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RECMGMT-L  April 2006, Week 1

RECMGMT-L April 2006, Week 1

Subject:

Re: Retaining listservs

From:

Larry Medina <[log in to unmask]>

Reply-To:

Records Management Program <[log in to unmask]>

Date:

Fri, 7 Apr 2006 10:27:02 -0700

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (167 lines)

Anybody out there come up with a retention period for
> listservs?  Not the individual messages that a person
> subscribed to a listserv might get, but an agency that
> administers a listserv.  I'm thinking about the
> listserv archives here.


When you say "THE Listserv Archives", I'm assuming you're referring to "THE
Listservs" you go on to speak about in the main body of your post, not THIS
Listserv, for example?

And I'm also unsure when you're using the term "Archives" which variety of
"archive" you're speaking of... a classic archive in the RIM/Archival sense,
or an IT "archive", being similar to a deeper version of what we know as a
backup tape (?)

Not trying to pick nits, but it does matter when it comes to discussing how
long something should be maintained WHY you're maintaining it and WHAT it
represents.

Our state's IT dept sent out a message to all listserv
> administrators/moderators that the state wanted to
> come up with a retention period for archived listserv
> messages.  Don't know yet if he was just talking about
> online versus some type near/offline retention or a
> total retention.


So it sounds as if they don't have a well defined POLICY about what State
run/managed Listservs are to be used for and what information SHOULD and
SHOULDN'T be discussed in Listservs.  Similar to many past discussions about
"How long should e-mail be retained?", it's important to note here that the
Listserv is the VEHICLE for communicating the CONTENT, and it's the CONTENT
that's subject to a retention period.

And again, there's that 'archived" concept being brought up.

This agency administrates the
> network infrastructure and handles all
> incoming/outgoing email (KY has a centralized email
> system for all state agencies) and they are getting
> concerned about the volume of email they're having to
> deal with.


Well, then again, they sound as if they need to look at POLICY.  It should
be clearly stated to all State employees WHAT SHOULD and SHOULDN'T be
communicated in e-mail by State employees, and when e-mail rises to the
level of a record, how it should be handled.  Many States, Cities and other
Agencies have a disclaimer banner statement on their systems when an
employee signs on that tells them what they can/can't, should/shouldn't use
the official State Computer Systems for and it may refer them to a policy
page that they've (supposedly) been provided on a regular basis to read and
sign stating they will comply with.  Additionally, many have a disclaimer
banner on ALL e-mail about "Official Business" and it may also indicate that
a person sending e-mail with that banner on it assumes some level of
responsibility for the content.

As mentioned in the past, e-mail is the Pandora's Box we've all opened and
need to find some way to deal with the demons coming out of it now.  Any
"policy" that sets a time or volume limit on e-mail and gives NO
CONSIDERATION to the content is a policy looking for a lawsuit.  An
organization's retention schedule is based on CONTENT, not delivery
method... these time/volume retention periods would be like applying a
schedule to an envelope and saying all correspondence received by mail is to
be retained for" x days or until you have x pounds" of them.


> Our state records branch manager
> administrates a listserv (hosted on the state system)
> for the KY Council on Archives (our state's
> professional archival organization) so he got the
> message and he informed this IT person that they have
> to work through our dept. and the state's Archives and
> Records Commission to actually develop a formal
> retention period.


BRAVO!  And this provides an EXCELLENT opportunity for educating them on
record management principles and best practices, and why they must be
applied consistently to ALL FORMS of information, regardless of media, form
or format the information is in.

Our thought is to:
> 1.  Give a somewhat vague and transitory retention (in
> our state general schedule for electronic and related
> records -
> http://www.kdla.ky.gov/recmanagement/schedules/erecordsgeneral.pdf
> ) and encourage the state IT folks to work with the
> individual agencies that have listservs about those
> that feel a need to keep long-term versus those that
> don't.  We would then work with agencies individually
> to schedule the listserv on the agency's specific
> schedule.


Now here's a prescription for disaster.  Again, retention is based on
CONTENT, not FORMAT.  The long standing rule is "regardless of media, form
or format" comes from 44USC Ch 3301, it definitely applies to ALL Federal
Agencies, but that's where the requirements for most States, Counties,
Cities, etc. are derived from... and most businesses use the same criteria.
The fact they're "electronic records" doesn't make them any less records
when it comes to determining retention periods.

If you establish differing periods for records for different agencies, it
would have to be based on a common retention period for the content and an
additional period for business needs (or potential historic, enduring or
intrinsic value), allowing some to retain records longer than others.

Or
>
> 2.  Come up with a generic retention (2 years for
> example) for all listservs - and then schedule those
> that need to be scheduled longer separately.


Again, you're looking at the "vehicle", not the content.

This discussion also raised the issue about blogs as
> well.  (I thoroughly chastised and beat the person who
> asked the question - kidding)  To the best of my
> knowledge there current aren't any OFFICIALLY
> sanctioned blogs recognized as a government record.


Another case where policy would be the way to address the issue.  There
should be a policy regarding the use of blogs, or even the allowing of
employees to use blogs or IM from a State system.  And once they decide to
allow it, then they need to establish a retention period for records (based
on content) generated in them. If the State allows their use, and the
information resides on a State system, then it becomes Public Record and is
subject to all rules related to Public Records, correct?

This doesn't mean individual employees or officials
> aren't doing them on their own - which raises the
> whole issue of public versus private ownership and all
> of that.  But that's for a different post.


Yep, and here's where the "disclaimer banner" and someone having to click
that they agree before they sign onto a system is beneficial.  This at least
minimizes the liability the State has for the actions of an employee failing
to follow the guidelines.

Any ideas or comments from both the public and private
> sector would be appreciated.
>

It's a lot different in a public vs. private environment.  In a public
environment, you have the whole arena of "Public Records Act" issues to deal
with that govern how you must act and react. In a private environment, you
have decisions to make based largely on risk... you have regulations, laws,
statutes and business practices to follow, and you make some decisions based
on how risk tolerant you are willing to be if you elect to follow all of
them or not.

This should be an interesting thread =)

Larry

--
Larry Medina
Danville, CA
RIM Professional since 1972

List archives at http://lists.ufl.edu/archives/recmgmt-l.html
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