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Highlights: Report to Congressional Requesters:
June 2002:
Information Management:
Challenges in Managing and Preserving Electronic Records:
GAO-02-586:
June 2002:
Information Management:
Challenges in Managing and Preserving Electronic Records:
Highlights of GAO-02-586, a report to Congressional Requesters:
Why GAO Did This Study:
In the wake of the transition from paper-based to electronic processes,
federal agencies are producing vast and rapidly growing volumes of
electronic records. The difficulties of managing, preserving, and
providing access to these records represent challenges for the National
Archives and Records Administration (NARA) as the nation’s recordkeeper
and archivist. GAO was requested to (1) determine the status and
adequacy
of NARA’s response to these challenges and (2) review NARA’s efforts to
acquire an advanced electronic records archiving system, which will be
based on new technologies that are still the subject of research.
What GAO Found:
NARA has taken action to respond to the challenges associated with
managing and preserving electronic records. In 2001, NARA completed
an assessment of the current federal recordkeeping environment. This
study concluded that although agencies are creating and maintaining
records appropriately, most electronic records (including databases
of major federal information systems) remain unscheduled (that is,
their value has not been assessed nor their disposition determined),
and records of historical value are not being identified and provided
to NARA for archiving. As a result, valuable electronic records may
be at risk of loss. Part of the problem is that records management
guidance is inadequate in the current technological environment of
decentralized systems producing large volumes of complex records.
Another factor is the low priority often given to records management
programs and the lack of technology tools to manage electronic records.
Finally, NARA does not perform systemic inspections of agency records
management, and so it does not have comprehensive information on
implementation issues and areas where guidance needs strengthening.
Although NARA plans to improve its guidance and address technology
issues, its plans do not address the low priority generally given
to records management programs nor the inspection issue.
Recognizing the limitations of its technical strategies to support
preservation, management, and sustained access to electronic records,
NARA is planning to design, acquire, and manage an advanced electronic
records archive; however, this project faces substantial risks.
Although the electronic records archive project is in its initial
stages, it is already falling behind schedule. Further, to acquire a
major system of this kind, NARA needs to improve its information
technology (IT) management capabilities, and although it has made
progress in doing so, its efforts are not yet complete.
What GAO Recommends:
GAO recommends that the Archivist of the United States develop
documented strategies to raise awareness of the importance of records
management programs and for conducting systematic inspections of these
programs. In addition, to reduce risks, GAO recommends that the
Archivist reassess the schedule for acquiring the new archival system
so that the agency can complete key planning tasks and address IT
management weaknesses. In commenting on a draft of this report, the
Archivist agreed with our recommendations and offered clarifications,
which we have incorporated as appropriate.
Figure: Master Copies of Electronic Records in NARA’s Archives:
[See PDF for image]
Source: NARA.
[End of figure]
This is a test for developing highlights for a GAO report. The full
report, including GAO’s objectives, scope, methodology, and analysis is
available at www.gao.gov/cgi-bin/getrpt?GAO-02-586. For additional
information about the report, contact Linda Koontz, 202-512-6240. To
provide comments on this test highlights, contact Keith Fultz (202-512-
3200) or email HighlightsTest@gao.gov.
Contents:
Letter:
Results in Brief:
Background:
NARA Is Responding to Challenges of Electronic Records Management:
NARA’s Effort to Acquire Advanced Electronic Archival System Faces
Risks:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Objectives, Scopes, and Methodology:
Appendix II: Approaches to Archiving Electronic Records Provide Partial
Solutions:
Appendix III: NARA’s Electronic Records Guidance Has Evolved:
Appendix IV: Agencies Are Managing Large Volumes of Important
Elecrtonic Records:
Appendix V: Comments from the National Archives and Records
Administration:
Glossary:
Table:
Table 1: Timeline for ERA Program:
Figures:
Figure 1: Removable Hard Drives and Backup Devices Used by Independent
Counsel Staff:
Figure 2: Master Copies of Electronic Records in NARA’s Archives:
Figure 3: OAIS Model and Its Components:
Figure 4: Sample of XML Version of State Department Telegram:
Figure 5: The Long Now Foundation Rosetta Disk Language Archive:
Figure 6: Internet Archive Collection of Presidential Candidate Web
Sites:
Figure 7: Google’s Usenet Archive:
Abbreviations:
ASCII: American Standard Code for Information Interchange:
DARPA: Defense Advanced Research Projects Agency:
DOD: Department of Defense:
EAST: Examiners Automated Search Tool:
ERA: Electronic Records Archive:
GAO: General Accounting Office:
GIS: Geographic Information System:
GRS: General Records Schedule:
GSA: General Services Administration:
HTML: Hypertext Markup Language:
HUD: Housing and Urban Development:
IG: Inspector General:
IT: information technology:
NARA: National Archives and Records Administration:
NASA: National Aeronautics and Space Administration:
OAIS: Open Archival Information System:
OMB: Office of Management and Budget:
PMO: program management office:
POP: persistent object preservation:
PTO: U.S. Patent and Trademark Office:
SAS: State Archiving System:
SF: standard form:
VERS: Victorian Electronic Record Strategy:
WEST: Web Examiner Search Tool:
XML: Extensible Markup Language:
Letter June 17, 2001:
The Honorable Stephen Horn
Chairman, Subcommittee on Government Efficiency,
Financial Management and Intergovernmental Relations
Committee on Government Reform
House of Representatives:
The Honorable Ernest J. Istook, Jr.
Chairman, Subcommittee on Treasury,
Postal Service and General Government
Committee on Appropriations
House of Representatives:
Agencies are increasingly moving to an operational environment in which
electronic--rather than paper--records provide comprehensive
documentation of their activities and business processes. Although this
transformation has improved the way federal agencies work and interact
with each other and with the public, it has also created the new
challenge of managing and preserving vast and rapidly growing volumes
of electronic records. Because these records document essential
government functions and provide information necessary to protect
government and citizen interests, their proper management is essential
for ongoing government activities; further, the preservation of
significant documents and other records is crucial for the historical
record.
Overall responsibility for the government’s electronic records lies
with the National Archives and Records Administration (NARA), which
carries out a dual mission for the nation: oversight of records
management, which governs the life cycle of records (creation,
maintenance and use, and disposition), and archiving, which is the
permanent preservation of documents and other records of historical
interest. In carrying out these missions, NARA and agencies use a
process known as scheduling to assess the value of records and
determine their disposition.
The challenges associated with managing and preserving electronic
records have long been recognized throughout government. Because of
concern about these issues, you requested that we review electronic
records management and preservation activities at NARA. Our objectives
were to:
* determine the status of NARA’s efforts to respond to governmentwide
electronic records management problems and the adequacy of its planned
actions and:
* assess NARA’s efforts to acquire an archival system for electronic
records.
As part of our assessment of NARA’s efforts to acquire an electronic
records archiving system, you also asked that we identify alternative
technologies under consideration for the long-term preservation of
electronic records.
To address our objectives, we reviewed applicable guidance and other
documentation; surveyed NARA’s appraisal archivists working with
federal agencies; reviewed records management activities and obtained
the views of record managers in selected federal agencies managing
large volumes of electronic records; and reviewed legal challenges to
federal electronic recordkeeping practices. We reviewed agency and
contractors’ documentation for the electronic records archive program
and assessed NARA’s effort to develop or enhance its information
technology capabilities. Further details on our objectives, scope, and
methodology are provided in appendix I.
Results in Brief:
NARA has taken action to respond to the challenges associated with
managing and preserving electronic records. In 2001, NARA completed an
assessment of the current federal recordkeeping environment; this study
concluded that although agencies are creating and maintaining records
appropriately, most electronic records (including databases of major
federal information systems) remain unscheduled, and records of
historical value are not being identified and provided to NARA for
preservation in archives. As a result, valuable electronic records may
be at risk of loss. Part of the problem is that records management
guidance is inadequate in the current technological environment of
decentralized systems producing large volumes of complex records.
Another factor is the low priority often given to records management
programs and the lack of technology tools to manage electronic records.
Finally, NARA does not perform systematic inspections of agency records
and records management programs, and so it does not have comprehensive
information allowing it to identify records management implementation
issues and areas where its guidance needs to be strengthened. NARA
plans to improve its guidance and to address technology issues.
However, NARA’s plans do not address the low priority generally given
to records management programs nor the issue of systematic inspections.
Recognizing the limitations of its technical strategies to support
preservation, management, and sustained access to electronic records,
NARA is planning to design, acquire, and manage an advanced electronic
records archive (ERA); however, this project faces substantial risks.
NARA is behind schedule for the ERA system, largely because of flaws in
how the schedule was developed. Further, to acquire a major system like
ERA, NARA needs to improve its information technology (IT) management
capabilities, and although it has made progress in doing so, its
efforts are not yet complete.
Regarding alternative archiving technologies for electronic records, we
found that archival organizations now rely on a mixture of evolving
approaches that generally fall short of solving the long-term
preservation problem. Appendix II provides a detailed discussion of
these approaches.
In light of the continuing challenge of managing federal records, both
electronic and otherwise, we are recommending that the Archivist of the
United States develop a strategy for raising awareness of the
importance of federal records management programs and for performing
systematic inspections. In addition, to mitigate the risks associated
with developing the new archival system, we are recommending that the
Archivist reassess the schedule for this effort.
In commenting on a draft of this report, the Archivist stated that more
must be done to address the enormous challenges in managing and
preserving electronic records and agreed with the report’s
recommendations. He also offered clarifications concerning records
management priority, inspections, and the ERA schedule that we have
incorporated as appropriate.
Background:
Advances in information technology and the explosion in computer
interconnectivity brought about by the Internet are irreversibly
changing the way we communicate and conduct business. Office automation
applications and networked desktop computers are providing the
capability to rapidly create and share electronic documents, use Web
sites for executing business and financial transactions, and
instantaneously communicate with individuals and groups. While the
transformation from a paper-based to an electronic business environment
has led to improvements in the way federal agencies do business, both
with each other and with the public, it has also created the new
challenge of managing and preserving electronic records, which must be
approached differently from their paper counterparts. Unlike paper
records, electronic records are not tangible, come in many formats, and
depend on the hardware and software with which they were created.
NARA’s mission is to ensure “ready access to essential evidence” for
the public, the President, the Congress, and the Courts. NARA’s
responsibilities stem from the Federal Records Act,[Footnote 1] which
requires each federal agency to make and preserve records that
(1) document the organization, functions, policies, decisions,
procedures, and essential transactions of the agency and (2) provide
the information necessary to protect the legal and financial rights of
the government and of persons directly affected by the agency’s
activities. Effective management of these records is critical for
ensuring that sufficient documentation is created; that agencies can
efficiently locate and retrieve records needed in the daily performance
of their missions; and that records of historical significance are
identified, preserved, and made available to the public. According to
NARA, without effective records management, the records needed to
document citizens’ rights, actions for which federal officials are
responsible, and the historical experience of the nation will be at
risk of loss, deterioration, or destruction.
Under the act, NARA is responsible for oversight of records management
and archiving. Records management--that is, the policies, procedures,
guidance, tools and techniques, resources, and training needed to
design and maintain reliable and trustworthy records systems--governs
the life cycle of records from creation, through maintenance and use,
to final disposition. Archiving is the permanent preservation of
records documenting the activities of the government. NARA thus
oversees agency management of temporary records used in everyday
operations and ultimately takes control of permanent agency records
judged to be of historic value.[Footnote 2] Of the total number of
federal records, less than 3 percent are designated permanent.
NARA Is Responsible for Oversight of Records Management:
NARA is responsible for issuing records management guidance; working
with agencies to implement effective controls over the creation,
maintenance, and use of records in the conduct of agency business;
providing oversight of agencies’ records management programs; and
providing storage facilities for certain temporary agency records. The
Federal Records Act also authorizes NARA to conduct inspections of
agency records and records management programs.
NARA works with agencies to identify and inventory records, appraise
their value, and determine whether they are temporary or permanent, how
long the temporary records should be kept, and under what conditions
both the temporary and permanent records should be kept. This process
is called scheduling. No record may be destroyed unless it has been
scheduled, and for temporary records the schedule is of critical
importance because it provides the authority to dispose of the record
after a specified time period. Records are governed by schedules that
are specific to an agency or by a general records schedule, which
covers 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 other two thirds, NARA and the agencies
must agree upon specific records schedules. Once a schedule has been
approved, the agency must issue it as a management directive, train
employees in its use, apply its provisions to temporary and permanent
records, and evaluate the results.
While the Federal Records Act covers documentary material regardless of
physical form or media, records management and archiving were until
recently largely focused on handling paper documents. With the advent
of computers, both records management and archiving have had to take
into account the creation of records in varieties of electronic
formats. NARA’s basic guidance for the management of electronic records
is in the form of a regulation at 36 CFR Part 1234. This guidance is
supplemented by the issuance of periodic NARA bulletins and a records
management handbook, Disposition of Federal Records. NARA’s guidance
has two basic requirements. First, agencies are required to maintain an
inventory of all agency information systems. The inventory should
identify (1) the system’s name; (2) its purpose; (3) the agency
programs supported by the system; (4) data inputs, sources, and
outputs; (5) the information content of databases; and (6) the system’s
hardware and software environment. Second, NARA requires agencies to
schedule the electronic records maintained in its systems. Agencies
must either schedule those records under specific schedules, completed
through submission and approval of Standard Form 115 (SF 115), Request
for Records Disposition Authority, or pursuant to a general records
schedule. NARA relies on this combination of inventory and scheduling
requirements to ensure the management of agency electronic records
consistent with the Federal Records Act.
NARA has also established a general records schedule for electronic
records. General Records Schedule 20 (GRS 20) authorizes the disposal
of certain categories of temporary electronic records. It has been
revised several times over the years in response to developments in
information technology, as well as legal challenges. (App. III provides
a discussion of the evolution of electronic records guidance and legal
challenges to
GRS 20.):
As it stands now, GRS 20 applies to electronic records created both in
computer centers engaged in large-scale data processing and in the
office automation environment. With regard to computer centers, GRS 20
authorizes the disposal of certain types of scheduled electronic
records associated with large database systems, such as inputs,
outputs, and processing files. With regard to the office desktop
environment, GRS 20 authorizes the deletion of the electronic version
of records on word processing and electronic mail systems once a
recordkeeping copy has been made. In addition, it authorizes deletion
of electronically generated administrative spreadsheets and other
administrative records that are included in recordkeeping systems that
have been authorized for disposal by NARA. Since most agency
“recordkeeping systems” are paper files, GRS 20 essentially authorizes
agencies to destroy E-mail and word-processing files once they are
printed. As already noted, records not covered by a general records
schedule may not be destroyed unless authorized by a records schedule
that has been approved by NARA.
GRS 20 does not address many common products of electronic information
processing, particularly those that result from the now prevalent
distributed, end-user computing environment. For example, although the
guidance addresses the disposition of certain types of electronic
records associated with large databases, it does not specifically
address the disposition of electronic databases created by
microcomputer users. In addition, while addressing word processing and
E-mail records, GRS 20 does not address more recent forms of electronic
records such as Web pages and portable document format (PDF) files.
[Footnote 3]:
NARA Archives Permanent Records of Historical Interest:
As the nation’s archivist, NARA accepts for deposit to its archives
those records of federal agencies, the Congress, the Architect of the
Capitol, and the Supreme Court that are determined to have sufficient
historical or other value to warrant their continued preservation by
the U.S. government. NARA also accepts papers and other historical
materials of the Presidents of the United States, documents from
private sources that are appropriate for preservation (including
electronic records, motion picture films, still pictures, and sound
recordings), and records from agencies whose existence has been
terminated, including Offices of Independent Counsel (see fig. 1).
Figure 1: Removable Hard Drives and Backup Devices Used by Independent
Counsel Staff:
[See PDF for image]
Source: NARA.
[End of figure]
NARA archives vast quantities of federal records in various formats.
Its archival facilities (a network of regional archives) hold over 21
million cubic feet of original textual materials, while its multimedia
collections include nearly 300,000 reels of motion picture film; more
than 5 million maps, charts, and architectural drawings; over 200,000
sound and video recordings; about 9 million aerial photographs; nearly
14 million still pictures and posters; and over 87,000 computer data
sets stored on computer tapes and cartridges (see fig. 2).
Figure 2: Master Copies of Electronic Records in NARA’s Archives:
[See PDF for image]
Source: NARA.
[End of figure]
In addition to its archives, NARA also manages the archival holdings of
10 presidential libraries, the Nixon presidential materials staff, and
the Clinton presidential materials project. These include over 400
million paper records, over 15 million feet of film, nearly 10 million
still pictures, nearly 100,000 hours of audio and video recordings, and
almost half a million museum objects.
The types of electronic records that NARA currently accepts for
archiving are limited to those that are independent of specified
hardware or software and are in text-based formats, such as databases
and certain text-based geographic information system (GIS)[Footnote 4]
files. NARA does not accept digital images, Web pages, word processor
files, relational databases, or any records with complex
structure.[Footnote 5] (Although NARA does not as yet accept such files
for archiving, they must still be scheduled.):
Management and Preservation of Electronic Records Pose Major
Challenges:
During the last four decades, archiving--the permanent preservation of
information of enduring value for access by future generations--has
undergone a major change. Before the advent of large bureaucracies
supported by the now ubiquitous computer, archivists dealt with a
scarcity of sources, with much of their efforts focused on tracking
down unique manuscripts or recovering incomplete files.[Footnote 6] The
archived records were relatively durable--clay tablets, stone,
parchment, vellum, or rag paper. Albeit scarce and often incomplete,
these records come down through the centuries relatively intact and
could be preserved with little or no difficulty. The growth of the
government, complex organizations, and advent of the electronic age
have reversed the conditions facing today’s archives: rather than
dealing with scarce sources, the archives are facing a flood of
potentially valuable information stored on fragile materials, including
pulp paper and computer tapes and disks.
While the preservation of information recorded on traditional materials
such as paper or film requires significant resources, the current major
archival challenge is the preservation of electronic records. Like
traditional archival materials--books, papers, or film--electronic
information is recorded on media that deteriorate with age. However,
unlike the traditional archival materials, electronic records are
stored in specific formats and cannot be read without software and
hardware--sometimes the specific types of hardware and software on
which they were created.
The rapid evolution of information technology makes the task of
managing and preserving electronic records complex and costly. Agencies
are increasingly moving to an operational environment in which
electronic--rather than paper--records provide comprehensive
documentation of their activities and business processes. Part of the
challenge of managing electronic records is that they are produced by a
mix of information systems, which vary not only by type but by
generation of technology: the mainframe, the personal computer, and the
Internet. Each generation of technology brought in new systems and
capabilities without displacing the older systems.[Footnote 7] Thus,
organizations have to manage and preserve electronic records associated
with a wide range of systems, technologies, and formats.
The challenge of managing and preserving vast and rapidly growing
volumes of electronic records produced by modern organizations is
placing pressure on the archival community and on the information
industry to develop a cost-effective long-term preservation strategy
that would free electronic records of the straitjacket of proprietary
file formats and software and hardware dependencies. This challenge is
affected by several factors: decentralization of the computing
environment, the complexity of electronic records, obsolescence and
aging of storage media, massive volumes of electronic records, and
software and hardware dependencies.
* Decentralization of computing environment: The challenge of managing
electronic records significantly increases with the decentralization of
the computing environment. In the centralized environment of a
mainframe computer, it is relatively easy to identify, assess, and
manage electronic records. This is not the case in the decentralized
environment of agencies’ office automation systems, where every user is
creating electronic files that may constitute a formal record and thus
should be preserved.
* Complexity of electronic records: Electronic records have evolved
from simple text-based files to complex digital objects that may
contain embedded images (still and moving), drawings, 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). These records cannot be converted to paper or text
formats without the loss of context, functionality, and information.
* Obsolescence and aging of storage media: Storage media are affected
by the dual problems of obsolescence and decay. They are fragile, have
limited shelf life, and become obsolete in a few years. Few computers
today have disk drives that can read information stored on 8-or 5¼-inch
diskettes, even if the diskettes themselves remain readable.
* Massive volumes: Electronic records are increasingly being created in
volumes that pose significant technical challenge to our ability to
organize and make them accessible. For example, among the candidates
for archiving are military intelligence records comprising more than 1
billion electronic messages, reports, cables, and memorandums, as well
as over 50 million electronic court case files.
* Software and hardware dependency: Electronic records are created on
computers with software ranging from word-processors to E-mail
programs. As computer hardware and application software become
obsolete, they may leave behind electronic records that cannot be read
without the original hardware and software.
Past GAO Work Highlighted Electronic Records Challenges:
In July 1999, we reported that NARA and federal agencies were facing
the substantial challenge of preserving electronic records in an era of
rapidly changing technology.[Footnote 8] In that report we stated that
in addition to handling the burgeoning volume of electronic records,
NARA and the agencies would have to address several hardware and
software issues to ensure that electronic records were properly
created, maintained, secured, and retrievable in the future. We also
noted that NARA did not have governmentwide data on the records
management capabilities and programs of all federal agencies. As a
result, we recommended that NARA conduct a governmentwide survey of
agencies’ electronic records management programs and use the
information as input to its efforts to reengineer its business
processes. NARA’s subsequent efforts to assess governmentwide records
management practices and study the redesign of its business processes
are discussed later in this report.
Agencies Are Beginning to Automate Management of Electronic Records:
In response to the difficulty of manually managing electronic records,
agencies are slowly turning to automated records management
applications to help automate electronic records management life-cycle
processes. The primary functions of these applications include
categorizing and locating records and identifying records that are due
for disposition, as well as storing, retrieving, and disposing of
electronic records that are maintained in repositories. Also, some
applications are beginning to be designed to automatically classify
electronic records and assign them to an appropriate records retention
and disposition category.
The Department of Defense (DOD), which is pioneering the assessment and
use of records management applications, has published application
standards and established a certification program.[Footnote 9] The DOD
standard, endorsed by NARA, includes the requirement that records
management applications acquired by DOD components after 1999 be
certified to meet this standard.[Footnote 10] As of March 2002, DOD had
certified 31 applications. NARA was testing one of the DOD-certified
electronic records management applications, and it will be assessing
the second version of the DOD standard to determine whether it can or
should become a governmentwide standard.
Theory, Methods, and Model for Long-Term Preservation of Electronic
Records Are Being Developed:
NARA is not alone in facing the challenges posed by electronic records,
particularly long-term preservation. There is a general consensus in
the archival community that a viable strategy for the long-term
preservation and archiving of electronic records has yet to be
developed. Accordingly, archives scholars, national archival and
library institutions, and private industry representatives are
collaborating on major initiatives to develop the theoretical and
methodological knowledge needed for the permanent preservation of
records created in electronic systems. These initiatives include the
following:
* The International Research on Permanent Authentic Records in
Electronic Systems project is a major two-phase international research
project in which archival and computer engineering scholars, national
archival institutions (including NARA), and private industry
representatives are collaborating to develop the theoretical and
methodological knowledge required for the permanent preservation of
authentic records created in electronic systems. The first phase of the
project, focusing on records generated in databases and document
management systems, was recently completed; the second phase (2002 to
2006) deals with the issues of authenticity, reliability, and accuracy
of records produced in new digital environments.
* The Library of Congress’ National Digital Information Infrastructure
and Preservation Program is a national cooperative effort led by the
Library to develop the strategy and technical approaches needed to
archive and preserve digital information; NARA is also participating in
this effort. The program is in an early stage; completion is not
expected until 2004 or 2005, when the Library will provide
recommendations to the Congress.
* NARA is collaborating in a joint effort on electronic record
archiving with the Defense Advanced Research Projects Agency (DARPA),
the U.S. Patent and Trademark Office, the National Partnership for
Advanced Computational Infrastructure, and the San Diego Supercomputer
Center. Led by DARPA, the collaboration aims to develop and demonstrate
architectures and technologies for electronic archiving and the
development of persistent object preservation, a proposed technique for
electronic archiving (discussed in app. II).
These initiatives are all in their early stages; none of them has yet
yielded proof-of-concept prototypes demonstrating the viability of a
long-term solution to preserving and accessing electronic records.
Progress has been made, however, in the development of a standard model
for electronic archiving systems. The Open Archival Information System
(OAIS) model, which is currently emerging as a standard in the archival
community, was initially developed by the National Aeronautics and
Space Administration (NASA) for archiving the large volumes of data
produced by space missions. However, the model is applicable to any
archive, digital library, or repository. As a standard framework for
long-term preservation archives, the model defines the environment
necessary to support a digital repository and the interactions within
that environment. According to NASA, it also promotes the understanding
and increased awareness of archival concepts needed for long-term
digital information preservation and access, as well as for describing
and comparing architectures and operations of existing and future
archives.
Many institutions have already chosen to use the framework of the OAIS
reference model to guide their digital preservation efforts, including
the National Library of the Netherlands, NARA (in conjunction with the
development of its electronic records archiving project), NASA’s
National Space Science Data Center, and many commercial organizations.
The OAIS model (see fig. 3) breaks the archiving system down into six
distinct functional areas: ingest, archival storage, data management,
administration, preservation planning, and access.
* In the ingest area, systems accept information submitted from outside
the framework and prepare the contents for storage. This functional
area also includes systems to generate descriptive information to allow
future management within the archive.
* In the archival storage area, systems pass the information, now
called archival information packages, into a storage repository, where
it is maintained until the contents are requested and retrieved.
* The data management area encompasses the services and functions for
populating, maintaining, and accessing both descriptive information
that identifies and documents archive holdings and administrative data
used to manage the archive.
* The administration area provides the services and functions for the
overall operation of the archive system.
* In the preservation planning area, systems monitor the environment of
the OAIS and provide recommendations to ensure that the information
stored in the OAIS remains accessible, even if the original computing
environment becomes obsolete.
* The access area includes systems that allow a user to determine the
existence, description, location, and availability of information
stored in the OAIS, allowing information products to be requested and
received.
Figure 3: OAIS Model and Its Components:
[See PDF for image]
Source: Consultative Committee for Space Data Systems.
[End of figure]
The OAIS framework does not presume or apply any particular
preservation strategy. This approach allows organizations that adopt
the framework to apply their own strategies or combinations of
strategies. The framework does assume that the information managed is
produced outside the OAIS, and that the information will be
disseminated to users who are also outside the system. Because the
model is simplified to include only functions common to all
repositories, it allows institutions to focus on the approaches
necessary to preserve the information.
NARA Is Responding to Challenges of Electronic Records Management:
NARA is taking action to respond to long-standing problems associated
with managing and preserving electronic records in archives. In 2001,
NARA completed an assessment of governmentwide records management
practices. This assessment concluded that although agencies are
creating sufficient records and maintaining them appropriately, most
electronic records remain unscheduled, and permanent records of
historical value are not being identified and provided to NARA for
preservation and archiving. As a result, potentially valuable records
may be at risk.
According to the study, the problems in electronic records management
appear to stem from (1) inadequate governmentwide records management
guidance and (2) the low priority traditionally given to federal
records management functions and a lack of technology tools to manage
electronic records. To address these problems, NARA now plans to
(1) analyze key policy issues related to the disposition of records and
improve its guidance and (2) examine and redesign, if necessary, the
scheduling and appraisal process and make this process more effective
through the use of technology. NARA’s plans, however, do not address
the low priority given to records functions. Further, these plans do
not address the need to monitor performance of records management
programs and practices on an ongoing basis.
NARA’s Assessment of Federal Records Practices Identifies Problems:
Records must be effectively managed throughout their life cycle, which
includes records creation, maintenance and use, and scheduling and
disposition. Agencies must create reliable records that meet the
business needs 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 create internal recordkeeping requirements for
maintaining records, consistently apply these requirements, and
establish systems that allow them to find records that they need.
Scheduling is the means by which NARA and agencies identify federal
records, determine time frames for disposition, and identify permanent
records of historical value that are to be transferred to NARA for
preservation and archiving. With regard particularly to electronic
records, agencies are also to compile inventories of their information
systems, after which the agency is required to develop a schedule for
the electronic records maintained in those systems.
In 2001, NARA completed an assessment of governmentwide records
management practices, as recommended in our prior work. The assessment
included a recordkeeping study performed by a contractor--SRA
International--and a series of records system analyses performed by
NARA staff. The SRA study was based on a survey of federal employees
representing over 150 federal government organizations and on 54 focus
groups and interviews involving individuals from 18 agencies; the NARA
staff’s records system analyses focused on records management practices
for key business processes in 11 federal agencies.
The resulting NARA/SRA study identified problems in agency records
management.[Footnote 11] Specifically, NARA’s assessment of records
management for key processes in 11 agencies concluded the following.
* Records creation: In general, the NARA study showed that the
processes that were studied appeared to generate adequate records
documentation.
* Records maintenance and use: For the most part, recordkeeping
requirements were adequate, documented, and consistently applied. In
addition, employees were generally able to find the records that they
needed.
* Records scheduling and disposition: The study identified significant
problems in both records scheduling and disposition. According to the
study, many significant records--as well as most federal electronic
records--are unscheduled. In addition to the unscheduled records, NARA
identified several significant records that had been improperly
scheduled. The study concluded that records scheduling was clearly a
problem area.
Our review at four agencies (Commerce, Housing and Urban Development,
Veterans Affairs, and State) provides confirmation of this result,
eliciting a collective estimate that less than 10 percent of mission-
critical systems were inventoried. The number of mission-critical
systems at these four agencies was reported to be 907, according to
information collected by the Office of Management and Budget in
November 1999 as part of the federal government’s effort to assess the
Year 2000 computing challenge.[Footnote 12] Thus for these four
agencies alone, over 800 systems had not been inventoried and the
electronic records maintained in them had not been scheduled.
Scheduling the electronic records in a large number of major
information systems presents an enormous challenge, particularly since
it generally takes NARA, in conjunction with agencies, well over 6
months to approve a new schedule.[Footnote 13]
Failure to inventory systems and schedule records places these records
at risk. The absence of inventories and schedules means that NARA and
agencies have not examined the contents of these information systems to
identify official government records, appraised the value of these
records, determined appropriate disposition, and directed and trained
employees in how to maintain and when and how to dispose of these
records. As a result, temporary records may remain on hard drives and
other media long after they are needed or could be moved to less costly
forms of storage. In addition, there is increased risk that these
records may be deleted prematurely while still needed for fiscal,
legal, and administrative purposes.
The lack of scheduling presents particular risks to the preservation of
permanent records of historic significance. NARA’s study of 11 agencies
found instances where valuable permanent electronic records were not
being appropriately transferred to NARA’s archives because these
records had not been scheduled, appraised, identified as permanent, and
placed under the control of the agency’s records program. This lack of
management control places these valuable records at increased risk of
loss, destruction, and deterioration.
NARA’s Records Management Guidance Has Not Kept Pace with the
Challenges of Electronic Records:
The NARA/SRA study identified the lack of sufficient governmentwide
guidance as one cause of records management problems. As NARA has
acknowledged, its policies and processes on electronic records have not
yet evolved to reflect the modern recordkeeping environment: records
created electronically in decentralized processes.[Footnote 14]
Despite repeated attempts to clarify its electronic records guidance
through a succession of NARA bulletins, the current guidance remains
incomplete and confusing. According to the study, for example,
employees lack knowledge concerning how to identify electronic records
and what to do with them once identified. The guidance does not provide
disposition instructions for electronic records maintained in many of
the common types of formats produced by federal agencies, including PDF
files, Web pages, and spreadsheets. To support their missions, many
agencies must maintain such records--often in large volumes--with
little guidance from NARA (see app. IV for a discussion of the records
management challenges faced by selected agencies).
The NARA/SRA study concluded that while agencies appreciate the
specific assistance from NARA personnel, they are frustrated because
they perceive that NARA is not meeting agencies’ broader needs for
guidance and records management leadership. This study reported that
agencies believe that NARA has a responsibility to lead the way in
transitioning to an electronic records environment and to provide
guidance and standards, as well as tools to enable agencies to follow
the guidance. According to the study, some viewed NARA as leaving
agencies to fend for themselves, sometimes levying impossible
requirements that pressure agencies to come up with their own
individual solutions.
Agency Records Management Programs Are Given Low Priority and Lack
Technology Tools:
The NARA/SRA study identified another cause of records management
difficulties: the low priority generally afforded to records management
programs. The study states that records management is not even “on the
radar scope” of agency leaders. Further, records officers have little
clout and do not appear to have much involvement in or influence on
programmatic business processes or the development of information
systems designed to support them. New government employees seldom
receive any formal, initial records management training. One agency
told NARA that records management is “number 26 on our list of top 25
priorities.” The study also noted that federal downsizing may have
negatively affected records management and staffing resources in
agencies.
Further, records management is generally considered a “support”
activity. Since support functions are typically the most dispensable in
agencies, resources for and focus on these functions are often limited.
This finding was echoed by a recent review of archival practices of
research universities, corporate research and development programs, and
federal science agencies, which noted that “agency records management
programs lack the resources to meet even the legally required standards
of
securing adequate documentation of their programs and activities.”
[Footnote 15]:
As indicated by the NARA/SRA study, a related issue is the technical
challenge of electronic records management: effective electronic
records management may require more sophisticated and expensive
information technology (such as automated electronic records management
systems) than was previously necessary for paper-based records
management programs. Because management tends not to focus on records
management, priority has not been given to acquiring or upgrading the
technology required to manage records in an electronic environment. The
study noted that technology tools for managing electronic records do
not exist in most agencies, and further, that agency information
technology environments have not been designed to facilitate the
retention and retrieval of electronic records. As a result, despite the
growth of electronic media, agency records systems are predominantly in
paper format rather than electronic.
The study further noted that agencies planning or piloting automated
electronic records management systems perform better recordkeeping than
those without such tools. Typically, such agencies are already
performing better recordkeeping, and they tend to invest in electronic
records management systems because of the value they place on good
records management. According to the study, many agencies are either
planning or piloting information technology initiatives to support
electronic records management, but their movement to electronic systems
is constrained by the level of financial support provided for records
management.
Inspections of Federal Electronic Records Programs Are Limited:
A possible further cause of agency records management problems, not
addressed in the NARA/SRA study, is the limited nature of NARA’s
current inspection program. NARA is responsible, under the Federal
Records Act, for conducting inspections or surveys of agency records
and records management programs and practices. Its implementing
regulations require NARA to select agencies to be inspected (1) on the
basis of perceived need by NARA, (2) by specific request by the agency,
or (3) on the basis of a compliance monitoring cycle developed by NARA.
[Footnote 16] In all instances, NARA is to determine the scope of the
inspection. Such inspections provide not only the means to assess and
improve individual agency records management programs but also the
opportunity for NARA to determine overall progress in improving agency
records management and identify problem areas that need to be addressed
in its guidance.
Between 1996 and 2000, NARA performed 16 inspections of agency records
management programs, or about 3 per year. These reviews were systematic
and comprehensive, covering all aspects of an agency’s records program.
However, only 2 of the 24 major executive departments or agencies were
evaluated, with most of NARA’s evaluations focused on component
organizations or independent agencies. Moreover, these evaluations
frequently bypassed the issue of electronic records.
In 2000, NARA replaced agency evaluations with a new inspection
approach--targeted assistance. NARA decided that its previous approach
to inspections was basically flawed: besides reaching only a few
agencies, it was often perceived negatively by agencies and resulted in
a list of records management problems that agencies then had to resolve
on their own. Under the targeted assistance approach, NARA enters into
partnerships with federal agencies to provide them with guidance,
assistance, or training in any area of records management. Services
offered include expedited review of critical schedules, tailored
training, and help in records disposition and transfer.
However, although this approach may improve records management in the
targeted agencies, it is not a substitute for systematic inspections
and evaluations of federal records programs. Because the targeted
assistance program is voluntary and, according to NARA, initiated by a
written request from the agency, relying on it exclusively could
significantly limit NARA’s evaluations of federal recordkeeping. First,
only agencies requesting targeted assistance--presumably those already
having greater appreciation of the importance of records management--
are evaluated. Second, the scope and the focus of the targeted
assistance are not determined by NARA but by the requesting agency.
NARA Is Addressing Records Management Problems, but Additional
Opportunities Exist:
NARA has recognized that its policy and regulations for the management
and disposition of electronic records must be revised to provide
agencies with clear and comprehensive guidance encompassing all types
and formats of electronic records. Having completed its assessment of
federal records management practices, NARA now plan a two-phase project
to (1) analyze key policy issues related to the disposition of records
and improve governmentwide guidance, and (2) examine and redesign, if
necessary, the scheduling and appraisal process and make this process
more effective through the use of technology.
According to NARA, the purpose of the first phase of the project is to
analyze and make decisions, as necessary, on key policy issues related
to determining the disposition of records. NARA plans to evaluate
current legislation, regulations, and guidance to determine if these
are adequate in the current recordkeeping environment. NARA expects the
outcome of the first phase, scheduled for completion by the end of
fiscal year 2002, to be policy decisions that support the appropriate
disposition of all government documentation in today’s multimedia
environment.[Footnote 17] These results are also intended, as
recommended in our prior work, to inform the redesign of the current
scheduling and appraisal process planned for the second phase of the
project, the development of electronic recordkeeping requirements, and
improvements to records management guidance and assistance to agencies.
In the second phase, NARA plans to examine and redesign, if necessary,
the process used by the federal government to determine the disposition
of records. This is planned as a multiyear process (2003 to 2006)
during which NARA intends to address the scheduling and appraisal of
federal records in all formats. Currently, it takes NARA well over 6
months to approve a new schedule. According to NARA, the extensive
appraisal time delays action on the disposition of records and
discourages agencies from submitting schedules, potentially putting
essential evidence at risk. NARA has two goals for this project:
(1) making the process for determining the disposition of records,
regardless of medium, more effective and efficient and dramatically
decreasing the amount of time it takes to get approval for the
disposition of records from the Archivist of the United States, and
(2) deciding how to appropriately apply technology to support the
revised process for determining the disposition of records as part of
managing records throughout their life cycle.
Although NARA’s plans address the need to improve guidance and
determine how to use technology to support records management, these
plans do not address another issue raised in its study: the low
priority generally given to records management and the related lack of
management commitment and attention to these functions. Without a
strategy to establish senior-level agency commitment to records
management and raise awareness of its importance to the federal
government, these programs are likely to continue to be regarded by
agency management and employees as low-priority “support” functions.
In addition, NARA’s plans do not address the issue of systematic
inspections. While the results of its recent study provide a baseline
of governmentwide records management practices, NARA’s targeted
assistance approach does not provide systematic and comprehensive
information to assess progress over time. Without this type of data,
NARA will be impaired in its ability to determine if it is achieving
results in improving agency records management. Further, NARA may not
have the means to identify agency implementation issues and areas where
its guidance needs to be clarified, augmented, and strengthened. The
feedback provided by inspection is especially critical now as NARA
plans to redesign the scheduling and appraisal process, and improve its
guidance.
NARA’s Effort to Acquire Advanced Electronic Archival System Faces
Risks:
Archiving--the final phase of records management for permanent records-
-presents a significant challenge when records are electronic. In light
of the growth in the volume, complexity, and diversity of electronic
records, NARA has recognized that its technical strategies to support
preservation, management, and sustained access to electronic records
are inadequate and inefficient. To address this challenge, the agency
is pursuing two strategies. Its short-term strategy is to extend the
useful life of its current systems and to create some new systems for
archiving electronic records and for cataloging and displaying
electronic records on-line. NARA’s long-term strategy, on which it is
placing its primary focus, is to contract with a private sector firm to
acquire (that is, obtain) an advanced electronic records archive (ERA).
However, NARA faces substantial risks in implementing its long-term
strategy. NARA is not meeting its schedule for the ERA system, largely
because of flaws in how the schedule was developed. As a result, the
schedule will be compressed, increasing risks. Further, although NARA
recognizes that to be successful it must improve its information
technology (IT) management capabilities and has made progress in doing
so, these efforts are not yet complete.
NARA Is Planning to Acquire an Advanced Electronic Records Archiving
System:
NARA’s long-term strategic initiative is to develop an advanced
electronic records archive. The agency’s goals for this system are to
preserve and provide access to any kind of electronic record, free from
dependency on any specific hardware or software, so that the agency can
carry out its mission into the future.
Although the new archival system is not yet formally defined, agency
documents, public presentations, and interviews with agency officials
and staff indicate, in broad outline, how they envision this system. It
will probably be a distributed system, allowing the storage and
management of massive record collections at a variety of installations,
with accessibility provided via the Internet. It may be based on
persistent object preservation, an advanced form of file format
conversion and encapsulation (described in app. II) that is the subject
of research sponsored by NARA and other organizations. A leading
candidate for performing this encapsulation and capturing the necessary
information is the Extensible Markup Language (XML), which provides a
means for “tagging” (annotating) information in a meaningful fashion
that can be readily interpreted by disparate computer systems (XML is
further discussed in app. II).
NARA has indicated that ERA will be a major system, and that it is
likely that it will be developed and implemented in several phases (or
“builds”), with each phase adding more functions to the system.
According to NARA, its development will take several years, and it will
involve a significant expenditure of resources on program management,
research, and systems development activities.
NARA is planning to award the contract for the new electronic archival
system in January 2004. Table 1 is a timeline showing key tasks for the
program.
Table 1: Timeline for ERA Program:
Key ERA tasks: Develop vision statement; Completion dates:
March 1, 2002[ A].
Key ERA tasks: Develop concept of operations; Completion
dates: April 1, 2002[ B].
Key ERA tasks: Conduct market survey; Completion dates: June
28, 2002.
Key ERA tasks: Perform analysis of alternatives; Completion
dates: July 22, 2002.
Key ERA tasks: Develop cost estimates; Completion dates:
August 19, 2002.
Key ERA tasks: Develop high-level conceptual and functional
requirements; Completion dates: September 24, 2002.
Key ERA tasks: Develop business case/economic analysis;
Completion dates: September 30, 2002.
Key ERA tasks: Develop final functional requirements;
Completion dates: December 2, 2002.
Key ERA tasks: Issue Request for Information; Completion
dates: January 13, 2003.
Key ERA tasks: Release Request for Proposal; Completion dates:
August 4, 2003.
Key ERA tasks: Fiscal year 2004 budget for ERA In effect;
Completion dates: October 1, 2003.
Key ERA tasks: Award ERA contract; Completion dates: January
12, 2004.
[A] Completed April 18, 2002.
[B] Completed in draft on April 1, 2002.
[End of table]
To assist in this effort, NARA contracted with Integrated Computer
Engineering (ICE), Incorporated,[Footnote 18] a private company
experienced in systems development and acquisition. With the assistance
of this contractor, NARA has been establishing the ERA program
management office. Since July 2001, the program management office has
been focused on developing the capability to manage the development and
acquisition of the ERA system.
NARA is also funding two independent assessments of the research into
the technology that is proposed for ERA. These two independent
assessments, conducted by the National Academy of Sciences, will review
research that NARA is now sponsoring, as well as alternative
approaches. The first assessment is a technical review of the viability
of persistent object preservation, the architecture for persistent
archives of electronic records that is being researched by the National
Partnership for Advanced Computational Infrastructure (see app. II).
This assessment--scheduled for completion on January 31, 2003--will
address the adequacy and soundness of the persistent object
preservation architecture as a whole, as well as its major components,
from the points of view of computer science, systems engineering, and
archival sciences. NARA has stated that the assessment of the
persistent object information management architecture and its technical
validation should be completed before ERA is developed. In its fiscal
year 2002 budget hearings, NARA referred to the articulation of the
persistent object preservation architecture as the one “major
dependency” in its strategy for acquiring an ERA system.
The second assessment will identify and evaluate alternative methods
for digital preservation of records, examine the operational use of the
Internet for digital archiving, and identify those aspects of the
preservation of electronic records that cannot be adequately addressed
either by state-of-the-art information technology or by technologies
under development. It will also address the feasibility of
commercializing new ideas from research. According to NARA, the second
assessment is to be completed 6 to 9 months after the first.
ERA Schedule Faces Significant Risks:
Although the ERA project is still in its initial stages, it is already
falling behind schedule. As shown in table 1, the initial deliverables
for design and acquisition are late: the vision statement, due March 1,
was not completed until April 18, and the concept of
operations,[Footnote 19] due April 1, was delivered in draft form on
that date and had not been finalized as of May 31. This lateness can be
attributed to flaws in how the schedule was developed. In its tracking
of ERA risks, NARA has acknowledged that the schedule for completion of
tasks was based on incomplete work projections, and that its deadlines
may not be achievable. Rather than constructing a plan based on
estimates of the amount of work and resources required to complete each
task, NARA constructed a “success oriented” schedule that was planned
around ensuring that ERA was funded beginning in fiscal year 2004.
In addition, the ERA program management office is behind schedule on
its efforts to develop the plans and guidance to strengthen its
capability for managing the acquisition and deployment of ERA. In July
2001, with the help of its systems development and acquisition
contractor, the office began focusing on developing these plans and
procedures. We tracked planned and actual completion dates for 13
policy and planning documents that the program management office needs
in order to develop and acquire a major system (according to NARA and
its contractor). To date, however, only 7 of the 13 documents have been
completed.[Footnote 20] The 7 that have been delivered were late by an
average of over 2 months. The initially planned delivery dates of the
other 6 documents have passed; on average these are late by almost 4
months.[Footnote 21]
Besides the approach taken to constructing the schedule, another
contribution to schedule slippage may be NARA’s slow start in hiring
full-time government staff for the ERA program management office. For
fiscal year 2002, NARA was authorized 16 positions for the ERA program
office. However, as of April 2002, NARA had only 5 full-time staff on
board.
NARA Is Strengthening IT Management Capabilities, but These Efforts Are
Incomplete:
Acquiring a major IT system such as the planned electronic archival
system is a significant challenge for a relatively small organization
like NARA, whose IT management capabilities are relatively limited. In
its fiscal year 2002 budget hearings, NARA indicated that it must
strengthen its IT management capabilities and infrastructure to support
the ERA program, and NARA is currently taking steps to do so in three
key areas: IT investment management, enterprise architecture, and
information security. None of these efforts, however, is yet complete.
Sound IT Management Capabilities Contribute to Success in Acquiring IT
Systems:
IT investment management provides a systematic method for agencies to
minimize risks while maximizing the return on investments. The Clinger-
Cohen Act requires agency heads to implement a process for maximizing
the value and assessing and managing the risks of an agency’s IT
investments. Our research of leading private and public sector
organizations’ IT management practices indicates that effective
investment management requires the use of defined and disciplined
investment management processes.
An enterprise architecture provides a description--in useful models,
diagrams, and narrative--of the mode of operation for an agency. It
describes the agency in both (1) logical terms, such as interrelated
business processes and business rules, information needs and flows, and
work locations and users; and (2) technical terms, such as hardware,
software, data, communications, and security attributes and standards.
An enterprise architecture provides these perspectives both for the
current environment and for the target environment, as well as a
transition plan for sequencing from the current to the target
environment. Managed properly, an enterprise architecture can clarify
and help optimize the dependencies and relationships among an agency’s
business operations and the underlying IT infrastructure and
applications that support these operations.
Information security is an important consideration for any organization
that depends on information systems to carry out its mission. Our study
of security management best practices, as summarized in our 1998
executive guide,[Footnote 22] found that leading organizations manage
their information security risks through an ongoing cycle of risk
management. This management process involves (1) establishing a
centralized management function to coordinate the continuous cycle of
activities while providing guidance and oversight for the security of
the organization as a whole, (2) identifying and assessing risks to
determine what security measures are needed, (3) establishing and
implementing policies and procedures that meet those needs,
(4) promoting security awareness so that users understand the risks and
the related policies and procedures in place to mitigate those risks,
and (5) instituting an ongoing monitoring program of tests and
evaluations to ensure that policies and procedures are appropriate and
effective.
NARA Is Improving Its IT Investment Management Processes:
The Clinger-Cohen Act of 1996 requires agencies to establish an IT
investment process that provides the means for senior management to
obtain timely information regarding the progress of investments in an
information system, including a system of milestones for measuring
progress in terms of cost, timeliness, quality, and the capability of
the system to meet specified requirements. Weak IT investment
management processes significantly increase the risk that agency funds
and resources will not be efficiently expended.
The first step toward establishing effective investment management is
putting in place foundational, project-level control and selection
processes. These foundational processes allow the agency to identify
variances in project cost, schedule, and performance expectations; to
take corrective action, if appropriate; and to make informed, project-
specific selection decisions.
The second major step toward effective investment management is to
continually assess proposed and ongoing projects as an integrated and
competing set of investment options. This portfolio management approach
enables the organization to consider the relative costs, benefits, and
risks of new and previously funded investments and thereby identify the
mix that best meets its mission, strategies, and goals.
NARA’s IT investment management policies and processes were assessed
and reported on by its inspector general (IG) in April 2000. The report
identified several strengths in NARA’s IT investment management
processes, including having an IT investment board, a defined process
for selecting projects, criteria to be applied in considering whether
to undertake a particular IT investment, ratings of each investment’s
breadth of impact, and a determination of the net benefits and risks be
identified for proposed investments. However, the IG identified
weakness and made 13 recommendations for strengthening NARA’s IT
investment management processes. NARA concurred with all
recommendations. While it has to date fully addressed only 2 of the
recommendations, it plans to resolve the remaining 11 issues by
September 30, 2002.
While NARA’s investment management process has several strengths and
NARA continues to improve process weaknesses, NARA has yet to complete
its efforts to establish a mature investment management capability.
Lacking a fully mature investment management process increases the risk
that the electronic archival system will not be implemented on time and
within budget, and that crucial resources and funds for meeting the
electronic records challenges will not be invested effectively and
efficiently. Specifically, if NARA management’s oversight of the ERA
program is not based on complete information (including comparisons of
the actual cost and schedule to the estimated cost and schedule, as
well as identification of project risks and benefits), the risk is
increased that NARA management will not be able to determine whether
the ERA program is having schedule or other problems and ensure that
corrective actions are taken.
NARA Is Developing an Enterprise Architecture:
The importance of enterprise architecture development, implementation,
and maintenance is a basic tenet of effective IT management. Used in
concert with other IT management controls, an enterprise architecture
can greatly increase the chances for optimal mission performance. We
have found that attempting to modernize operations and systems without
an enterprise architecture leads to operational and systems
duplication, lack of integration, and unnecessary expense.
Over the past several years, NARA has taken action to develop an
enterprise architecture. NARA has drafted a current architecture and is
working on a target architecture, but this work is incomplete.[Footnote
23] However, the process to develop the electronic archival system is
well under way. Without an enterprise architecture to guide its
development, NARA increases the risk that the planned electronic
archival system will be incompatible with existing and future
operations and systems, thus wasting resources and requiring that
unnecessary interfaces be built to achieve integration.
NARA Is Improving Information Security, but Has Not Yet Completed Key
Tasks:
NARA is currently strengthening its information security, having
recognized that it has numerous weaknesses. Significant security
weaknesses were identified by two IG assessments (conducted in fiscal
years 2000 and 2001) and a NARA-initiated vulnerability assessment of
its network (performed concurrently with the IG assessments). As a
result of these assessments, the Archivist of the United States
declared information security a material weakness in fiscal year
2000.[Footnote 24] Actions taken by the Archivist to addresses these
shortcomings and respond to recommendations identified in the reports
include establishing an information security program, updating and
developing new security policy documents, developing contingency plans
and business recovery plans, and strengthening firewalls across the
network to control inbound and outbound traffic. NARA said that it
would implement the IG’s recommendations by June 28, 2002, and by the
end of fiscal year 2002 it plans to have rectified the shortcomings
that led to its information security being declared a material
weakness.
However, although NARA is making progress in strengthening its
information security, two additional weaknesses could affect the ERA
program. First, NARA currently lacks a program for assessing agencywide
information security risks. Federal guidance requires all federal
agencies to establish comprehensive information security programs based
on assessing and managing risks.[Footnote 25] Risk assessments provide
a basis for establishing appropriate policies and selecting cost-
effective techniques to implement these policies. NARA intends to
develop an agencywide risk assessment capability in fiscal year 2003,
but it is not clear that this will allow vulnerability assessments to
be completed before ERA is developed. Without a method to identify and
evaluate risks, NARA cannot be assured that it has effective mechanisms
for protecting its information assets: networks, systems, and
information associated with ERA. Because a compromise of security in a
single poorly secured system can undermine the security of multiple
systems, NARA needs to complete vulnerability assessments of all
systems that will interface with ERA.
Second, because NARA lacks an enterprise architecture, it may have
difficulty addressing agencywide security. Federal guidance calls for
agencies to make security controls for systems consistent with and an
integral part of the enterprise architecture of the agency.[Footnote
26] Without an enterprise architecture that addresses security issues
agencywide, NARA cannot be sure that its current or future archiving
systems are adequately protected.
These weaknesses may be particularly significant for ERA, because this
system presents security issues that NARA has never before addressed,
according to an initial assessment report on ERA prepared by NARA’s
systems development and acquisition contractor.[Footnote 27] The
proposed distributed structure of ERA introduces the security risks
associated with the Internet--threats to the integrity of data and to
data accessibility. According to the Federal Bureau of Investigation,
Internet systems are threatened by hackers (who may be terrorists,
transnational criminals, and intelligence services) using information
exploitation tools such as computer viruses, worms, Trojan horses,
logic bombs, and eavesdropping sniffers.[Footnote 28] As Internet usage
increases, the Internet has become an increasingly tempting target, and
the number of reported Internet-related security incidents is
growing.[Footnote 29] The effect on ERA of the vulnerabilities of the
Internet would have to be assessed and addressed.
Conclusions:
In response to the challenges associated with managing and preserving
electronic records, NARA has performed an assessment of governmentwide
records management--an important first step that identified several
problems, including the inadequacy of guidance on electronic records,
the low priority generally given to records management, and the lack of
technology tools to manage electronic records. While NARA has plans to
improve its guidance and address the need for technology, it has not
yet formulated a strategy to deal with the stature of records
management programs across government. Further, it has no strategy for
acquiring the kind of comprehensive information on records management
that would be provided by systematic inspections and evaluations of
federal records programs. Without such a strategy, records management
will likely continue to be considered a low-priority “support” activity
lacking appropriate management attention, and NARA will not acquire
information needed to address problems in agency records management and
guidance. Inadequacies in records management put at risk records that
may be valuable: records providing information on essential government
functions, information that is necessary to protect government and
citizen interests, and information that is significant for the
historical record.
NARA’s effort to acquire an advanced electronic records archive is at
risk. NARA is not meeting its schedule for the ERA system, largely
because of flaws in how the schedule was developed. As a result, the
schedule will be compressed, leaving less time for completing essential
planning tasks. In addition, NARA has not yet improved IT management
capabilities that would reduce the risks inherent in its effort to
acquire ERA. Without these capabilities, NARA risks spending funds to
acquire a system that does not meet mission needs and requirements,
effectively work with existing systems, or provide adequate security
over the information it contains.
Recommendations for Executive Action:
To address the low priority given to records management programs across
government, we recommend that the Archivist of the United States
develop a documented strategy for raising agency senior management
awareness of and commitment to records management principles,
functions, and programs. Further, we recommend that the Archivist
develop a documented strategy for conducting systematic inspections of
agency records management programs to (1) periodically assess agency
progress in improving records management programs and (2) evaluate the
efficacy of NARA’s governmentwide guidance.
To mitigate the risks associated with the acquisition of an advanced
electronic archival system, we recommend that the Archivist reassess
the ERA project schedule. A revised schedule should be developed, based
on estimates of the amount of work and resources required to complete
each task, that allows sufficient time for NARA to:
* complete essential planning tasks and:
* strengthen its IT management capabilities by (1) implementing an IT
investment management process, (2) developing an enterprise
architecture, and (3) improving information security.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, which are reprinted in
appendix V, the Archivist of the United States generally agreed with
our recommendations but provided clarifications concerning records
management priority, inspections, and the ERA schedule. NARA also
provided technical comments, which we have incorporated as appropriate.
The Archivist agreed with our recommendation that NARA develop a
strategy for raising agency senior management awareness of and
commitment to records management principles, functions, and programs,
adding that the responsibility for oversight of records management is
not NARA’s alone, but is shared by the Office of Management and Budget
(OMB), the General Services Administration (GSA), and the heads of
federal agencies. Further, he acknowledged that more needs to be done
to have a major effect on agency leadership. The Archivist, however,
disagreed with our conclusion that NARA does not plan to address the
low priority generally given to records management.
Our conclusion was not meant to imply that NARA does not intend to
address the priority of records management. We acknowledge NARA’s past
efforts to raise awareness of the importance of records management and
its stated plans to further address this issue. Instead, our conclusion
reflects the fact that NARA’s written plan to reform federal records
management policies and practices--which NARA refers to as its Records
Management Initiatives--does not currently address this issue. We
believe that to be successful, NARA must document its plans to address
the low priority of records management programs across government,
including specific goals, strategies, and milestones. Such a plan is
critical in ensuring concurrence on planned actions among the key
players that NARA mentions, including federal agencies, GSA, and OMB;
that appropriate resources are assigned; and that NARA has the means to
track progress against its goals.
The Archivist also agreed with our recommendation that NARA develop a
strategy for conducting systematic inspections of agency records
management program, but noted that continuing its past inspection
program, as cited in the report, would not succeed. NARA disagreed with
our conclusion that it has no plans to address the issue of records
management inspections, noting that it plans to use risk management
analysis while leveraging its inspection resources. The Archivist said
that this approach would include an assessment of broad categories of
important records across agencies, agency-specific interventions, and
the use of NARA’s authority to report the results of evaluations of at-
risk records to OMB and the Congress.
We are not suggesting that NARA resurrect its past inspection program,
which it concluded was basically flawed. However, we also do not
believe that NARA’s current targeted assistance approach is an
appropriate substitute for systematic inspections and evaluations of
federal records programs. In regard to our conclusion, it is again
based on the fact that the written strategy for the Records Management
Initiatives does not address the need for systematic inspections. We
acknowledge NARA’s statement that it plans to use a risk-based approach
to addressing this issue, but we reiterate the need for a documented
plan with associated goals, strategies, and milestones.
In commenting on our recommendation that NARA reassess the ERA project
schedule, the Archivist stated that such a reassessment is prudent and
that NARA intends to conduct such reassessments repeatedly, both
periodically from an overall program management viewpoint and on a
continuing basis as part of its ERA risk management activity. The
Archivist noted that NARA is currently reassessing the schedule as part
of its refinement of the ERA acquisition strategy, and that this
reassessment will address the issues raised in our report.
Regarding the schedule for the ERA system, the Archivist noted that
while some program documentation was not completed on schedule, all
items on the ERA project’s “critical path” have been completed on time,
and NARA expects to meet all milestones on the critical path this year.
We disagree. As discussed in our report, the development of key program
documents--such as the ERA vision statement and the concept of
operations--were affected by delays. For example, the ERA vision
statement, planned for completion on March 1, 2002, was not completed
until April 18, 2002, approximately 6 weeks late. Similarly, the
concept of operations, due on April 1, 2002, and which NARA
documentation shows as being on the critical path, was delivered in
draft form on that date and had not been finalized as of May 31.
Falling behind schedule in the initial stages presents risks to
successful and timely completion of the ERA project and is one of the
reasons we are recommending that the agency reassess its schedule.
The Archivist also disagreed with our conclusion that if the results of
the two National Academy of Sciences assessments are not fully
reflected in the ERA requirements, there is added risk that the
technical strategy underlying the development of the system will prove
not to be optimal, and that alternatives will not have been considered.
The Archivist noted that NARA should receive the first National Academy
of Sciences report at a time when it expects to receive the industry’s
response to NARA’s request for information, and that the report will
provide an unbiased, expert view of the feasibility of building a
system that is inherently evolutionary, addressing the core problem of
digital preservation. According to the Archivist, NARA will factor both
the scientific and the industry views into its articulation of a draft
request for proposals. In regard to the second National Academy of
Sciences report, the Archivist noted that its primary purpose is to
provide input to NARA’s long-range plans for addressing the continuing
evolution of information technology and electronic records, and that
the report will be useful in revising the ERA research plan to address
new problems and opportunities identified by the experts, and in plans
for successive builds of the ERA system.
We acknowledge NARA’s clarification regarding the timing and use of the
two NAS studies and believe this approach should assist in developing a
system that will meet mission needs. Accordingly, we have revised our
recommendation to reflect this.
We are sending copies of this report to the Ranking Minority Member,
Subcommittee on Government Efficiency, Financial Management and
Intergovernmental Relations, House Committee on Government Reform, and
to the Ranking Minority Member, Subcommittee on Treasury, Postal
Service and General Government, House Committee on Appropriations. We
are also sending copies to the Archivist of the United States, the
Secretary of Housing and Urban Development, the Secretary of State, the
Secretary of Commerce, the Secretary of Veterans Affairs, and the
Administrator of NASA. This report will also be available on GAO’s home
page at http://www.gao.gov.
If you have any questions concerning this report, please call me at
(202) 512-6240 or Mirko J. Dolak, Assistant Director, at (202) 512-
6362. We can also be reached by E-mail at koontzl@gao.gov and
dolakm@gao.gov, respectively. Key contributors to this report were
Timothy Case, Barbara Collier, Jamey Collins, David Plocher, and Megan
Savage.
Linda D. Koontz
Director, Information Management Issues:
Signed by Linda D Koontz:
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to:
* determine the status of NARA’s efforts to respond to governmentwide
electronic records management problems and the adequacy of its future
plans and:
* assess NARA’s efforts to acquire an archival system for electronic
records.
As part of our assessment of NARA’s efforts to acquire an electronic
records archiving system, we were also asked to identify alternative
technologies under consideration for the long-term preservation of
electronic records.
To determine the status of NARA’s efforts to assess and respond to
governmentwide electronic records management problems and the adequacy
of its future plans, we reviewed federal legislation and NARA records
management guidance, available studies, and reports; surveyed NARA’s
appraisal archivists working with federal agencies; reviewed records
management activities and obtained the views of record managers in
selected federal agencies managing large volumes of electronic records-
-the Departments of State, Commerce, Housing and Urban Development
(HUD), and Veterans Affairs (VA), as well as NASA and the Patent and
Trademark Office; and reviewed legal challenges to federal electronic
recordkeeping practices, including Public Citizen v. John Carlin and
Scott Armstrong v. Executive Office of the President. We also reviewed
NARA’s documentation of its effort to redesign its approach and
guidance for the management of electronic records. As part of this
effort, we investigated whether agencies are scheduling their major
information systems and the related databases; to do so, we asked five
major agencies--Commerce, HUD, VA, State, and NASA--what portion of
their major information systems were scheduled and placed under the
agency records management program. We based our assessment on the
inventory of Year 2000 mission-critical systems reported by 24 major
agencies to the Office of Management and Budget.[Footnote 30] In
addition, to determine the status of the Library of Congress’ National
Digital Information Infrastructure and Preservation Program and its
relationship to NARA’s efforts to design and acquire advanced
electronic archival system, we discussed the program’s objectives and
schedule with Library of Congress officials.
To assess NARA’s efforts to acquire an archival system for electronic
records, we reviewed agency and contractors’ documentation for the
electronic records archive (ERA) program, including program and project
phasing; on the basis of federal requirements and information industry
practice, we assessed NARA’s effort to develop or enhance its
information technology capabilities, including information technology
investment management, enterprise architecture, and information
security.
To identify alternative technologies under consideration for the long-
term preservation of electronic records, we reviewed archival studies
and literature, and we surveyed selected digital preservation
approaches used by the information industry and selected national
governments. In addition, we contacted the archives of three
judgmentally selected foreign countries (Australia, Canada, and the
United Kingdom) that had been identified by records management
professionals as using advanced electronic records management and that
we had previously reviewed.[Footnote 31] We also contacted the Public
Record Office of Victoria, Australia; although this archive is not at
the scale of a national archive, we included it because it has employed
a unique technological approach to archiving electronic records.
We performed our work from June 2001 to May 2002 in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: Approaches to Archiving Electronic Records Provide Partial
Solutions:
The challenge of managing and preserving the vast and rapidly growing
volumes of electronic records produced by modern organizations is
placing pressure on archives and on the information industry to develop
a cost-effective long-term preservation strategy that will free
electronic records from the constraints of proprietary file formats and
software and hardware dependencies. Part of this strategy will involve
ways to capture and use information about the records to make them
accessible, as information in card catalogs does in traditional
libraries. After considerable research in this area, some agreement is
being reached on the metadata (data about data) required for preserving
electronic records, and some practical applications are using XML
(Extensible Markup Language[Footnote 32]) for creating such metadata.
However, there is no current solution to the electronic records
archiving challenge, and so archival organizations now rely on a
mixture of evolving approaches that generally fall short of solving the
long-term preservation problem. The four most common approaches--
migration, emulation, encapsulation, and conversion--are in use or
under consideration by the major archives. NARA is supporting the
investigation of a new approach involving records conversion (known as
persistent object preservation), but this has yet to mature.
Recognizing that archival solutions may be some time off, companies in
the information industry are relying on off-the-shelf technology for
providing access to billions of electronic records. These commercial
archives, however, concentrate on electronic records of types that are
relatively uniform in comparison to those that a government archive
must address.
Archiving Requires Documentation of Attributes and Relationships of
Records:
Archives use catalogs of various types to capture information about
records, information that is critical for sharing, storing, managing,
and accessing records effectively--particularly in the context of
millions of records. Because such information is data containing
descriptive information about other data, it is referred to as
metadata. Metadata are a central element of any approach to ensure that
preserved records are functional. For electronic records, the metadata
needed are often more extensive than information in traditional
catalogs, including information that is important for preservation.
Metadata Provide Information Necessary to Describe Electronic
Collections:
The creation of accessible software-and hardware-independent
electronic records requires that all materials that are placed in
archives be linked to information about their structure, context, and
use history. Metadata to be associated with electronic records may
include information about:
* the source of the record;
* how, why, and when it was created, updated, or changed;
* its intended function or purpose;
* how to open and read it;
* terms of access, and:
* how it is related to other software and records used by the
originating organization.
These metadata must be sufficient to support any changes made to
records through various generations of hardware and software, to
support the reconstruction of the decisionmaking process, to provide
audit trails throughout a record’s life cycle, and to capture internal
documentation. Without an adequately defined metadata structure, an
effective electronic archive cannot be constructed.
Numerous research projects have examined the question of defining
metadata that would be sufficient to ensure digital preservation.
Although archives experts note that unresolved issues remain, the work
on preservation metadata is beginning to move from the research area to
practice. The Public Record Office Victoria (Australia), a state
archive, has published standards for the management of electronic
records that includes a metadata model originally developed by the
National Archives of Australia.
For incorporating metadata, the Victoria archive mandates the use of
XML. XML is being actively considered by archives and researchers as a
promising approach to generating metadata.
XML Enables Infrastructure-Independent Description of Electronic
Records:
XML is a flexible, nonproprietary set of standards for annotating
(“tagging”) data with semantically rich labels that permit computers to
process files on the basis of their meaning.[Footnote 33] Like the more
familiar HTML (Hypertext Markup Language) files used on the World Wide
Web, XML files can be easily transmitted via the Internet, and with
appropriate software, they can be displayed by Web browsers. The
difference is that HTML is used only for telling computers how to
display information for a human being to view, whereas the semantically
based XML tags allow computers to automatically interpret and process
XML files.
XML is called extensible because it is not a fixed format. Instead, XML
is actually a “metalanguage”--a language for describing other
languages--which allows the design of customized markup languages for
limitless different types of documents. Thus, although in the beginning
stages of adoption, XML is viewed as a promising format for a wide
range of applications.[Footnote 34]
Several XML attributes make it attractive for archive applications. The
semantic nature of XML tags makes XML suitable for recording metadata.
Its extensibility would allow archives to expand their systems to
accommodate evolving needs. As an open standard, it reduces the
problems of proprietary software. Further, because they are basically
text files, XML files can be readily interpreted by disparate computer
systems. Even without the mediation of software, human beings can
interpret an XML-tagged file, because XML tags are human readable (see
fig. 4). This quality allows them to be preserved both on computer
media and on paper (so that they would be readable both by human beings
and automatically through optical character recognition).
Figure 4: Sample of XML Version of State Department Telegram:
[See PDF for image]
Source: San Diego Supercomputer Center.
[End of figure]
Figure 4 is an example of a text document--a World War II vintage
telegram in the Franklin D. Roosevelt library--converted to XML
format.[Footnote 35] The XML “tags” provide the means for identifying-
-and retrieving--key pieces of information, such as date sent,
addressee, and place of sender. If the file were viewed in an XML-
compliant Web browser, the tags in the telegram would not be visible,
and the telegram itself could be displayed in various ways for the
convenience of the human reader. At the same time, the presence of the
tags permits computer systems to perform powerful searches and exchange
data.
XML is also used by the National Archives of Australia,[Footnote 36]
which converts files from their native formats to XML versions, while
retaining a copy of the original source file. The Australian archives
has also developed a metadata model, but it has not yet determined its
final preservation metadata requirements.
Electronic Archives Take Combinations of Approaches to Preservation:
For long-term preservation of electronic records, electronic archives
must address the problems of obsolescence and aging of storage media,
the dependence of electronic records on the software and hardware on
which they were created, the complexity of electronic records, and the
massive volumes of records created by often decentralized systems.
According to one archival expert, a viable strategy for long-term
preservation for electronic records would call for “a long-lived
solution that does not require continual heroic effort or repeated
intervention of new approaches every time formats, software, or
hardware paradigms, document types, or recordkeeping practices
change.”[Footnote 37]
Since no one solution is yet available that addresses all the problems,
most archives and other institutions that preserve records use a
variety of approaches, often in combination. The current approaches for
dealing with the technical issues associated with long-term electronic
archiving are:
* technology preservation--maintaining old technologies to allow access
to old formats;
* emulation--using software running on new-technology platforms to
mimic old technologies;
* migration--transferring digital materials from one hardware/software
configuration to another, or from one generation of computer technology
to a subsequent generation;[Footnote 38]
* encapsulation--grouping together a digital object with other
information necessary to provide access to that object; and:
* conversion to standard formats--transforming records into objects
that are relatively software and hardware independent.
The recent development of durable analog storage media (that is, media
that preserve images of human-readable documents, much as microfiche
does) suggests the possibility of approaches that combine those above
with the use of analog rather than digital media.[Footnote 39]
Technology Preservation Is a Short-Term Solution Only:
Technology preservation refers to the practice of maintaining outdated
equipment well after it is useful in everyday business processes. Under
this approach, electronic files or records, which are saved in their
native formats, continue to be accessible through the use of original
hardware and software. In the short term, this is a simple and cost-
effective approach, and some organizations do maintain older
information systems only to be able to access their records.[Footnote
40]
However, this approach is at best an interim solution to the problem of
the dependence of electronic records on the software and hardware on
which they were created. The solution eventually fails, because
maintaining the original technology grows increasingly difficult and
costly with the passage of time. Further, it does not solve the problem
of aging and obsolescent storage media, which would also grow more
difficult if not impossible to replace. Issues of cataloging and
metadata are also not addressed by this approach. With the seemingly
endless introduction of new hardware and software, the sheer number of
differing formats and applications, and the cost to maintain any and
all systems, technology preservation is not a feasible strategy for the
long term.
Emulation Is Currently More Theoretical Than Practical for Electronic
Archiving:
A proposed approach to the problem of software and hardware dependence
is emulation, which aims to preserve the original software environment
in which records were created. Emulation software mimics the
functionality of older software (generally operating systems) and
hardware. Under the emulation approach, data files are stored along
with copies of the creating software as well as software that emulates
the hardware/operating system required to run the software.[Footnote
41] This technique seeks to recreate a digital document’s original
functionality, look, and feel by reproducing, on current computer
systems, the behavior of the older system on which the document was
created. In other words, an emulation strategy means that nothing is
done to the original electronic file; rather, the original environment
is recreated. Since the original file remains unaltered, emulation also
offers a solution to the problem of preserving the original
functionality and the “look and feel” of complex digital files.
Emulation has been in practical use on computer systems for many years:
* IBM mainframes emulate previous mainframes in order to support legacy
systems and allow several generations of operating system versions to
be run.
* Operating system emulators allow a single computer to provide more
than one operating environment (such as Macintosh and Windows).
* Emulation software allows desktop computers to run video games and
legacy video gaming systems.
However, according to one archival expert, emulation has not yet been
applied to preserving archival documents in any systematic way.
Although emulation could in theory be part of a solution to the problem
of hardware and software independence, it is just beginning to be
explored as an archival approach. Emulation is under consideration as
one of various archiving approaches by the United Kingdom’s Public
Record Office.[Footnote 42]
One problem unique to emulation is that intellectual property rights
issues may be involved when either operating systems or applications
are emulated.[Footnote 43] Even if the software and hardware are
obsolete, their copyrighted specifications are not likely to be
released for the benefit of archival integrity. Further, the use of an
emulated operating system or application introduces outmoded programs
into a modern environment, requiring users to understand how to use
them; in other words, using the old software may require expert
knowledge of the outdated systems--knowledge that is likely to
disappear.
Other problems with emulation include the increasing possibility that
software failures will occur as the old systems continue to age and the
pool of expertise concerning them shrinks. Emulation assumes that the
emulated software will continue to run without maintenance. As the year
2000 date conversion problem showed, this is not a safe assumption, as
it is possible that software may contain bugs that may eventually cause
catastrophic loss of information.[Footnote 44] Further, an emulation
approach depends on several components working together (the emulation
software, the original application, and the data); as the number of
components increases, so does the risk of failure.
Migration of Both Media and File Formats May Preserve Records:
Migration refers to the periodic transfer of digital materials from one
format configuration to another, or from one generation of computer
technology to a subsequent generation. In the context of archiving,
migration can refer both to the media on which information resides
(conversion from older to newer media or forms of media) and to the
formats in which it is encoded (conversion from one file format or
system to another).
The first type of migration, media migration, has been so far
unavoidable: it is the standard approach to the problem of media
obsolescence and aging. In media migration, records are moved from
older storage media to newer media, either to avoid the obsolescence or
decay of an older medium or to upgrade to a more advanced medium (often
to increase storage capacities while reducing cost). However, media
migration alone does not ensure that the electronic records transferred
to the new media continue to be accessible, especially if their format
is obsolete. As new storage technologies evolve--including extreme-
longevity analog media such as the High Density Rosetta disk discussed
later in this appendix--the migration process may become less frequent
and more efficient.
The second type of migration, format migration, is a process of
preservation by conversion: specifically, format migration is defined
as rearranging the original sequence of structural and data elements of
a file to conform to another configuration. Such migration occurs
whenever older systems and formats are displaced by newer, often more
advanced systems and formats. Many organizations have, for example,
converted old database systems to newer systems, and in the process
they have converted the formats of the records they contain.
The major difficulty with format migration is the risk of altering
records during conversion from the source to the target format. For
conversions to be successful, those performing the transition must have
knowledge of the original application and data formats,[Footnote 45]
and the more complex the file structure, the more important this
knowledge is. Whether the application is commercial or generated in
house, over time this knowledge may be lost and with it the ability to
perform a successful migration. For such reasons, migration has been
described as cost effective only for certain types of records that
remain in operational use.[Footnote 46] For records in use, problems
with imperfect conversion are more likely to be discovered by users,
and organizational resources are more likely to be devoted to ensuring
that these are resolved or mitigated.
Further, although format migration has occurred in many contexts in the
past, it has not been extensively used in archiving. Most electronic
archives are relatively new, so they are dealing with records in
current formats created by systems that are still operational. Thus,
they have not yet experienced the need to incorporate format migration
into their processes. Rather, they treat migration as a future option
for dealing with preserving the types of records that they are
currently storing.
As a strategy for the long-term preservation of electronic records,
relying on format migration is risky. Migration as a preservation
strategy would have to be a continuous process, with conversions
occurring whenever a new format needed to be introduced. With each
format conversion, the possibility of loss would be increased, and the
more complex the record, the more the possibility of loss. Thus,
migration is at best an imperfect solution as it can potentially lead
to the loss of record integrity.
Migration was selected by the United Kingdom’s Public Record Office as
its current archival approach. In addition to migration, the Public
Records Office is also considering using emulators and viewers to
access archived files in their native formats.
Encapsulation Preserves Both Records and Information about Records:
Encapsulation is the combining of several elements to create a new
single entity; in the context of archiving, the elements would be the
records themselves, metadata identifying and describing the records,
and possibly other elements (such as viewers enabling the records to be
read).[Footnote 47]
Unlike migration, encapsulation does not necessarily involve a change
in the original file format. If the format is unchanged, encapsulation
would avoid the problem of loss of integrity that migration entails.
Leaving records in their native formats would leave open the
possibility of processing the objects with the original software, and
it would also permit subsequent transformation of the encapsulated
records using methods that were not available when the records were
originally placed into the archives.[Footnote 48]
Encapsulation is currently being used by the Victoria Public Records
Office in Australia.[Footnote 49] The Victoria archive uses XML to
encapsulate records along with standardized metadata describing each
record in a Victorian Electronic Record Strategy (VERS)
format.[Footnote 50] The VERS format mandates the use of XML to
describe and encapsulate records. However, the Victoria archive has
only recently begun applying its process, and its electronics records
collection is as yet small (described as “a few records”), so it is
premature to judge its effectiveness for large-scale, long-term
preservation.
Conversion to Standard Formats Makes Records Less Dependent on Hardware
and Software:
Conversion transforms records into standard text formats such as
ASCII[Footnote 51] or XML to increase their independence from hardware
and software. This approach is currently used by the National Archives
of Canada[Footnote 52] and by NARA (both of which accept databases in
ASCII format), as well as the National Archives of Australia,[Footnote
53] which converts files from their native formats to XML, while
retaining a copy of the original source file.
The Victoria archives is using a combination of conversion and
encapsulation in its preservation approach, because before
encapsulating selected types of documents, it is requiring their
conversion (where appropriate) to Adobe Systems’ Portable Document
Format (PDF). PDF is a compact format that preserves all the fonts,
formatting, graphics, and color of any source document, regardless of
the software and hardware used to create it. Although PDF is a
proprietary file format, PDF files can be shared, viewed, navigated,
and printed exactly as intended by anyone with the freely distributed
Adobe Acrobat Reader.
The primary shortcomings of the conversion approach are the limitations
and the longevity of the selected standard.[Footnote 54] For example,
converting databases to ASCII format limits their usefulness: the
conversion of a relational database to flat ASCII database tables will
eliminate the embedded information about the relationships among data
elements.[Footnote 55] Conversion to XML, on the other hand, may
involve fewer such limitations, but it depends on the XML standard
remaining in use and accessible.
NARA is investigating an advanced form of conversion combined with
encapsulation known as persistent object preservation (POP). Under this
approach, records are converted by XML tagging and then encapsulated
with metadata. According to NARA, the persistent object transformation
approach would make electronic records self-describing in a way that is
independent of specific hardware and software. The architecture for POP
is being developed through the National Partnership for Advanced
Computational Infrastructure. The partnership is a collaboration of 46
institutions nationwide (including NARA) and 6 foreign affiliates, with
the San Diego Supercomputer Center serving as the technical resource.
According to NARA, persistent object preservation would accommodate
preservation of persistent but evolving collections by providing the
ability to dynamically reconstruct data collections on new technology.
The result would be a system that could upgrade individual technical
components and migrate media while safeguarding the archived records.
POP would thus not only enable the use of future, advanced
technologies, it would also reduce threats to integrity and
authenticity, because POP would not require changes in the preserved
data. However, POP may not be sufficiently mature to be translated into
system design.
Migration to Durable Analog Media May Offer Hybrid Approach:
An archive that stores records digitally must use media migration as a
preventive measure to avoid decay and obsolescence. However, the use of
analog storage offers a possible alternative that may diminish the need
for media migration. Whereas all current media now record digital
information as 0’s and 1’s, analog storage of documents is suggested by
a new product, called a High Density Rosetta, developed by Norsam
Technologies (see fig. 5).
Figure 5: The Long Now Foundation Rosetta Disk Language Archive:
[See PDF for image]
Source: Rolfe Horn, courtesy of the Long Now Foundation.
[End of figure]
The nickel-plated disk, which has a life expectancy that is orders of
magnitude longer than current electronic media,[Footnote 56] allows the
analog storage of information and images that are readable via an
electron or optical microscope. Such a medium could avoid the
obsolescence created by software-reliant media. The plates are
physically inscribed by an ion beam, through a process known as ion
milling.[Footnote 57] This medium can store on each side of its 2-inch
plate over 196,000 pages (with electron microscope retrieval) or 5,000
to
18,000 pages (with optical microscope retrieval). Using a text-based
coding
system such as XML would permit both coded (software readable) and
image
(human readable) information to be stored on this long-lived medium.
The
migration issue would then arise if new software were to be adopted,
but
the image information would persist.
The High Density Rosetta is being used by the Long Now Foundation to
create an extreme-longevity archive of selected languages.[Footnote 58]
According to the foundation, 50 to 90 percent of the world’s languages
are predicted to disappear in the next century, many with little or no
significant documentation. As part of the effort to secure this
critical legacy of linguistic diversity, the foundation initiated the
Rosetta Project,[Footnote 59] an effort to develop a contemporary
version of the historic Rosetta Stone. The project’s goal is the
development of a permanent archive of 1,000 languages. For storage of
this archive, the project is using the High Density Rosetta to micro-
etch text of archived languages at a scale readable by a 1,000-power
optical microscope.
Information Technology Industry Relies on Off-the-Shelf Technologies to
Provide Access to Electronic Collections:
While government and academic institutions are searching for a
permanent solution to electronic records archiving problems, the
private sector, also concerned about and affected by the potential loss
of electronic records, relies on existing information architectures and
off-the-shelf technologies to make accessible massive volumes of
electronic records dating back over two decades. These archiving
achievements do not meet the rigorous requirements for permanence and
authenticity that are demanded by a government archive, nor are their
owners required to process, store, and access the full range of complex
file formats encountered by governments. However, they do illustrate
the capability to provide storage and access to large quantities of
data. Two of the most notable private sector efforts are the Internet
Archives and the Google archive of Usenet messages.
Internet Archives:
The Internet Archives has created a digital library of Internet sites
and other born-digital cultural artifacts. It is attempting to archive
the entire publicly available Web, offering free access to researchers,
historians, scholars, and the general public. Anyone with access to the
Internet can, through the Internet Archives Web site,[Footnote 60]
navigate the Web at any moment in time from 1996 to the present. This
collection of Web pages contains over 100 terabytes, or 10 billion Web
pages, and it is currently growing at a rate of 12 terabytes per month.
The stored and accessible 100 terabytes is larger than the amount of
data contained in the world’s largest libraries, including the Library
of Congress, making it the largest known database in existence. Without
the efforts of the Internet Archives, these 10 billion Web pages might
have been lost. As it is, they provide a record of the origins and
evolution of the Internet, as well as a reflection of societal
interests and opinions at different moments in time. This is
particularly true in the case of Web sites such as those of
presidential candidates (see fig. 6) and of monumental events such as
the September 11 attacks, both of which have prominence on the Internet
Archives Web site as “Special Wayback Collections.”:
Figure 6: Internet Archive Collection of Presidential Candidate Web
Sites:
[See PDF for image]
Source: Internet Archives.
[End of figure]
According to the Internet Archives, it has achieved inexpensive storage
on a major scale: it uses off-the-shelf technology at a cost of about
$4,000 per terabyte. As a preservation strategy, the Internet Archives
currently uses media migration to avoid media obsolescence and take
advantage of technological advances to reduce costs. As a safety
measure, backup copies of a part of the collection are also created.
Google:
Google claims to have the largest index of Web sites available on the
World Wide Web and the industry’s most advanced search technology.
Google’s Web site also contains an archive of Usenet messages that
cover the past 20 years (see fig. 7).[Footnote 61] Usenet is a
collection of text messages that are posted on Internet electronic
bulletin boards. These bulletin boards--which existed before E-mail,
Web browsers, and the Web itself--provide avenues for communication in
an open forum, allowing others to read and reply. Some notable “posts”
included in Google’s Usenet Archives are the first post mentioning
Microsoft (1981), the first post mentioning a compact disc (1982), and
the posts sent just after the September 11 attacks.
Figure 7: Google’s Usenet Archive:
[See PDF for image]
Source: Google.
[End of figure]
Google currently provides access to more than 700 million messages
dating back to 1981, and this number is rapidly increasing. Google’s
collection is by far the most complete collection of Usenet articles
ever assembled. Before Google’s acquisition of the archive, posts
without activity were usually deleted from the live discussion forums
after a few days or weeks, and therefore they were not viewable or
searchable by users. Some feel that Google’s Usenet archive is an
irreplaceable and invaluable reference, representing “the human side
of the Internet” through first-hand accounts of historical events.
[End of section]
Appendix III: NARA’s Electronic Records Guidance Has Evolved:
A review of the development of electronic records guidance issued by
the National Archives and Records Administration (NARA) over the last
several decades demonstrates the extent to which the rapid evolution of
information technology has posed significant challenges for NARA in its
role of providing guidance to federal agencies concerning the
management of electronic records under the Federal Records
Act.[Footnote 62]
NARA provides guidance for electronic records management and
disposition largely through two sets of guidance:
* the electronic records management regulation, which provides general
responsibilities for agency management of electronic records;[Footnote
63] and:
* the general record schedules, which provide disposal authorization
for specific categories of temporary records common to most
agencies.[Footnote 64]
The history of these two sets of guidance reflects the evolution of
NARA’s electronic records guidance.
Electronic records management was given a formal role in 1968 when
NARA, then the National Archives and Records Service (NARS) of the
General Services Administration (GSA), established a unit to develop
policies for selecting and preserving electronic records. This Data
Archives Staff undertook to develop three sets of guidance: (1)
inventory guidance--forms for inventorying magnetic tape files; (2)
environmental guidance--recommendations for proper handling and
storage of magnetic tape; and (3) GRS 20--a general records schedule
for computerized records.
Of that guidance, GRS 20 emerged as NARA’s first significant electronic
records guidance. It was intended to cover electronic records created
by mainframe applications in the then-dominant agency data processing
operations. The major purpose was to address the efficient disposition
of those electronic records, including destruction of unneeded
temporary records and transfer to NARS (NARA) of permanent records.
The 1972 GRS 20, entitled Data Automation Program Records, stated,
“This schedule covers machine readable records, related documentation
required for their servicing, and files related to the automatic data
processing (ADP) procurement, operations, and management functions.”
GRS 20 divided these records into categories that “correspond roughly
to the typical organizational and functional structure found in most
ADP installations and their parent organizations.”[Footnote 65]
According to recent NARA summaries, the 1972 GRS 20 was meant “to
provide disposal authority for specific categories of temporary records
associated with mainframe applications. Excluded from its coverage, and
all subsequent revisions, were the types of records generated by large
data systems that might have archival value.”[Footnote 66] The clear
meaning of the 1972 GRS 20, however, was that it was not meant merely
to identify and provide for efficient disposal of “ancillary materials
common to most data processing operations.”[Footnote 67] Quite the
contrary, the guidance identified a range of records that should be
scheduled through filing of a Standard Form 115. These ranged from
various temporary records to potentially permanent records, such as
master data files.
GRS 20 was revised in 1977.[Footnote 68] While the 1977 revision
restructured the 1972 electronic records categories, it retained the
earlier purpose of providing disposition instructions for virtually all
records associated with data processing operations--temporary and
permanent, program and administrative.[Footnote 69]:
In 1983, GSA issued Bulletin FPMR B-127, Archives and Records, which
provided guidance on records created or maintained “using personal
computers and electronic information storage or transmission equipment
(electronic filing and electronic mail).”[Footnote 70] According to the
bulletin, “The proliferation of personal computers in many Federal
agencies and the implementation of sophisticated electronic filing and/
or mail systems has created a need for adaptation of traditional
records management techniques for the control and disposal of records
and information.” The bulletin then reiterated that the disposition of
all records regardless of physical form is controlled by the Federal
Records Act and instructed agencies to ensure “that appropriate
internal controls are instituted to prevent the loss or alienation of
official records created or acquired in electronic form.”:
Two pieces of similar guidance followed in 1985. First, NARA issued
Bulletin 85-2 to provide general guidance “on how to manage records
created, stored, or transmitted using personal computers or other
electronic office equipment including word processors.”[Footnote 71]
This bulletin again rooted electronic records management in the
fundamental requirements of the Federal Records Act: “The creation,
maintenance, and disposition of all official records regardless of
physical form is controlled by the provisions of [the Federal Records
Act and implementing regulations].”:
Two weeks after issuing Bulletin 85-2, NARA issued an ADP Records
Management regulation.[Footnote 72] This rule was the first version of
the regulation still found at 36 CFR 1234. The rule consolidated
guidance consistent with the goals of the 1968 Data Archives Staff,
requiring each agency (in very summary terms) to:
* establish a program for the management of ADP records, including
classifying, preserving, and scheduling machine-readable records; and:
* ensure proper care, handling, and storage of magnetic computer tapes
and disk packs.
The next major step in the evolution of NARA’s electronic records
guidance occurred in the 1988 revision of two general records
schedules: GRS 20, now entitled Electronic Records, and GRS 23, Records
Common to Most Offices within Agencies.[Footnote 73] The revisions
significantly modified the scope of both general records schedules and,
for the first time, provided disposal authority for personal computer
records in GRS 23.
With regard to GRS 20, the 1988 revision altered its scope, stating,
“This schedule applies to disposable electronic records routinely
stored on magnetic media by Federal agencies in central data processing
facilities.” As opposed to the broad purpose of the 1972 and 1977
versions, which had been to provide disposition guidance for all
electronic records associated with data processing operations, the 1988
GRS 20 discussed only disposable records. All references to scheduling
records were removed. This change was not limited, however, to GRS 20.
It reflected a NARA decision that all general records schedules should
pertain only to disposable records. The intent was to rely on other
guidance to provide instructions about scheduling and disposition of
permanent records, such as the regulation at 36 CFR 1234 and the
Appraisal Guidelines for Permanent Records, now published as an
appendix in NARA’s Disposition of Federal Records handbook.
The second major change in 1988 was the GRS 23 treatment of records
generated on personal computers. Like the 1988 GRS 20, the 1988 GRS 23
was explicitly limited to disposable records: “The records covered by
this schedule relate to routine internal administrative and
housekeeping activities.” GRS 23 provided disposal authority for
temporary administrative records generated by end-user applications on
stand-alone or networked computers. This included word processing
files, spreadsheets, and administrative databases. In addition to
authorizing the destruction of administrative or housekeeping records
when no longer needed, the 1988 GRS 23 authorized the deletion of
electronic versions of records created after they were printed to hard
copy, unless the records were maintained only in electronic form. If
the electronic record was maintained only in electronic form, it could
be deleted only after the expiration of the retention period authorized
for the hard copy by the GRS or a NARA-approved SF 115. As NARA
subsequently stated, its acceptance of paper recordkeeping for
electronic records was based on the assessment that even with the
growing use of computers, “agencies continued to maintain records
produced with office automation applications in organized paper files,
especially since end-user applications were not designed to classify,
index, and maintain documents for their authorized retention period …”
Thus, the revised GRS authorized deletion of word processing and E-mail
records after they had been copied to paper or microform.[Footnote 74]
The 1988 revisions to GRS 20 and 23 were followed by the 1990 revision
to NARA’s electronic records management regulation.[Footnote 75] This
revision continued the purposes of the 1985 bulletins, but provided
more detailed mandates for “procedures to manage electronic records, to
provide for the selection and maintenance of electronic storage media,
and to follow the legal requirements for the disposition of such
records.” Agency requirements under this still valid and largely
unchanged regulation include the following:
* develop and implement an agencywide electronic records management
program;
* establish procedures for addressing records management requirements
before approving new electronic records systems or enhancements to
existing systems; and:
* specify the location, manner, and media in which electronic records
will be maintained to meet operational and archival requirements, and
maintain inventories of electronic records systems.
While NARA endeavored to create a comprehensive electronic records
management scheme through the combination of affirmative guidance, such
as the 1990 regulation, and the revised general records schedules, the
GRS 20 principle that paper printouts could substitute for electronic
records became the focus of controversy through a lawsuit challenging
the 1989 destruction of White House E-mail tapes. The case, Armstrong
v. Executive Office of the President, spanned several years and
involved multiple issues and court rulings. In a 1993 ruling in that
case, the U.S. Court of Appeals ruled that paper printouts of E-mail
messages were not adequate substitutes for electronic versions stored
on computer tapes because they “may omit fundamental pieces of
information which are an integral part of the original electronic
records, such as the identity of the sender and/or recipient and the
time of receipt.”[Footnote 76] Thus, the court rejected the
government’s argument that “electronic records are merely ‘extra
copies’ of the paper versions,” and concluded that “since there are
often fundamental and meaningful differences in content between the
paper and electronic versions of these documents, the electronic
versions do not lose their status as records and must be managed and
preserved in accordance with the FRA.”:
Largely in response to the court’s findings, NARA revised GRS 20 in
1995.[Footnote 77] First, as an organizational matter, it moved the
electronic records instructions from GRS 23 into GRS 20 in order to
have a single general schedule for all disposable electronic records.
This resulted in combining instructions for the broad format categories
of word processing files, electronic mail records, and electronic
spreadsheets with those for specific functional categories of
administrative records, such as backup files, finding aids, and systems
operations records. Second, as a substantive matter, NARA now
instructed agencies to “identify records created using office
automation and to maintain them in a recordkeeping system that
preserves their content, structure, and context for their required
period.” According to the GRS,
“Only after the records have been properly preserved in a recordkeeping
system will agencies be authorized by GRS 20 to delete the versions on
the electronic mail and word processing systems. As indicated, most
agencies have no viable alternative at the present time but to use
their current paper files as their recordkeeping system. As the
technology progresses, however, agencies will be able to consider
converting to electronic recordkeeping systems for their records.”:
Thus, NARA stated in the 1995 GRS, “Program records that have been
transferred to the recordkeeping system will not be affected by GRS
20.” However, because NARA accepted the use of paper files as
appropriate recordkeeping systems for electronic records, this logic
permitted the disposal of electronic versions of records that required
retention or permanent preservation. Accordingly, while GRS 20 did not
authorize the destruction of program records, it did permit the
destruction of electronic copies of those records.
In 1997, a Federal District court, in Public Citizen v. John Carlin,
overturned the 1995 GRS 20, finding that it did not go far enough to
direct agencies to protect electronic records.[Footnote 78] The court
ruled that NARA should not have treated electronic records as
disposable simply because they could be copied into another form:
“[The] differences between electronic and paper records illustrate the
fact that the administrative, legal, research, and historical value of
electronic records is not always fully captured--indeed, is usually not
captured--by paper or microfiche copies. Electronic records therefore
do not become valueless duplicates or lose their character as ‘program
records’ once they have been printed on paper; rather, they retain
features unique to their medium.”:
The court also found that NARA failed to perform its statutory duty to
evaluate the value of records for disposal: “By categorically
determining that electronic records possess no administrative, legal,
research or historical value beyond paper print-outs of the same
document or record, the Archivist has absolved both himself and the
federal agencies he is supposed to oversee of their statutory duties to
evaluate specific electronic records as to their value.”:
In response to the district court ruling, NARA established an
Electronic Records Work Group to review the 1995 GRS 20 and make
recommendations for revisions. It also issued a number of pieces of
guidance to reflect the District Court’s ruling.[Footnote 79]
On August 6, 1999, the U.S. Court of Appeals for the D.C. Circuit
upheld NARA’s GRS 20, reversing the District Court decision that had
overturned the 1995 GRS 20.[Footnote 80] The Court of Appeals rejected
the lower court’s reasoning that NARA had authorized destruction of all
types of word processing and E-mail records without regard to content:
“GRS 20 does not authorize disposal of electronic records per se;
rather, such records may be discarded only after they have been copied
into an agency recordkeeping system.”:
The court acknowledged that an electronic recordkeeping system would be
superior to a paper recordkeeping system, but it also agreed with NARA
that agencies should be free “to maintain their recordkeeping systems
in the form most appropriate to the business of the agency.” Thus the
court said,
“We agree with Public Citizen that electronic recordkeeping has
advantages over paper recordkeeping, but our duty as a reviewing court
is to ask only whether the Archivist’s policy choice is arbitrary or
capricious; manifestly it is not. All agencies by now, we presume, use
personal computers to generate electronic mail and word processing
documents, but not all have taken the next step of establishing
electronic recordkeeping systems in which to preserve those records. It
may well be time for them do so, but that is a question for the
Congress or the Executive, not the Judiciary, to decide.”:
Finally, the court found that the 1995 GRS 20 met the Armstrong test of
requiring that electronic records be stored in a manner that captures
all relevant transmission data.
As a result of the Court of Appeals ruling, NARA instructed agencies to
again use the 1995 GRS 20 to dispose of temporary electronic records
after recordkeeping copies were filed in electronic, paper, or
microform recordkeeping systems.[Footnote 81] NARA did say, however,
“We believe there may be better alternatives to GRS 20 for disposition
authority for electronic copies of program records and expect to
develop those alternatives as part of a comprehensive review of the
policies and procedures for scheduling and appraisal of records in all
formats. The Court decision provides the Government time to include
electronic copies in this overall review. Our review may result in
significant changes in the way that agencies schedule their records in
the future. When we have completed this review, we will promulgate new
guidance.”:
On October 10, 2001, NARA published a notice seeking public comment on
a petition for rulemaking filed by the Public Citizen Litigation Group
(a plaintiff in both Public Citizen v. John Carlin and Armstrong v.
Executive Office the President) requesting NARA to revise its
electronic records management regulations.[Footnote 82] In this notice,
NARA stated that it was currently “evaluating alternatives to GRS 20
for disposition authority as part of a comprehensive review of the
policies and procedures for scheduling and appraisal of records in all
formats.” As of May 2002, this review was ongoing.
[End of section]
Appendix IV: Agencies Are Managing Large Volumes of Important
Electronic
Records:
Agencies are facing the complex challenge of managing electronic
records and in some cases maintaining these records on a long-term
basis. For example, because of their particular missions, NASA, the
Patent and Trademark Office, Veterans Affairs (VA), and the State
Department must each electronically manage millions of electronic
records, either long-term or permanently. In some instances, the
volumes of electronic records that these agencies manage are far larger
than the volumes of permanent electronic records that NARA currently
archives. The experiences of these agencies highlight electronic
records management and the gaps in existing guidance.
National Aeronautics and Space Administration:
NASA is committed to the long-term preservation of massive volumes of
electronic space science data and images of our solar system. The
observational data sets from NASA missions record the continually
changing aspects of our Earth and represent an asset that must be
retained in a findable, accessible, and usable state. The agency
proposed to permanently maintain these data within the agency in order
to support future science usage. Presently, NASA’s National Space
Science Data Center archives over 20 terabytes of digital space science
data from past and present NASA missions, of which 3 terabytes are
currently electronically accessible. In addition, the Hubble Space
Telescope has created a data archive of over 7 terabytes of images of
our solar system, and continues to archive an additional 3 to 5
gigabytes every day. Archiving and ensuring data integrity of all these
electronic records require periodic data renewal cycles, involving
migration from old to new media, resource-intensive data reorganization
and reformatting, or even recreation of related software.
Because these records are of permanent value and NARA has no means to
archive them in any useful way, NASA retains custody of them. They
accordingly fall into an undefined category: they are permanent records
that NARA cannot archive. The current arrangement by which they are
maintained is not covered by NARA guidance. Nor is NASA’s archiving
approach covered by this guidance, which does not cover migration and
archival formats (other than flat ASCII files on tape), management of
digital images, or maintenance of electronic records in databases for
extended periods of time.
U.S. Patent and Trademark Office:
The Patent and Trademark Office manages and indefinitely preserves
millions of digitized patents and trademarks. Patent examiners must
have access to a complete collection of the history of U.S. patents in
order to research prior art before approving new patents. Recently, the
office replaced the examiners’ collection of paper patents with EAST
(Examiners Automated Search Tool) and WEST (Web Examiner Search Tool),
which are complete electronic patent collections containing the full
text of over 2.5 million U.S. patents and full images of over 6.5
million U.S. patents and over 14.5 million foreign patents. In
addition, the Patent and Trademark Office has digitized the text and
images of over 2.7 million trademark applications and registration. The
Patent and Trademark Office has been using XML[Footnote 83] to develop
and implement systems to support the filing, examination, publication,
and archival storage of intellectual property documents in electronic
format.
The Patent and Trademark Office’s digitization program has highlighted
an issue that is not adequately addressed by NARA guidance: that is,
when a record exists in many versions (electronic, paper, microform,
etc.), which should be considered primary? Many of the patent files
that have been digitized were originally paper files, and it has been
argued that destroying the original paper versions after digitization
has led to or risked loss of important information.[Footnote 84] Just
as converting an electronic original to paper may lead to information
loss, so may the reverse. NARA guidance does not address this issue,
leaving agencies at risk of losing information.
Department of Veterans Affairs:
VA must manage and preserve, for 75 years, millions of electronic
medical and benefit records. An integral part of VA’s enrollment
process for each veteran applying for health benefits is the use of
several Veterans Health Information Systems and Technology Architecture
(VISTA) databases to enter and verify veteran eligibility information.
This information must be maintained in the system and accessible for
the life of the veteran in order to document entitlement to health care
benefits, which VA has determined to be a maximum period of 75 years.
One enrollment database alone contains information for 9 million
veterans.
VA patient enrollment records present another instance of the confusion
regarding scheduling requirements for electronic records and for
records in multiple versions. Although VA is working toward a
completely electronic process, enrollment records are initiated on
paper because of current legal requirements for ink signatures. In
general, however, VA does not schedule electronic records when it has
scheduled the paper version. It is NARA policy, however, that
electronic records must also be scheduled. According to VA, another key
challenge that it faces is ensuring the validity and authenticity of
electronic records, and it would like to see adequate guidance and
standards about electronic signatures from NARA so that all government
agencies are using the same approach.
Department of State:
State electronically preserves over 25 million diplomatic cables and
more than 400,000 digital images of correspondence of the Secretary of
State. The State Archiving System (SAS) is a repository for over 25
million cables, from 1973 to the present, documenting the conduct of
U.S. foreign policy. The cables are managed electronically for 25 years
before they are due to be transferred to NARA. However, if the cable
records in SAS had been transferred to NARA for archiving, they would
no longer have been accessible to users.
NARA has responded to the State Department’s archiving and access needs
by developing a new system (Access to Archival Databases), which is
expected to be available in the summer of 2002. This system will allow
NARA to provide on-line access to archived State Department cables.
When the system is available, the cable records will be transferred to
NARA for archiving.
In addition, the Secretariat Tracking and Retrieval System (STARS)
tracks approximately 440,000 digital images of foreign policy memoranda
and correspondence of the Secretary of State from 1986 to the present.
Both STARS and SAS must not only preserve the records, but also
maintain reliable and rapid access to the image data. As technologies
change, preserving and providing access to the records present complex
electronic records management challenges.
The State Department’s records management office has sole
responsibility for maintaining SAS, and it has had to proceed with the
long-term management and preservation of the system records--
periodically updating and migrating all the images to reflect new
technologies--without guidance from NARA. NARA guidance does not
address updating or migration of file formats.
[End of section]
Appendix V: Comments from the National Archives and Records
Administration:
National:
Archives at College Park:
8601 Adelphi Road College Park, Maryland 20740-6001:
May 30, 2002:
Joel C. Willemssen Managing Director Information Technology Team
General Accounting Office 441 G Street NW Washington, DC 20548:
Dear Mr. Willemssen:
Thank you for the opportunity to review and comment on the draft report
on challenges in managing and preserving electronic records. The report
recognizes the enormous challenges the Federal Government faces in
managing and preserving electronic records and many of the actions the
National Archives and Records Administration has taken to meet those
challenges. Nevertheless, we agree that more must be done, and we
support the report’s recommendations. We would like to clarify several
points in the report, however, and have suggested some technical
corrections in an attachment.
Records Management:
The report recommends that we develop a strategy for raising agency
senior management awareness of and commitment to records management
principles, functions, and programs. We certainly agree with this
recommendation, and are active on a number of fronts to raise senior
management awareness of and commitment to records management in Federal
agencies. Such activities include:
*The Deputy Archivist of the United States and I along with senior NARA
program officials have held a series of meetings with agency heads on
the importance of records management and specific agency records
issues.
*The Deputy Archivist and I speak at agency conferences to emphasize
the importance of records management. For example, in April I addressed
senior leadership at the Treasury Department’s records management
conference.
*NARA has developed tools (e.g., PowerPoint presentations) that
agencies can use to do their own management briefings. These have been
popular with agency records management officers.
*NARA developed specific guidance for senior agency management,
Documenting Your Public Service, which was distributed to all senior
officials at the start of the Administration.
*NARA works with the Office of Management and Budget (OMB) to include a
records management emphasis or implications in new guidance to agencies
such as the OMB Circular A-130 revision, annual OMB Circular A-11
revisions, and the Government Paperwork Elimination Act.
*NARA is the managing partner for the Electronic Records Management E-
Government Initiative, which involves a coalition of Federal agencies
working together to develop policies and tools to improve electronic
records management.
Despite all of these activities, however, we agree that more needs to
be done to have a major effect on agency leadership. Effective records
management must be a partnership, a concept reflected in the U.S. Code.
As laid out in 44 U.S.C. chapters 29 and 35, the responsibility for
oversight of records management is shared by NARA, the Office of
Management and Budget (OMB), and the General Services Administration.
Of equal importance, the head of each Federal agency is charged with
the responsibility to make and preserve records (44 U.S.C. 3101) and
“establish and maintain an active, continuing” records management
program (44 U.S.C. 3102, emphasis added).
Federal agency management will not take an interest in records
management unless it can help them meet their business needs. The
recent Report on Current Recordkeeping Practices within the Federal
Government, which we commissioned, found that when agencies have a
strong business need for good recordkeeping, such as for legal or
operational needs, their recordkeeping practices are better. As part of
the strategy we are developing for our Records Management Initiatives,
we plan to create incentives for agencies to work with us in a
“virtuous cycle” where our records management program adds value to the
agencies’ business processes and as a result records are kept long
enough to protect rights, ensure accountability, and document the
national experience. We disagree with the GAO report’s conclusion that
NARA does not plan to address the low priority generally given to
records management. Our whole approach is predicated on the assumption
that records and records management are integral aspects of agencies’
business architectures. In addition, our plans recognize that we need
to show more leadership with Federal agencies and the Congress on
records management issues.
The GAO report also recommends that we develop a strategy for
conducting systematic inspections of agency records management
programs. While we agree with the thrust of the recommendation,
continuing our past inspection program as cited in the report will not
succeed. When NARA undertook the Records Management Initiatives to
rethink completely how we do records management in the Federal
Government, we put our evaluation program on hold, pending changes to
the program, because it was clear we needed to do things differently.
For example:
*The evaluation program could at best conduct 3 agency evaluations a
year, meaning it would take at least 60 years to cover the major
agencies of the Federal Government. *Each evaluation was extremely
labor intensive involving staff from multiple units (headquarters and
field) up to a year.
*Because the evaluations were of records management programs,
responsibility for responding to them fell to records management staff,
not the program staff who actually managed the records. Where records
management is not closely identified with the business process, it will
not be effective.
*Many of the recommendations were broad, could take years to implement,
and could be extremely resource intensive. Frequently agencies lost
interest in the issues, especially if there was a change in records
officer before the action plan was completed.
*Program effectiveness was very uneven. A few agencies (e.g., IRS)
completed their actions plans in a timely fashion. Yet even though we
have not started a new evaluation in several years, there are a number
of agencies that have not completed their action plans.
In addition, the Report on Current Recordkeeping Practices within the
Federal Government concluded that while NARA should work with
individual agencies, “given the availability of resources ... NARA may
wish to carefully consider which agencies should be selected for
assessment. The situational factors at some agencies may limit the
likelihood that specific, or any, intervention options can improve
RM.”’ While heeding this caution, we plan to make evaluations, surveys,
and inspections part of the strategy we are developing to assess how
well records are managed in agencies as a result of our Records
Management Initiatives. We disagree with the GAO report’s conclusion
that NARA has no plans to address the issue of records management
inspections. Using risk management analysis while leveraging our
inspection resources, our approach will include looking systematically
at broad categories of important records across agencies as well as
undertaking agency-specific interventions. We also plan to make more
use, as necessary, of our authority to report the results of
evaluations to OMB and the Congress, especially on issues related to
at-risk records.
Electronic Records Archives:
The GAO report recommends that we reassess the Electronic Records
Archives (ERA) project schedule. We believe that such reassessment is
prudent and intend to conduct such reassessments repeatedly, both
periodically from an overall program management viewpoint and on a
continuing basis as part of our ERA risk management activity. We are
currently reassessing the schedule as part of our refinement of the ERA
acquisition strategy. This reassessment will address the issues that
the report raised, and we will report the results of our reassessment
to both GAO and our Congressional committees.
We would, however, like to clarify two points of special importance
related to the ERA project schedule. First, the report states that
“NARA is not meeting its schedule for the ERA system....” Although some
program documentation deliverables have not been completed on schedule,
all items on the “critical path” have been completed on time, and we
expect to meet all milestones on the critical path this year.
Second, the report suggests aligning the project schedule for
deliverables from the study NARA is sponsoring by the Computer Science
and Technology Board of the National Academy of Sciences (NAS) with the
system acquisition schedule. The NAS study is divided into two parts,
with a separate report to be issued at the end of each. The division of
this study into two parts reflects the fact that the preservation of
electronic records is an open-ended, evolving challenge for which there
can be no one-time solution. NARA has both near-term and long-term
needs
to preserve electronic records. The critical near-term need is to stem
and prevent the loss of valuable electronic records of the Federal
Government
by developing the capability to preserve and provide access to them.
The
long-term need must incorporate the expectation of continuing and often
unpredictable change into NARA’s long-range planning.
The first part of the NAS study will assess the technical
recommendations NARA has received from research we cosponsored, with
the National Science Foundation, in the National Partnership for
Advanced Computational Infrastructure (NPACI). It will focus on the
information management architecture proposed by NPACI for persistent
archives of digital information. The most basic requirement for any
digital archives is for a solution that is sustainable in the face of
continuing and ultimately unpredictable change in information
technology. Otherwise, the solution itself will come to embody, in a
relatively short time, the very problems it purports to solve.
Thus, as the GAO report correctly notes, the infrastructure
independence of the basic architecture is a “major dependency” for the
acquisition of the ERA system. The NAS report on this topic “is
expected to address the adequacy and soundness of the architecture as a
whole and its major components.” But the GAO report asserts, “NARA’s
planning has left little opportunity for the assessment results to be
reflected in the ERA design without disrupting the acquisition process
and increasing the risk to the ERA schedule.” We disagree with this
conclusion, which assumes NARA will make design decisions about the ERA
system prior to receipt of the NAS report. In fact, NARA will not even
begin to address design until well after the NAS report is received.
The delivery of the first report, projected for January 2003, is timed
to fit into the schedule for development of the ERA system.
NARA should receive the first NAS report in the same time frame that we
receive industry’s responses to our planned request for information.
Those two information sources will be complementary. The NAS report
will provide an unbiased, expert view of the feasibility of building a
system that is inherently evolutionary, addressing the core problem of
digital preservation. The industry responses will indicate how close
the market is to supporting the development of a system that is
independent of infrastructure. NARA will factor both the scientific and
the industry views into its articulation of a draft request for
proposals.
The GAO report also asserts, “If these results [of the two NAS reports]
are not fully reflected in the requirements, there is added risk that
the technical strategy underlying the development of the system will
prove not to be optimal, and that alternatives will not have been
considered.” We disagree with this conclusion. NARA is articulating
requirements to reflect its mission needs and the interests and needs
of its stakeholders. The requirements will state what the system must
do, not how it should accomplish these goals. Rather than dictate a
solution, NARA will ask industry to propose the optimal methods of
satisfying our requirements. Any other approach would create
unnecessary and inappropriate barriers to acquiring the best possible
solution that the market can provide. In this context, it should be
noted that the NPACI architecture for persistent archives is a notional
architecture. It does not specify any particular hardware, software or
network architecture. Furthermore, after contract award for design of
the system, the ERA Program will enter a requirements definition and
refinement stage ending with a System Requirements Review,
collaborating
with the contractor to finalize what is to be built. This will be
another
opportunity to fold in additional research-related information.
With respect to the second part of the NAS study, the GAO report
states, “By this date [October 1, 2003], the Request for Proposals for
the electronic archival system will be released, leaving little or no
opportunity for the results of the second assessment to influence the
first build of the system.” The primary purpose of the second NAS
report, however, is to provide input to NARA’s long range plans for
addressing the continuing evolution of information technology and
electronic records. As stated in the NAS contract statement of work,
the second part of the study “will provide a more comprehensive
discussion of the digital archiving and preservation issues and options
confronting the National Archives and Records Administration.” The
second NAS report will be useful in revising the ERA research plan to
address new problems and opportunities identified by the experts, and
in plans for successive builds of the ERA system. Even in the initial
build, we intend to provide the second NAS report to contractors to
develop designs for the initial build of the ERA system. Given that
design work will start only after award of the contract, the contractor
will be able to take the NAS assessment into account in developing its
design, and NARA will be able to use it in evaluating the design.
Thank you for considering our comments. As your report recognizes, we
face enormous challenges in managing and preserving electronic records,
and we welcome the perspective GAO brings to these issues. Work we
already have underway will be instrumental in meeting the report’s
recommendations, and we will be pleased to report to you and the
Congress regularly about our progress.
If you have any questions, please contact Lori Lisowski, Director of
Policy and Communications, at 301-837-1850.
John W. Carlin Archivist of the United States:
Signed by John W. Carlin:
Enclosure:
[T] SRA International, Inc., Report on Current Recordkeeping Practices
within the Federal Government, December 10, 2001, p. 32. Emphasis in
original.
[End of section]
Glossary:
administrative records:
Records created by several or all federal agencies in performing common
facilitative functions that support the agency’s mission activities,
but do not directly document the performance of mission functions.
Administrative records relate to activities such as budget and finance,
human resources, equipment and supplies, facilities, public and
congressional relations, and contracting. Administrative records are
temporary and are covered by general record schedules.
business process:
A collection of related, structured activities--a chain of events--that
produce a specific service or product for a particular customer or
customers.
data architecture:
The framework for organizing and defining the interrelationships of
data in support of an organization’s missions, functions, goals,
objectives, and strategies. Data architectures provide the basis for
the incremental, ordered design and development of systems or subject
databases based on successively more detailed levels of data modeling.
electronic record:
In the context of the federal government, any information that is
recorded by or in a format that only a computer can process and
satisfies the definition of a federal record in 44 U.S.C. 3301.
electronic recordkeeping system:
An electronic system in which records are collected, organized, and
categorized to facilitate their preservation, retrieval, use, and
disposition.
enterprise architecture:
An institutional systems blueprint that defines in both business and
technology terms an organization’s current and target operating
environments and provides a road map for moving between the two.
Extensible Markup Language (XML):
A flexible, nonproprietary set of standards for tagging information so
that it can be transmitted using Internet protocols and readily
interpreted by disparate computer systems.
federal records:
In the context of federal recordkeeping, all books, papers, maps,
photographs, machine-readable materials, or other documentary
materials, regardless of physical form or characteristics, made or
received by an agency of the U.S. government under federal law or in
connection with the transaction of public business, and preserved or
appropriate for preservation by that agency or its legitimate successor
as evidence of the organization, functions, policies, decisions,
procedures, operations, or other activities of the government or
because of the informational value of the data in them.
metadata:
Data containing descriptive information about other data.
office automation records:
Electronic records created by means of office automation software, such
as word processors, spreadsheets, other desktop applications, or
electronic mail.
office automation:
The techniques and means used for the automation of office activities,
in particular, the processing and communication of text, images, and
voice.
permanent records:
Records that NARA appraises as having sufficient value to warrant
continued preservation by the federal government as part of the
National Archives of the United States.
Portable Document Format (PDF):
A proprietary de facto standard for electronic document distribution
worldwide. Created by Adobe Systems, the portable document file format
preserves all the fonts, formatting, graphics, and color of any source
document, regardless of the application and platform used to create it.
program records:
Records created by each federal agency in performing the unique
functions that stem from the distinctive mission of the agency. The
agency’s mission is defined in enabling legislation and further
delineated in formal regulations. Program records may be temporary or
permanent; they must be scheduled.
record:
See federal records.
recordkeeping system:
A manual or automated system in which records are collected, organized,
and categorized to facilitate their preservation, retrieval, use, and
disposition.
recordkeeping:
The act or process of creating and maintaining records.
records management:
The planning, controlling, directing, organizing, training, promoting,
and other managerial activities involved in records creation,
maintenance and use, and disposition in order to achieve adequate and
proper documentation of the policies and transactions of the federal
government.
records management application:
The term used by the Department of Defense’s Design Criteria Standard
for Electronic Records Management Software Applications (DOD 5015.2-
STD) for software that manages records. The primary management
functions of such software are categorizing and locating records and
identifying records that are due for disposition.
records schedule:
A document providing mandatory instructions for what to do with records
no longer needed for current business, with provision of authority for
the final disposition of recurring and nonrecurring records.
technical reference model:
A taxonomy that provides a consistent set of service areas, interface
categories, and relationships to address interoperability and open
systems; part of an enterprise architecture.
temporary records:
Records appraised as having temporary or limited value and approved for
destruction either immediately or after a specific period of time.
Usenet:
An Internet-based worldwide distributed discussion system. Usenet
consists of a set of “newsgroups” with names that are classified
hierarchically by subject. “Articles” or “messages” are “posted” to
these newsgroups by people on computers with the appropriate software;
these articles are then broadcast to other interconnected computer
systems via a wide variety of networks.
XML:
See Extensible Markup Language.
XML document:
A text document marked up with hierarchically arranged descriptive tags
and attributes conforming to the XML standard. An XML document can also
begin with declarations that refer to other files providing further
instructions for interpreting and displaying data elements.
FOOTNOTES
[1] 44 U.S.C. chapters 21, 29, 31, and 33.
[2] NARA’s regulations implementing the Federal Records Act are found
at 36 CFR 1200-1280.
[3] PDF is a proprietary format of Adobe Systems, Inc., that preserves
the fonts, formatting, graphics, and color of any source document,
regardless of the application and platform used to create it.
[4] A geographic information system is a computer system for capturing,
storing, checking, integrating, manipulating, analyzing, and
displaying data related to positions on the Earth’s surface. Typically,
a GIS is used for handling maps of one kind or another. These might be
represented as several different layers where each layer holds data
about a particular kind of feature (e.g., roads). Each feature is
linked to a position on the graphical image of a map.
[5] In January 2001, NARA directed agencies to provide a one-time
“snapshot” of their public Web sites as they existed on or before
January 20, 2001.
[6] National Research Council, Preservation of Historical Records,
National Academy Press (Washington, D.C.: 1986).
[7] International Council on Archives, Guide for Managing Electronic
Records from an Archival Perspective (Paris: February 1997).
[8] U.S. General Accounting Office, National Archives: Preserving
Electronic Records in an Era of Rapidly Changing Technology, GGD-99-94
(Washington, D.C.: July 19, 1999) (http://www.gao.gov/archive/1999/
gg99094.pdf).
[9] Department of Defense, Design Criteria Standard for Electronic
Records Management Software Applications, DOD 5015.2-STD (November
1997) (http://www.dtic.mil/whs/directives/corres/html/50152std.htm).
[10] DOD 5015.2-STD requires that records management applications be
able to manage records regardless of their media.
[11] SRA International, Inc., Report on Current Recordkeeping Practices
within the Federal Government (Dec. 10, 2001) (http://www.nara.gov/
records/rkreport.html). Both the SRA study and the NARA staff analyses
were reported within this document.
[12] The 24 major agencies reported 6,435 mission-critical systems.
Subcommittee on Government Management, Information, and Technology,
House Committee on Government Reform, Federal Government Earns B+ on a
Final Y2K Report Card, news release (Washington, D.C.: Nov. 22, 1999).
[13] According to NARA, its current goals for schedule processing are
180 days for simple schedules and 365 days for complex schedules. In FY
2001 the median time for completing schedules was 237 days.
[14] National Archives and Records Administration, An Overview of Three
Projects Relating to the Changing Federal Recordkeeping Environment
(January 2001) (http://www.nara.gov/records/rmioverview.html).
[15] Center for History of Physics, American Institute of Physics, AIP
Study of Multi-institutional Collaborations: Final Report--Highlights
and Project Recommendations, College Park, MD (2001) (http://
www.aip.org/history/pubs/collabs/highlights.html).
[16] CFR 1220.54 (a).
[17] NARA expects the policy review phase to be completed by the end of
2002, but according to NARA, all new or revised policies will not be in
place by that date. The entire project will not be complete until 2006.
[18] On January 15, 2002, American Systems Corporation (ASC) announced
its acquisition of ICE, Inc. According to the ERA project manager, this
change does not affect the status of NARA’s contract with ICE, Inc.
[19] A concept of operations is a document that describes
characteristics of the system from the user’s viewpoint.
[20] The seven completed documents were the acquisition strategy,
configuration management plan, risk management plan, quality assurance
plan, life-cycle model, requirements management plan, and technology
research plan.
[21] The six uncompleted documents were the revised program management
office (PMO) organization, PMO billet roles/responsibilities, metrics
plan, PMO training needs assessment, ERA PMO training plan, and program
management plan.
[22] U.S. General Accounting Office, Information Security Management:
Learning from Leading Organizations, GAO/AIMD-98-68 (Washington, D.C.:
May 1998).
[23] NARA’s effort to develop an enterprise architecture includes a
separate effort to develop a data architecture.
[24] Fiscal Year 2000 Federal Managers’ Financial Integrity Assurance
(FMFIA) Report to the President.
[25] Chapter 35 of title 44, section 1061, subchapter II--Information
Security, United States Code.
[26] Office of Management and Budget, Incorporating and Funding
Security in Information Systems Investments, Memorandum 00-07
(Washington, D.C.: Feb. 28, 2000).
[27] Integrated Computer Engineering, Inc., Electronic Records Archives
Initial Assessment Final Report, version 1.2 (Oct. 18, 2001).
[28] Virus: a program that “infects” computer files, usually executable
programs, by inserting a copy of itself into the file. These copies are
usually executed when an infected file is loaded into memory, allowing
the virus to infect other files. Unlike the computer worm, a virus
requires human involvement (usually unwitting) to propagate. Worm: an
independent computer program that reproduces by copying itself from one
system to another across a network. Unlike computer viruses, worms do
not require human involvement to propagate. Trojan horse: a computer
program that conceals harmful code. A Trojan horse usually masquerades
as a useful program that a user would wish to execute. Logic bomb: in
programming, a form of sabotage in which a programmer inserts code that
causes the program to perform a destructive action when some triggering
event occurs, such as termination of the programmer’s employment.
Sniffer or packet sniffer: a program that intercepts routed data and
examines each packet in search of specified information, such as
passwords.
[29] For example, the number of incidents handled by Carnegie-Mellon
University’s Computer Emergency Response Team (CERT) Coordination
Center has increased from 1,334 in 1993 to 8,836 during the first two
quarters of 2000. Similarly, the Federal Bureau of Investigation
reports that its caseload of computer-intrusion-related cases is more
than doubling every year.
[30] Subcommittee on Government Management, Information, and
Technology, House Committee on Government Reform, Federal Government
Earns a B+ on Final Y2K Report Card, news release (Washington, D.C.:
Nov. 22, 1999).
[31] U.S. General Accounting Office, National Archives: Preserving
Electronic Records in an Era of Rapidly Changing Technology, GAO/GGD-
99-94 (Washington, D.C.: July 19, 1999) (http://www.gao.gov/archive/
1999/gg99094.pdf).
[32] XML is a simplified subset of the Standard Generalized Markup
Language (SGML) used to define portable document formats.
[33] Tagging data in a standard way allows any system that recognizes
the standard to readily understand and process data that conform to
that standard. In tagging, a standard format is used to label each
element of a data set with metadata that clarify what kind of
information is being provided. Common tagging systems for electronic
information--also known as markup languages--use labels set off by
angled brackets to show where data elements begin and end: for example,
in , the second tag includes a slash to indicate
that it is a closing tag.
[34] U.S. General Accounting Office, Electronic Government: Challenges
to Effective Adoption of the Extensible Markup Language, GAO-02-327
(Washington, D.C.: Apr. 5, 2002).
[35] Amarnath Gupta, Preserving Presidential Library Websites, San
Diego Supercomputer Center, SDSC TR-2001-3 (Jan. 18, 2001).
[36] National Archives of Australia (http://www.naa.gov.au/).
[37] Jeff Rothenberg, Avoiding Technological Quicksand: Finding a
Viable Technical Foundation for Digital Preservation, Council on
Library and Information Resources (January 1999) (http://www.clir.org/
pubs/reports/rothenberg/contents.html).
[38] Task Force on Archiving of Digital Information, Preserving Digital
Information (May 1, 1996) (http://www.rlg.org/ArchTF/).
[39] HD-Rosetta Archival Preservation Services (http://www.norsam.com/
hdrosetta.htm).
[40] Andrew Waugh, Ross Wilkinson, Brendan Hills, and Jon Dell’oro,
Preserving Digital Information Forever, Commonwealth Scientific and
Industrial Research Organisation (CSIRO) Mathematical and Information
Sciences (undated) (http://pigfish.vic.cmis.csiro.au/~ajw/
PresDigitInfoL.pdf).
[41] Jeff Rothenberg, Using Emulation to Preserve Digital Information,
Position Paper, NSF Workshop on Data Archiving & Information
Preservation (Mar. 26, 1999) (http://cecssrv1.cecs.missouri.edu/
NSFWorkshop/ppaper3.html).
[42] The Public Record Office is the national archive of England,
Wales, and the United Kingdom (http://www.pro.gov.uk/).
[43] Jeff Rothenberg, Using Emulation to Preserve Digital Documents,
Rand-Europe, Koninklijke Bibliotheek (The Hague: July 2000).
[44] See footnote 40.
[45] See footnote 40.
[46] See footnote 40.
[47] Encapsulation, Preserving Access to Digital Information (PADI)
(http://www.nla.gov.au/padi/topics/20.html).
[48] Ken Thibodeau, “Building the Archives of the Future: Advances in
Preserving Electronic Records at the National Archives and Records
Administration,” D-Lib Magazine (February 2001) (http://www.dlib.org/
dlib/february01/thibodeau/02thibodeau.html).
[49] Public Records Office Victoria (http://www.prov.vic.gov.au/
welcome.htm).
[50] The metadata are based on a model developed by the National
Archives of Australia.
[51] The ASCII character set of 128 characters includes the familiar
letters, numbers, and punctuation of the roman alphabet, along with
certain other characters such as spaces, tabs, and carriage returns.
[52] National Archives of Canada (http://www.archives.ca/).
[53] National Archives of Australia (http://www.naa.gov.au/).
[54] See footnote 40.
[55] A relational database allows the definition of data structures and
storage and retrieval operations. In such a database the data and
relations between them are organized in tables. A table is a collection
of records and each record in a table contains the same fields. Certain
fields may be designated as keys, which means that searches for
specific values of that field will use indexing for increased speed.
Interdependencies among these tables are expressed by data values.
[56] The manufacturer claims a life expectancy of at least 1,000 years
and a temperature threshold of 500° C.
[57] Ion milling is an etching process in which high-energy gallium
ions produced by a focused ion beam machine knock atoms from the
surface and micro-engrave into any given medium.
[58] The Long Now Foundation (http://www.longnow.org).
[59] The Rosetta Project (http://www.rosettaproject.org:8080/live).
[60] Internet Archives (http://www.archive.org/).
[61] Google Groups (http://www.google.com/grphp?hl=en).
[62] 44 U.S.C. chapters 21, 29, 31, and 33.
[63] 36 CFR Part 1234. This rule is supplemented by NARA’s Records
Management Handbook and periodic guidance on specific issues, e.g.,
NARA Bulletin No. 2000-02 (Dec. 27, 1999).
[64] GRS 20 (August 1995).
[65] GRS 20, Data Automation Program Records, FPMR 101-11.4 (Apr. 28,
1972).
[66] GRS 20 (August 1995).
[67] History of General Records Schedule 20, Electronic Records
(www.nara.gov/records/grs20/20hist.html).
[68] GRS 20, Machine-Readable Records, FPMR 101-11.4 (Feb. 16, 1977).
[69] Administrative records are those created in the performance of
common facilitative functions that support an agency’s mission
activities, but do not directly document the performance of mission
functions. Administrative records are temporary. Program records are
those created in the performance of the unique functions that stem from
an agency’s mission. Program records may be temporary or permanent;
they must be scheduled.
[70] GSA Bulletin FPMR B-127 (June 17, 1983).
[71] NARA Bulletin No. 85-2 (June 18, 1985).
[72] 36 CFR 1234, 50 FR 26939 (June 28, 1985).
[73] GRS 20 (June 1988); GRS 23, Records Common to Most Offices within
Agencies (June 1988).
[74] GRS 20 (August 1995).
[75] Electronic Records Management, 55 FR 19216 (May 8, 1990).
[76] Armstrong v. Executive Office of the President, 1 F. 3d 1274 (Aug.
13, 1993).
[77] GRS 20 (August 1995).
[78] Public Citizen v. John Carlin, 2 F. Supp. 2d 1 (D.D.C. 1997).
[79] See, e.g., NARA, Disposition of Electronic Records, Bulletin 98-02
(Mar. 10, 1998); U.S. General Accounting Office, National Archives:
Preserving Electronic Records in an Era of Rapidly Changing Technology,
GAO/GGD-99-94 (Washington, D.C.: July 1999).
[80] Public Citizen v. John Carlin, 184 F.3d 900 (D.C. Cir. 1999).
[81] NARA Bulletin 2002-2 (Dec. 27, 1999).
[82] 66 FR 51739 (Oct. 10, 2001).
[83] Extensible Markup Language (XML) is discussed further in appendix
II.
[84] The potential problem of information lost during the conversion
from paper to electronic patents was identified in a recent
Congressional hearing: when searching electronic patent databases for
prior art, patent searchers miss relevant patents. As noted in
testimony by an association representing patent researchers, this is
due to a unique problem related to how an invention is described: “in
many, if not most, cases the invention is never fully described ‘in the
words.’ The patent law requires only that the specification, including
the drawings, together be understandable and enabling to one of
ordinary skill in the art to make and use the invention. ‘The words,’
in many if not most cases, merely ‘flesh out’ what is shown in the
drawings and do not replicate ‘in words’ what is in the drawings, but
are ancillary thereto. Thus, in a patent database electronic search one
is often presented the additional problem of ‘searching’ for ‘words’
which were never there to begin with.” --Testimony of James F. Cottone,
President, National Intellectual Property Researchers Association,
Oversight Hearing on the U.S. PTO of the Subcommittee on Courts and
Intellectual Property of the House Judiciary Committee (Thursday, Mar.
9, 2000) (http://www.house.gov/judiciary/cottone.htm).
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