In response to the revelations about White House e-mail practices, members of the House Oversight and Government Reform Committee have introduced the Electronic Communications Preservation Act. The bill would direct the Archivist of the United States to issue regulations that require federal agencies to preserve electronic records — especially e-mail messages — in an electronic format.
Current National Archives and Records Administration regulations permit agencies to preserve electronic records by storing them in an electronic format or printing them on paper and saving the paper. Agencies almost universally choose the paper option if they preserve their electronic records at all.
The lawmakers backing the bill want to remove the print option by requiring agencies to preserve their records electronically so they are accessible via electronic search. They also want agencies to acquire electronic records management systems within four years.
I applaud the intent of Rep. Henry Waxman (D-Calif.) and the committee to remove the print option, but the measure does not go far enough. It is also somewhat misguided in its conception.
E-mail messages constitute only a small portion of federal electronic records. If Congress wants to legislate e-mail message preservation, it should consider all electronic records because the same principles would apply.
Agencies now pop their electronic information into searchable digital storage and pretend they are meeting records management requirements. Of course they are not because information stored that way can still be altered or deleted. Such an approach fails to incorporate NARA-approved instructions for retention and disposition, as is legally required for records. Agencies are not managing the information. They are simply storing it.
The bill would require electronic records management systems. However, those systems never stand alone. They depend on other content management systems. Recordkeeping systems do not create records. They receive and manage records created elsewhere. They are effective only when integrated with other content management applications that transmit records and their metadata for recordkeeping.
In contemporary terms, electronic records management systems exist as part of enterprise content management systems, which include components for managing documents, images, case files and Web content. Without the other components to supply records, electronic records management systems have nothing to manage.
The committee’s heart is certainly in the right place, but the lawmakers seem to have little understanding of the role of electronic records management in the context of today’s enterprise communications and content management systems.
The bill is praiseworthy for its efforts to correct e-mail aberrations that exist in the government far beyond the White House. Yet as much as I approve of its intent, the bill suffers from trying to legislate for too small a part of a much more complex whole.
Sprehe (jtsprehe@jtsprehe.com) is president of Sprehe Information Management Associates in Washington.
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