GAO For Release on Delivery Expected at 2 00 p m EDT June 17 2010 United States Government Accountability Office Testimony Before the Subcommittee on Informatio Policy Census and National Archives Committee on Oversight and Governme Reform House of Representatives INFORMATION MANAGEMENT The Challenges of Managing Electronic Records Statement of Valerie C Melvin Director Information Management and Human Capital Issues GAO-10-838T June 17  2010 Highlights Accountability Integrity Reliability INFORMATION MANAGEMENT  The Challenges of Managing Electronic Records  Highlights of GAO­10­838T  a testimony  before the Subcommittee on Information  Policy  Census and National Archives   Committee on Oversight and Government  Reform  House of Representatives  Why GAO Did This Study What GAO Found Federal agencies are increasingly using electronic means to create exchange and store information and in doing so they frequently create federal records that is information in whatever form that documents government functions activities decisions and other important transactions As the volume of electronic information grows so does the challenge of managing electronic records Both federal agency heads and the National Archives and Records Administration NARA have responsibilities for managing federal records Under the Federal Records Act agencies are to manage the creation maintenance use and disposition of records in order to achieve adequate proper documentation of the policies and transactions of the federal government and effective and economical management of agency operat If records are poorly managed individuals might lose access to benefits fo which they are entitled the government could be exposed to legal liabiliti and records of historical interest could be lost forever NARA is responsible among other things for providing records management guidance assistan and oversight However as GAO has previously reported records management has recei low priority within the federal government Prior reports have identified persistent weaknesses in federal records management including a lack of policies and training GAO’s most recent report in 2008 found weaknesse e-mail management at the four agencies reviewed due in part to insufficie oversight and training This year NARA published the results of its first As requested after providing some annual agency records management self-assessment survey indicating th context about records management almost 80 percent of agencies were at moderate to high risk of improper in the federal government and the disposition of records roles of federal agencies and NARA this testimony describes the Electronic records are challenging to manage especially as electronic challenges of electronic records information is being created in volumes that pose a significant technical management and potential means challenge to the ability to organize and make it accessible Further electr of addressing these challenges records range in complexity from simple text files to highly complex forma with embedded computational formulas and dynamic content and new In preparing this testimony GAO formats continue to be created Finally in a decentralized environment it relied primarily on its previous difficult to ensure that records are properly identified and managed by en work supplemented by analysis of users on individual desktops the “user challenge” E-mail is particularly publicly available documents problematic because it combines all these challenges and is ubiquitous View GAO­10­838T or key components   For more information  contact Valerie C   Melvin   202  512­6304  melvinv@gao gov   Technology alone cannot solve the problem without commitment from agencies Electronic recordkeeping systems can be challenging to implem and can require considerable resources for planning and implementation including establishing a sound records management program as a basis I addition the “user problem” is not yet solved particularly for e-mail messages Further automation will not solve the problem of lack of priorit which is of long standing However several developments may lead to increased senior-level attention to records management NARA’s use of pu ratings as a spur to agency management growing recognition of risks ent in poor information and records management the requirements and emph of the recent Open Government Directive and the influence of congressio oversight Senior management commitment if followed through with effe implementation could improve the governmentwide management of electronic and other records United States Government Accountability Office Mr Chairman and Members of the Subcommittee I appreciate the opportunity to discuss critical issues surrounding electronic records management in the federal government As you are aware federal agencies are increasingly using electronic mean to create exchange and store information and in doing so they frequently create federal records According to the Federal Record Act 1 federal records are information in whatever form that documents government functions activities decisions and other important transactions and such records must be managed and preserved in accordance with the2 As act the volume of electronically stored information grows so does the challenge of managing electronic records As requested after providing some context about records management in the federal government and the roles of federal agencies and the National Archives and Records Administration NARA my statement will focus on describing the challenges of electronic records management and potential means of addressing these challenges My comments today are based primarily on our previous work all which was conducted in accordance with generally accepted government auditing standards supplemented by analysis of information contained in publicly available documents following appropriate GAO quality assurance processes Background The federal government collects generates and uses large amoun of information in electronic form from enormous geographic databases to individual e-mails Much of that information can constitute official federal records and agencies must have ways to manage such records 1 44 U S C chapters 21 29 31 and 33 2 The definition of a record is given at 44 U S C 3301 Page 1 GAO-10-838T Federal Agencies and NARA Have Responsibilities for Federal Records Managemen 3 Under the Federal Records Act each federal agency is required to make and preserve records that 1 document the organization functions policies decisions procedures and essential transactio of the agency and 2 provide the information necessary to protec the legal and financial rights of the government and of persons 4 directly affected by the agency’s activities If these records are not effectively managed individuals might lose access to benefits for which they are entitled the government could be exposed to lega liabilities and historical records of vital interest could be lost forever In addition agencies with poorly managed records risk increased costs when attempting to search their records in respon to Freedom of Information Act requests or litigation-related discovery actions Finally without effective management of the documentation of government actions the ability of the people to hold the government accountable is jeopardized Effective records management is also an important tool for efficien government operation Without adequate and readily accessible documentation agencies may not have access to important operational information to make decisions and carry out their missions 5 Accordingly to ensure that they have appropriate recordkeeping systems with which to manage and preserve their records agenci 6 are required to develop records management programs These programs are intended among other things to provide for accurat and complete documentation of the policies and transactions of each federal agency to control the quality and quantity of records they produce and to provide for judicious preservation and dispos of federal records 3 44 U S C chapters 21 29 31 and 33 4 44 U S C § 3101 5 See generally Standards for Internal Control in the Federal Government GAO AIMD00-21 3 1 Washington D C November 1999 6 44 U S C § 3102 Page 2 GAO-10-838T Among the activities of a records management program are identifying records and sources of records and providing records management guidance including agency-specific recordkeeping practices that establish what records need to be created in order t conduct agency business Under the Federal Records Act and the regulations issued by NARA records must be effectively managed throughout their life cycle which includes records creation or receipt maintenance and use and disposition Agencies create records to meet the business nee and legal responsibilities of federal programs and to the extent known the needs of internal and external stakeholders who may make secondary use of the records To maintain and use the records created agencies are to establish internal recordkeeping requirements for maintaining records consistently apply these requirements and establish systems that allow them to find record that they need Disposition involves transferring records of permanent historical value to NARA for archiving and destroying a other records that are no longer needed for agency operations One key records management process is scheduling the means b which NARA and agencies identify federal records and determine time frames for disposition Creating records schedules involves identifying and inventorying records appraising their value determining whether they are temporary or permanent and determining how long records should be kept before they are destroyed or turned over to NARA for archiving For example one general records schedule permits civilian agencies to destroy case 7 files for merit promotions 2 years after the personnel action is completed or after an audit by the Office of Personnel Manageme whichever is sooner No record may be destroyed or permanently transferred to NARA unless it has been scheduled so the schedule of critical importance Without schedules agencies would have no clear criteria for when to dispose of records and to avoid disposin of them unlawfully would have to maintain them indefinitely 7 That is records relating to the promotion of an individual that document qualification standards evaluation methods selection procedures and evaluations of candidates Su records are covered under the General Records Schedule 1 Civilian Personnel Records Page 3 GAO-10-838T Scheduling records electronic or otherwise requires agencies to invest time and resources to analyze the information that an agen receives produces and uses to fulfill its mission Such an analysis allows an agency to set up processes and structures to associate records with schedules and other information metadata to help i find and use records during their useful lives and dispose of those no longer needed Records schedules are based on content and are media-neutral th is electronic records are classified on the same basis—by content as physical records In addition agencies are to compile inventorie of their information systems after which the agency is required to develop a schedule for the electronic records maintained in those systems NARA also has responsibilities related to scheduling records NARA works with agencies to help schedule records and it must approve all agency records schedules It also develops and maintains gene records schedules covering records common to several or all agencies According to NARA records covered by general records schedules make up about a third of all federal records For the oth two thirds NARA and the agencies must agree upon agency-specifi records schedules Under the Federal Records Act NARA is given general oversight responsibilities for records management as well as general responsibilities for archiving—the preservation in the National Archives of the United States of permanent records documenting 8 the activities of the government Of the total number of federal records less than 3 percent are permanent However under the a and other statutes some of the responsibilities for oversight over federal records management are divided across several agencies Under the Federal Records Act NARA shares a number of records management responsibilities and authorities with the General 8 44 U S C § 2904 Relevant NARA regulations implementing the Federal Records Act are found at 36 C F R §§ 1220–1238 Page 4 GAO-10-838T 9 Services Administration GSA The Office of Management and Budget OMB also has records management oversight 10 responsibilities under the Paperwork Reduction and Act the E11 Government Act For records management NARA is responsible for issuing guidance working with agencies to implement effective controls over the creation maintenance and use of records in the conduct of agenc business providing oversight of agencies’ records management programs approving the disposition destruction or preservation records and providing storage facilities for agency records The ac also gives NARA the responsibility for conducting inspections or surveys of agency records and records management programs Federal Records Management Has Been Given Low Priority and Has Had Persistent Weaknesses Historically despite the requirements of the Federal Records Act records management has received low priority within the federal government As early as 1981 in a report entitled Federal Records 12 Management A History of Neglect we stated that “persistent records management shortcomings” had been attributed to cause that included “lack of commitment by top management emphasis on agency missions and the low priority of records management ” Almost 30 years later the priority problem has remained remarkab persistent For instance a 2001 study prepared for NARA by SRA Internationa Inc on perceptions in the federal government with respect to records management concluded that recordkeeping and records 9 These shared responsibilities are due in part to the origins of NARA The 1984 National Archives and Records Administration Act Pub L No 98-497 98 Stat 2280 Oct 19 198 transferred the functions of GSA’s National Archives and Records Service to the newly created NARA 10 See 44 U S C § 3504 11 See 44 U S C § 3602 12 GAO Federal Records Management A History of Neglect PLRD-81-2 Washington D C Feb 24 1981 Page 5 GAO-10-838T management in general receive low priority as evidenced by lack staff or budget resources absence of up-to-date policies and 13 procedures lack of training and lack of accountability This assessment also concluded that although agencies were creating and maintaining records appropriately most electronic records remained unscheduled and records of historical value were not being identified and provided to NARA for archiving In 2002 drawing on the 2001 study we reported that the low prio given to records management programs was a factor in program 14 weaknesses We noted that records management is generally considered a “support” activity Because support functions are typically the most dispensable in agencies resources for and focu on these functions are often limited In 2008 we reported on weaknesses in federal e-mail managemen 15 at four agencies The four agencies reviewed generally managed email records through paper-based processes rather than using electronic recordkeeping A transition to electronic recordkeeping was under way at one of the four agencies and two had long-term plans to use electronic recordkeeping We attributed weaknesses agency e-mail management such as senior officials not conformin to regulations to factors including insufficient training and oversight regarding recordkeeping practices as well as the onerousness of handling large volumes of e-mail —similar to the effects of low priority described by SRA Accordingly we recommended that agencies with weaknesses in oversight policie and practices develop and apply oversight practices such as reviews and monitoring of records management training and practices that would be adequate to ensure that policies were 13 SRA International Inc Report on Current Recordkeeping Practices within the Federal Government Dec 10 2001 www archives gov records-mgmt faqs pdf report-onrecordkeeping-practices pdf This document reports on both a recordkeeping study performed by SRA International and a series of records system analyses performed by NARA staff 14 GAO Information Management Challenges in Managing and Preserving Electronic Records GAO-02-586 Washington D C June 17 2002 15 GAO Federal Records National Archives and Selected Agencies Need to Strengthen E Mail Management GAO-08-742 Washington D C June 13 2008 Page 6 GAO-10-838T effective and that staff were adequately trained and were implementing policies appropriately Further evidence of the persistence of the priority issue was provided in 2008 when NARA surveyed federal senior managers about their perception of records management According to the survey only 64 percent of managers saw records management as useful tool for mitigating risk In April 2010 NARA released a report on its first annual records management self-assessment which analyzed responses to a surv sent in September 2009 to 245 federal cabinet-level agencies age 16 components and independent agencies According to NARA the survey results showed that almost 80 percent of agencies were at 17 moderate to high risk of improper disposition of records For example the survey found that not all agencies had appropriate policies in place for handling e-mail and that only a little over half of the responding agencies had training in place for high-level executives and political appointees on how to manage e-mail this consistent with the finding in our 2008 report on e-mail practices regarding insufficient training and oversight regarding recordkeeping practices NARA rated almost half of the responding agencies 105 of 221 as high risk in the area of e-mail NARA’s survey also indicated among other things that a large proportion of agencies have not scheduled existing systems that contain electronic records In December 2005 NARA issued a bulletin requiring agencies to have NARA-approved records schedules for all records in existing electronic information systems by September 30 2009 27 percent of agencies responding to NAR 16 NARA Records Management Self-Assessment 2009 An Assessment of Records Management Programs in the Federal Government April 2010 220 agencies responde for a response rate of 91 percent 17 NARA assessed risk by calculating a weighted score based on agencies’ responses to t 34 survey questions Scores above 90 of 100 possible points are considered low risk 60 89 are moderate risk and below 60 are high risk NARA also identified issues that impac the reliability of the data including not covering the full universe of agencies issues rela to the roles of department vs component-level records officers and problems involving some questions being unclear NARA did not validate agencies’ self-reported results Page 7 GAO-10-838T September 2009 agency self-assessment survey indicated that few than half of their electronic systems were scheduled Such large numbers of unscheduled systems are a problem for agencies because their records cannot legally be disposed of with the consequences for increased cost and risk mentioned earlier NARA concluded that the varying levels of agency compliance with its records management regulations and policies have implications for the government’s effectiveness and efficiency in conducting its business protecting citizens’ rights assuring government accountability and preserving our national history Our Previous Reports Have Recommended Strengthening NARA’s Oversight Approa The Federal Records Act gave NARA responsibility for oversight of agency records management programs by among other functions making it responsible for conducting inspections or surveys of agencies’ records and records management programs and practice conducting records management studies and reporting the results of these activities to the Congress and 18OMB We have made recommendations to NARA in previous reports that were aimed at improving NARA’s insight into the state of federal records management as a basis for determining where its attentio is most needed In 1999 in reporting on the substantial challenge managing and preserving electronic records in an era of rapidly 19 changing technology we noted that NARA did not have governmentwide data on the electronic records management capabilities and programs of all federal agencies Accordingly we recommended that NARA conduct a governmentwide survey of these programs and use the information as input to its efforts to reengineer its business processes However instead of doing a governmentwide baseline assessment survey as we recommended 18 In particular the reports are to include evaluations of responses by agencies to any recommendations resulting from inspections or studies that NARA conducts and to the extent practicable estimates of costs to the government if agencies do not implement s recommendations 19 GAO National Archives Preserving Electronic Records in an Era of Rapidly Changing Technology GGD-99-94 Washington D C July 19 1999 Page 8 GAO-10-838T NARA planned to obtain information from a limited sample of agencies stating that it would evaluate the need for such a survey later 20 In 2002 we reported that because NARA did not perform systema inspections of agency records management it did not have comprehensive information on implementation issues and areas 21 where guidance needed strengthening We noted that in 2000 NARA had suspended agency evaluations inspections because it considered that these reached only a few agencies were often perceived negatively and resulted in a list of records managemen problems that agencies then had to resolve on their own Howeve we concluded that the new approach that NARA initiated targeted assistance did not provide systematic and comprehensive information for assessing progress over time Only agencies requesting assistance were evaluated and the scope and focus of the assistance were determined not by NARA but by the requestin agency Accordingly we recommended that it develop a strategy for conducting systematic inspections of agency records management programs to 1 periodically assess agency progress improving records management programs and 2 evaluate the efficacy of NARA’s governmentwide guidance In response to our recommendations NARA devised a strategy for comprehensive approach to improving agency records manageme that included inspections and identification of risks and priorities Subsequently it also developed an implementation plan that included undertaking agency inspections based on a risk-based 22 model government studies or media reports 20 In 2001 as mentioned earlier the NARA-sponsored SRA study was released www archives gov records-mgmt faqs pdf report-on-recordkeeping-practices pdf This document reports on both a recordkeeping study performed by SRA and a series ds of reco system analyses performed by NARA staff 21 GAO Information Management Challenges in Managing and Preserving Electronic Records GAO-02-586 Washington D C June 17 2002 22 GAO Electronic Records Archives The National Archives and Records Administration’s Fiscal Year 2006 Expenditure Plan GAO-06-906 Washi ngton D C Aug 18 2006 Page 9 GAO-10-838T In 2008 we reported that under its oversight strategy NARA had performed or sponsored six records management studies in the previous 5 years but it had not conducted any inspections since 2000 because it used inspections only to address cases of the 23 highest risk and no recent cases met its criteria In addition NARA’s reporting to the Congress and OMB did not consistently provide evaluations of responses by federal agencies to its recommendations as required or details on records management problems or recommended practices that were discovered as a result of inspections studies or targeted assistance projects Accordingly we recommended that NARA develop and implement an oversight approach that provides adequate assurance that agencies are following NARA guidance including both regular assessments of agency records and records management program and reporting on these assessments NARA agreed with our recommendations and devised a strategy that included annual sel assessment surveys inspections and reporting It has now begun implementing that strategy having released the results of its first governmentwide self-assessment survey as mentioned earlier Managing Records in Electronic Form Presents Major Challenges 24 As we have previously reported electronic records pose major management challenges their volume their complexity and the increasingly decentralized environment in which they are created mail epitomizes the challenge as it is not only voluminous and complex but also ubiquitous ● Huge volumes of electronic information are being created Electronic information is increasingly being created in volumes tha pose a significant technical challenge to our ability to organize it a 23 GAO Federal Records National Archives and Selected Agencies Need to Strengthen E Mail Management GAO-08-742 Washington D C June 13 2008 24 GAO Information Management Challenges in Managing and Preserving Electronic Records GAO-02-586 Washington D C June 17 2002 Page 10 GAO-10-838T make it accessible An example of this growth is provided by the difference between the digital records of the George W Bush administration and that of the Clinton administration NARA has 25 reported that the Bush administration transferred 77 terabytes of data to the Archives on leaving office which was about 35 times t amount of data transferred by the Clinton administration Another example is the Department of Energy’s National Energy Research Scientific Computing Center which said that as of January 2009 i had over 3 9 petabytes of data that is about 4 000 000 000 000 bytes in over 66 million files and that the volume of data in storag 26 doubles almost every year ● Electronic records are complex Electronic records have evolved from simple text-based files to complex digital objects that may contain embedded images still a moving sounds hyperlinks or spreadsheets with computational formulas Some portions of electronic records such as the content of dynamic Web pages are created on the fly from databases and exist only during the viewing session Others such as e-mail may contain multiple attachments and they may be threaded that is related e-mail messages are linked into send–reply chains They may depend heavily on context For example to understand the significance of an e-mail we may need to know not only the ident but the position in the agency of the sender and recipients Was i sent by an executive or a low-level employee In addition new technologies such as blogs wikis tweets and social media continue to emerge posing new challenges to records managers ● Identification and classification of electronic records are difficult in a decentralized computing environment The challenge of managing electronic records significantly increas with the decentralization of the computing environment In the centralized environment of a mainframe computer it is 25 A terabyte is about 1 trillion bytes or 1000 gigabytes 26 We did not verify the specific numbers which are provided for illustrative purposes on Page 11 GAO-10-838T comparatively simple to identify assess and manage electronic records However in the decentralized environment of agencies’ office automation systems every user can create electronic files o generally unstructured data that may be formal records and thus should be managed Documents can be created on individuals’ desktop computers and stored on local hard drives E-mail can com from outside the agency In cases like these the agency generally depends on the individual to identify the document or the e-mail a record and through placing it in a recordkeeping system associa it with its appropriate schedule make it searchable and retrievable and preserve it until it is due for disposal 27 As we reported in 2008 e-mail is especially problematic E-mail embodies several major challenges to records management ● It is unstructured data and it can be about anything or about several subjects in the same message making it difficult to classif by content ● There is a very large volume of it one study estimates that a typic 28 corporate user sends or receives around 110 messages a day Further there may be many copies of the same e-mail which can increase storage requirements or require a means of determining which copy to keep Keeping large numbers of messages potential increases the time effort and expense needed to search for information in response to a business need or an outside inquiry such as a Freedom of Information Act request ● It is complex e-mail records may have multiple attachments in a variety of formats they may include formatting that is important f meaning and they include information about senders recipients and time of sending Recordkeeping systems must be able to capt all this information and must maintain the association between the e-mail and its attachment s 27 GAO Federal Records National Archives and Selected Agencies Need to Strengthen E Mail Management GAO-08-742 Washington D C June 13 2008 28 The Radicati Group Inc Email Statistics Report 2010 Palo Alto Calif April 2010 Page 12 GAO-10-838T ● Its relevance depends on context It may be part of a message thr that is necessary to understand its content or it may discuss othe documents or issues that are not well identified An e-mail that sa “I agree Let’s do it” may be about a major decision or about going lunch next week ● It may not be obvious who is responsible for identifying an e-mail a record and at what point NARA regulations require that both senders and recipients may be responsible for identifying records However an e-mail may have multiple recipients and be forwarde to still other recipients Agency Commitment Is a Prerequisite for Addressing the Electro Records Challenge As NARA has pointed out the decision to move to electronic recordkeeping is inevitable but as we and NARA have previously reported implementing such systems requires that agencies comm the necessary resources for planning and implementation includin establishing a sound records management program as a basis Further automation will not at least at the current state of the technology solve the “end user problem”—relying on individual users to make sound record decisions Nor will automation solve th problem of lack of priority which as our previous work has shown is of long standing However several developments could lead to increased senior-level attention to records management NARA’s u of public ratings as a spur to agency management growing recognition of risks entailed in poor information and records management the requirements and emphasis of the recent Open Government Directive and the influence of congressional oversigh Senior management commitment if followed through with effectiv implementation could improve the governmentwide management electronic and other records Electronic Recordkeeping Systems Are Challenging to Implement and Will Not Yet S the End User Problem Moving to electronic recordkeeping is not a simple or easy process Agencies must balance the potential benefits against the costs of Page 13 GAO-10-838T redesigning business processes and investing in technology Our previous work has shown that such investments like any information technology investment require careful planning in the context of the specific agency’s circumstances in addition to wellmanaged implementation In 2007 a NARA study team examined the experiences of five federal agencies including itself with electronic records management applications with a particular emphasis on how thes organizations used these applications to manage29e-mail Among the major conclusions was that although the functionality of the software product itself is important other factors are also crucial such as agency culture and the quality of the records managemen program in place With regard to e-mail in particular the survey concluded that for some agencies the volume of e-mail messages created and received may be too overwhelming to be managed at the desktop by thousands of employees across many sites using a records management application alone A follow-up study in 2008 added that although a records management application offers compliant electronic recordkeeping “it can be expensive to acquir time consuming to prepare for and implement requires user intervention to file records and can be costly over the long haul fo 30 data migration and system upgrades ” NARA found that in most instances agencies had to work to overcome user resistance to us the system This user challenge has led records management experts to believ that end users cannot be relied on to manage e-mail records or indeed any other types of records A recent Gartner study conclud that user-driven classification of records especially e-mail has 31 failed and will continue to fail a study by the Association for 29 NARA A Survey of Federal Agency Records Management Applications 2007 Jan 22 2008 30 NARA Continuing Study of Federal Agency Recordkeeping Technologies 2008 Washington D C 2008 31 Gartner Research How to Address the Federal Government’s Records Management Challenges G00165869 Mar 14 2009 Page 14 GAO-10-838T 32 Information and Image Management AIIM stated “it is simply not plausible to expect all creators of records to perform accurate 33 manual declaration and classification ” According to Gartner “What enterprises really need and want is a mechanism that automatically classifies messages by records management type … 34 without user intervention ” At the time of writing August 2007 Gartner described such technology as “in its infancy ” but expecte it to mature rapidly because of high demand This technology automated records classification sometimes call “autocategorization” might help address the user problem The 35 Force is currently working with autocategorization projects However like other information technology it requires resources for setup and maintenance to be effective and it is not simple to 36 implement Further according to AIIM autocategorization might not work for an agency’s particular documents or file plan and might not be sufficiently accurate or cost effective Some proposals have been made to simplify the e-mail problem Gartner recommends treating e-mail as a separate issue from general records management perhaps by putting all e-mail in a single category of temporary records with a uniform retention period Similarly the Director of Litigation in NARA’s Office of General Counsel has suggested keeping all e-mail created by key 32 AIIM is a nonprofit organization focused on the management of documents content records and business processes as well as enterprise content management ECM 33 Richard Medina David Gaffaney and Linda Andrews “Autocategorization One Key Component for Enterprise Records Management ” AIIM E-Doc Magazine Vol 20 Iss 4 July August 2006 34 Gartner Research Best Practices in Records Management FAQs G00149526 Aug 17 2007 35 Michael Corrigan and J Timothy Sprehe “Intelligent Categorization Air Force Information Asset Management ” presentation delivered at FIRM Council March Program Mar 4 2010 http www digitalgovernment com Downloads E-Discovery-Records-Information-Management-Conference shtml 36 Automated classification systems may for example depend on sets of rules such as th appearance of specific key words to determine whether a document is a record and wh series of records it belongs to For example the words “litigation” and “plaintiff” appearing in a document might identify it as a legal record Page 15 GAO-10-838T senior officials with some additional designations by agency components as permanent and treating all the rest as temporary Both proposals would make managing e-mail simpler but could increase the risk that significant information will not be preserved Recent Developments Could Help Spur More Action on Information and Records Management Raising the priority of records management has been and continue to be an uphill battle As we have reported government needs to prioritize the use of resources and records management has not been a high priority Further records management can also be tim and resource-consuming and technically difficult to implement NARA can influence this situation by providing effective guidance and assistance to agencies as well as through its oversight and reporting activities With its recently initiated annual selfassessment survey NARA is responding to our earlier recommendations on oversight by beginning an effort to develop a comprehensive view of the state of federal records management a basis for determining where its attention is most needed Reportin the results of the survey with scores for individual agencies and components to the Congress OMB and the public is one way to help bring the records management issue to the attention of senio agency management Another factor that could help raise awareness of the value of records management is the growing recognition of the risks of wea electronic records and information management as a result of fea of potentially large costs to organizations that have to produce electronically stored information to respond to litigation as well as well-publicized incidents of lost records including e-mail This recognition of risk is coupled with increased awareness of the valu of organizations’ information assets according to AIIM the field of enterprise content management which includes records management has been accepted driven by the need to control th content chaos that pervades local drives file shares email system and legacy document stores As a result according to an AIIM survey the highest current priorities for ECM activity are electroni records management and managing e-mails as records Page 16 GAO-10-838T Further recent Open Government initiatives which emphasize the importance of making information available to the public for transparency and accountability could be an additional impetus to addressing electronic records management OMB’s Open Government Directive makes a direct link between open government and records management by requiring that each agency’s Open Government Plan include a link to a publicly available Web site that shows how the agency is meeting its existi 37 records management requirements More generally the directive urges agencies to use modern technology to disseminate useful information According to an Administration official records management plays a crucial role in open government by ensuring accountability through proper documentation of government actions 38 Increased attention to information and records management could provide another spur encouraging agencies to devote resources to managing their electronic records more effectively Finally the priority that agencies give to addressing weaknesses may be increased by hearings such as this which show that the Congress recognizes the importance of good records management for the efficient effective and accountable operations of government In summary federal records management has been given low priority for many years However the explosion of electronic information and records is an increasing risk to agencies and coul even become a drag on agencies’ ability to perform their missions not brought under control Raising visibility as NARA is doing by publishing the results of its self-assessment survey can raise the perception among senior 37 OMB Open Government Directive M-10-06 December 8 2009 38 Cass R Sunstein Administrator of the Office of Information and Regulatory Affairs OMB “Open Government and Records Management ” Keynote NARA 2010 Records Administration Conference May 12 2010 http archives gov records-mgmt pdf sunste raco2010 pdf Page 17 GAO-10-838T agency officials of the importance of records management Also significant is the push for Open Government which by heightenin the importance of agencies’ providing information to the public makes information a more central part of their missions and could help highlight the actual importance to agencies of actively managing their information Strong indications from the Congress that records management needs more attention could also raise th priority among agency management Mr Chairman this completes my prepared statement I would be pleased to respond to any questions you or other Members of the Subcommittee may have at this time Contact and Acknowledgments If you should have questions about this testimony please contact me at 202 512-6304 or melvinv@gao gov Other major contribut include Barbara Collier Lee McCracken J Michael Resser and Glenn Spiegel 310953 Page 18 GAO-10-838T This is a work of the U S  government and is not subject to copyright protection in the  United States  The published product may be reproduced and distributed in its entirety  without further permission from GAO  However  because this work may contain  copyrighted images or other material  permission from the copyright holder may be  necessary if you wish to reproduce this material separately   GAO’s Mission The Government Accountability Office the audit evaluation and investigative arm of Congress exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people GAO examines the use of public funds evaluates federal programs and polici 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