifecycle management process across the organization. Big Bucket retention schedules will be implemented enterprise-wide. Burdensome legacy file plans will be substantially streamlined. Multi-stage retention requirements, originally necessary for managing paper records, will be dramatically reduced or even eliminated. Requirements for the manual approval of routine records management procedures, such as disposition and transfer, will be reduced to only a small number of the most critical records series.
- Even though there will no longer be a legitimate notion of “records vs. non-records,” a small subset of every organization’s enterprise content will still require much more rigorous business rules applied over a significantly longer retention period. Some of this information will need to be maintained over several decades. And some of it will be permanent. The only realistic way to manage these “compliance records” will be in one or more electronic records repositories designed, monitored, and managed by qualified records management professionals. How these records repositories will differ from the repositories in use today is not yet clear, but they will most certainly focus much of their functionality on long-term preservation and solutions to continuing hardware and software obsolesces challenges.
- Rather than being forced to navigate across file shares, SharePoint, Box, Exchange, Alfresco, OneDrive, and on and on, solution dashboards will be used to centrally monitor and manage the lifecycle of information across disparate locations throughout the enterprise. These dashboards will also support defensible disposition by allowing records managers to audit and report on all information lifecycle activities across the entire organization.
- The information lifecycle requirements of transactional material produced by routine business activities will be baked into the process itself. This will mean the classification, security, access, retention, and disposition controls of this material will be completely accurate 100% of the time. It will also promote solution adoption by relieving end users of the burdensome records management requirements they rejected in previous solutions designed using the DoD 5015.2 model.
- Any records management process that includes a paper component - beyond the capture stage - will be rejected as fundamentally flawed and will be replaced by a cradle-to-the-grave digital lifecycle. While the dream of a paperless office may never materialize, the goal of total electronic records management across the enterprise will become realistically achievable.
- And autocategorization technology, for so long considered a science fiction fantasy by traditional records managers, will become a viable option for many enterprise records management solutions. While autocategorization accuracy rates still fall well short of 100%, the technology continues to mature quickly and post-DoD 5015.2 records management solutions are already in place that accurately categorize some organizations’ most routine and predictable material.
These are exciting times in Records and Information Management. New sources of information seemingly pop up every day. And regulations are now covering a far wider variety of information than ever before. Social media, mobility, and, in particular, the ubiquitous cloud are forcing organizations to rethink virtually every aspect of the records management solutions. Fortunately, innovative technology and revolutionary new records management practices – free of the constraints of an obsolete functional standard – will provide records management capabilities that will be more efficient at managing the information lifecycle than ever before.
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