Everything is a Record....there, I said it

By Monica Crocker posted 07-20-2012 13:55

  

It is with thanks to Mark Mandel’s latest post, The State of the Art in Records Management, Part 1, that I have the courage to state what might be regarded by some as pure records management blasphemy:  All information is a record

I came to this conclusion after I decided to simplify my life to make room for dramatic complications to it in the near future.  I decided I’d get any extraneous stuff out of the way in anticipation of those events.  I started by having a garage sale to get rid of a bunch of unnecessary “stuff.”  Then I discarded the whole “record versus non-record” argument.  It leads nowhere.  And, other than record managers, who cares?  What people REALLY want to know is “should I keep this or get rid of it?”  The answer to that question has very little to do with whether or not it’s a record. 

So, here’s the logic from an Information Governance perspective:

 

 Here’s the logic from a Records Management Perspective:

 

 So, what value did that extra step add for anyone?  As the Records Manager, I still have to manage the retention and disposition of EVERYTHING, regardless of whether or not it came out of the “Declare it a Record” step.  And our attorneys need to apply the discovery process to EVERYTHING, no matter where it falls in the decision process.  So, based on the assumption that, in order to be able to defensibly dipose of anything, it must have a retention period associated with it, everything has to have a retention period. 

I can see that delineating between records and non-records could be useful if you just don’t have the bandwidth to manage everything and want to limit your scope to just “records.”  Or it might be used as a tool to keep you in line by anyone that doesn’t want you to have authority to manage “everything.” Declaring some stuff “non-records” is a way for them to avoid any oversight of how they manage that “other” information.  When I proposed the governance model for SharePoint, one counter proposal was “Can’t we just say nothing in SharePoint is a record and therefore SharePoint content is excluded from the Records Management policy?”  Um, no…not even remotely an option.

The downside to the whole records/non-records distinction is that we tell users to go to the Records Retention Schedule to figure out how long to keep things.  If we exclude non-records (Convenience Copies, Transitory Communications) from that schedule, do they need to go to yet another document to get instructions on what to do with that information?  And if we include non-records on the schedule, then we need to rename the schedule, because we’ve just listed stuff on it that isn’t a record.  A comprehensive retention policy dictates disposition of all information, even the stuff that isn’t a record.  So, as long as you have one schedule that dictates whether or not to keep something and one set of procedures that explain how to do that (keep it or get rid of it), is there any need to apply a “record” or “non-records” label during the life cycle of the information?

So, here’s my best impersonation of Linda Richman from CoffeeTalk:*

”Records Retention; it’s neither about records, nor retention…discuss.”  

(Answer: It’s really about information life cycle.)

I’m testing the waters here in the AIIM forum, then I’ll put forth this theory during my sessions at the ARMA Conference …..wish me luck. 

* see http://en.wikipedia.org/wiki/Coffee_Talk for a listing of other Coffee Talk discussion topics. Hysterical.



#retention #ElectronicRecordsManagement #non-record #CoffeeTalk #disposition #authority #InformationGovernance #record
13 comments
723 views

Comments

02-28-2015 16:34

I have always believed that everything is a record. If it can be requested during an evidentiary hearing it will make no difference if it has or hasn't been declared a record. Duplication of data is a different monster which may occur even if you have declared a document a record, and there are technologies that can help us deal with that. The bigger concern should be how do I apply a retention policy to a record that may contain documents that are digital, physical and may be spread across the organization. We can no longer look at records from the physical or location perspective.

07-31-2012 19:54

Isn't the reason why we declare pieces of information as 'records' so that we know which is the reliable and authentic source?
I agree that the end user shouldn't need to worry about defining exactly what a record is but that's why, as Records Managers, we put control systems, policies and rules in place. If we allow everything to squeeze past, control will be lost. We will not be able to trust the authenticity of the information.
Imagine having 20 copies of the same piece of information, some with newer, slightly different versions made of them at different times by different people, others with no changes made. How do we trust the authenticity of the information? Which is the true copy? There needs to be a true source ‘record’ that must be retained as the reliable and authentic document of the transaction. Keep all the other copies if you want but I can only see it making the job of the Records manager even harder in the future.

07-31-2012 10:32

http://www.aiim.org/community/blogs/expert/Does-record-or-non-record-really-matter#c92e8178-45d3-4bc6-bdd2-78f9a8ac2ad5

07-27-2012 17:45

That I am going to carry this discussion forward in my next blog...

07-26-2012 16:02

Monica, welcome aboard the State of the Art of Records Management. Even in the federal government this redefinition of a record applies - it is more relevant than ever, especially with the new directives about to be released from NARA and OMB in response to the Obama memo on Managing Government Records.
The world is moving to Big Buckets - with one of those being Transitory or Non-Records - by the way these are already in the NARA General Records Schedule. This approach allows you to explcitly call out those objects that are not considered business records so you can delete them in a defensible way. Like email, drafts, copies, etc. - just doing this means you can clean the clutter out in a systematic and defensible way, using new technology like auto classification.
Those that resist this wave will be left in the basement.

07-25-2012 16:25

I agree that all information must be managed - have some retention requirement - from none to forever. However, there is some information that must be declared unalterable. So the end-user must not only ask "do I need to keep it" but in some instances "must this document be protected from change". When a brief is submitted to a court the user must then declare that electronic version that was submitted as a record - unalterable. So I believe the concept of "record" still has validity in this context.

07-25-2012 13:46

Let me just say...this has been a VERY stimulating conversation. I hope they all spark this level of interest. Yep, there are convenience copies and there are originals. That's one step towards answering the "what do I do with this?" question. But knowing the original is a "record" does not dictate what to do with it, so it doesn't help manage the information. The next question is "do I need to keep it?" The answer to that question is based on the retention period or whether or not it is subject to a Legal Hold, which, again has nothing to do with whether or not it's a record. When it comes down to "figuring out what to do with this piece of information" labeling it as a "record" does not help the average business user. You did point out a flaw in my diagram, however....I need to switch the order of the last two questions so that you only ask "Do I have any use for this?" if the answer to "Do I need to keep this?" is NO. Because, if it's a convenience copy under Legal Hold, you need to keep it, regardless of how useful it is.

07-25-2012 13:33

In your flow chart the first decision has this question,"Is it a convenience copy?" When dealing with electronic files, what is your criteria for determining whether the electronic document I am looking at is a convenience copy? Doesn't that presuppose that somewhere there is the "official" document, hence one that represents the "official record" - for example: the brief that was submitted to the court?

07-24-2012 15:11

You actually more concisely said what I stated in my blog post, "Are you a Records Manager or Information Governance Office?" http://www.aiim.org/community/blogs/community/Are-You-A-Records-Manager-Or-Information-Governance-Officer
In my job I am in a slightly different boat as we are training people to manage their own records. Hence the need to simplify and why I can't call everything a record or that would add confusion as I train non-records managers on how to manage their records.

07-24-2012 14:27

Exactly! So, since the differentiation between record and non-record is meaningless, and, since (a) I want to keep my job as "Records Manager" so I need people to think we have some records to manage and (b) I don't see anyone else stepping up to govern information (either records or non-records), then I guess it's my job to manage all information, thus, everything is a record. Or, we get the entire industry to change the term "records management" to "information governance" and I get a new title. Which was the subliminal objective of this post. The REAL point is, nothing is out of scope for the records management program; it all has to be managed, even the stuff you don't keep.

07-24-2012 13:21

You can treat everything as a record without it actually being a record, which is why I pointed out the irony of my agencies records control schedule having non-records and reference materials. You hit the nail on the head when you said: "if we include non-records on the schedule, then we need to rename the schedule, because we’ve just listed stuff on it that isn’t a record. A comprehensive retention policy dictates disposition of all information, even the stuff that isn’t a record."
Honestly, I hate the term "record." Just because something is a record doesn't mean it has the qualities of a record. The bureaucracy and red tape of the organization that we comply to puts us in the box of that terminology for compliance purposes.
I am not against everything being a record, but for the purpose of simplifying and helping users to know what documents they are the office of record over and what they are custodians over it definitely serves a purpose.
Governance looks at the big picture which is why the distinction can be thrown away.

07-24-2012 12:15

I understand the government paradigm towards managing records. My many years in state government planted the "everything is a record" idea seed. Since government regulations state that "agencies shall keep records of all activities" and that records can only be disposed of "in accordance with a retetion schedule" then, technically, government agencies should list EVERYTHING on a retention schedule (even what you consider "non-records") so that ANYTHING can ever be disposed of. Otherwise, it's not on the schedule, so you can never dispose of it. Treating everything as a record gives you the flexibility to determine how long (or short) a time period information is kept and what does and does not get transferred to the NARA. Otherwise, you end up explaining to Congress why you can't produce all those emails without any authorization to back you up.

07-24-2012 11:53

Inside a bubble, the whole idea of everything being a record might be able to fly. In the federal government, for example, bureaucracy and red tape means that clear markers need to be set up to define what is a record and what isn't a record. One such example is that federal agencies have to comply with the federal records act which explicitly defines what a record is in the code of federal regulations. Federal agencies also have to answer to the National Archives and Records Administration who will shun those that transfer to them non-records.
Ironically enough, NARA did approve a FDA records schedule that has a records series called "Reference Materials" with the following scope note: "Non-records materials..."