November 19, 1998
MEMORANDUM TO AGENCY RECORDS OFFICERS AND INFORMATION RESOURCE MANAGERS: NARA endorsement of DoD 5015.2-STD.
On November 18, 1998, the Archivist of the United States sent a letter to the Assistant Secretary of Defense (Command, Control, Communications, and Intelligence), stating that Department of Defense (DoD) 5015.2-STD, Design Criteria Standard for Electronic Records Management Software Applications ( DoD standard), conforms with the requirements of the Federal Records Act and the implementing records management regulations found in 36 Code of Federal Regulations, 1220-1238. The letter also stated that NARA would inform other Federal agencies that we endorse the DoD standard as establishing baseline requirements for automated record keeping. A copy of that letter is attached.
We are very pleased to be able to point to our partnership with DoD as an example of an effective collaboration that may provide benefits to the Federal government beyond our two agencies. NARA has worked closely with DoD on the DoD standard from the start, and our review of the standard was a second step in the process to see if we could recommend its use beyond DoD. This memorandum notifies you that we can. The third step, NARA's review of the software certification testing process, is under way and should be completed in the second quarter of FY 1999. We will report the results of that review in a future memorandum to records officers. For now, we must emphasize that NARA endorsement of the standard is not equivalent to endorsement of RMA software that has been certified as compliant with the DoD standard by the Joint Interoperability Test Command (JTIC) of the Defense Information Systems Agency.
Our endorsement approves the current DoD standard as one possible approach to managing electronic records. There may be other equally valid ways of doing things, especially in the area of automating individual work processes. NARA is working to facilitate the transition to electronic recordkeeping in the Federal sector. However, before moving to any electronic recordkeeping, agencies should fully investigate whether their business needs and the existing technology make electronic recordkeeping a good choice now. Agencies that want to begin the process of moving to electronic recordkeeping are encouraged to review this standard to see whether it will meet their needs.
This memorandum provides additional important information you will need if you decide to adopt or use the DoD standard to design an electronic recordkeeping system or to acquire commercial records management software products for your agency.
1. The functional criteria in the DoD standard, taken together,
represent an appropriate starting point for an automated records management
system, but they do not cover all aspects of the records life cycle.
The DoD standard is not a static document. It will be subject to periodic revision and NARA review of those changes. Already, NARA and DoD have agreed informally that two optional criteria in the current standard should be made mandatory in the next version. Optional requirement C3.2.11 is for a thesaurus to provide vocabulary control to be used by end users to help group records and is a means of minimizing errors in records management metadata entry. (While NARA believes that vocabulary control is an essential criterion, a thesaurus may not be the only way to achieve it.) Optional requirement C3.2.3, requiring the records management application (RMA) to have the capability to store and link different versions of the same record in the repository, would afford end users the ability to distinguish between versions of the same record. If you implement an RMA based on the current 5015.2-STD, we strongly encourage you to include these optional requirements in the software functionality specification.
DoD is also working on an extension to the standard to address national security classification marking and redaction. NARA is working with DoD to extend a future version of the standard to include transfer of permanent records to NARA.
2. The DoD standard and commercial RMA software packages are not
"out-of-the box" easy or quick solutions for managing your electronic
RMA software only operates in the context of an agency's records management program, policies, and procedures. For example, the DoD standard specifies "e-mail name" as part of the recordkeeping metadata associated with e-mail records. NARA's Office of General Counsel has interpreted the Armstrong v. EOP decision to require an intelligent representation of the e-mail account name (i.e., "Michael Miller" as opposed to "mmiller"). An RMA cannot do this automatically unless the e-mail package provides it. Steps must be taken when implementing an RMA built to 5015.2-STD specifications to ensure that intelligent representation of an e-mail userid account name is captured, either via modification of the automated interaction between the e-mail package and the RMA, or via implementation procedures requiring end users to supplement the information automatically passed between the applications.
DoD is developing a manual detailing procedures specific to the DoD environment to accompany the implementation of records management software to ensure that all of the statutory and regulatory requirements for managing Federal records are satisfied, including e-mail name representation and development of system administration procedures to minimize the persistence of deleted records on disaster recovery backups. Each agency must address the capabilities and limitations of the software package it selects and will need to update its procedures and train its users.
3. The DoD functional criteria need to be considered in toto, not
as individual choices.
If your system specifications for an electronic recordkeeping system do not include all of the DoD functional criteria, your system may not meet all of the requirements of the Federal Records Act and NARA regulations. Our review of the DoD standard to ensure that it met legal requirements was lengthy and detailed, and we are convinced that it is a standard that can be used by other agencies that are ready to begin implementing automated recordkeeping now. NARA does not have the staff resources necessary to conduct similar detailed reviews of individual agency recordkeeping system specifications at the same time as we work to develop electronic records management guidance that benefits all agencies. Therefore, we will concentrate our efforts in the next year on electronic records partnerships and activities that have the potential for wide applicability.
NARA endorsement of DoD standard 5015.2-STD represents the beginning, and only one of the many NARA activities related to electronic records management. Internally, NARA is organizing and broadening the records management framework of its guidance and policy to address electronic records management issues. This effort, in part, requires the identification of salient records management questions related to each phase of the record life cycle for various formats of electronic records (e.g., text records, spreadsheets, video, databases, etc.). Some of the questions related to this framework have already been identified by previous research funded by NARA's National Historical Publications and Records Commission. Some will be identified and addressed in other venues.
Collaboration with the Department of Defense is another important mechanism by which NARA will advance electronic records management capability. DoD 5015.2-STD is an important, incremental step in addressing such issues. Next steps include completion of the NARA evaluation of the JITC software certification testing program and working with DoD to extend the existing standard to incorporate other records management functionalities. As the Archivist of the United States detailed in his September 21 statement in response to the report of the Electronic Records Work Group, there are a number of other joint projects with DoD that will further work in the arena of electronic records management, such as: working with the Defense Advanced Research Projects Agency to use the power of supercomputers to test records life-cycle management solutions for large quantities of data and working with the Army Research Laboratory on tools available to process records generated by office automation software.
Finally, as recommended by the Electronic Records Work Group, NARA is also establishing a follow-on group to begin the systematic development of necessary guidance on electronic records management issues. We will continue to inform you of additional developments regarding these and other partnerships. Please monitor NARA's web site for background information as well as recent documents on this topic.
MICHAEL L. MILLER
Modern Records Programs