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RECMGMT-L  March 2018, Week 2

RECMGMT-L March 2018, Week 2

Subject:

Equity holder; risk (records management; records classification)

From:

Maarja Krusten 2 <[log in to unmask]>

Reply-To:

Records Management Program <[log in to unmask]>

Date:

Fri, 9 Mar 2018 15:52:52 -0500

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (100 lines)

Equity holder in the business sense can be someone who owns an asset
(property, shares, a business, etc. ) and has a specific meaning in terms
of records security classification and declassification:
(1) information security classified by or under the control of a federal
agency;
(2) in the possession of a receiving entity on the transfer of a
governmental function;
(3) or in the possession of a successor federal agency if the original
agency no longer exists.
In the records management context, for unclassified or classified records,
equity also can refer to the owner of the asset.  Just as in business,
there are rewards, risks and liabilities associated with assets. My
question for you is this--what drives consideration of those elements in RM
terms in different workplaces?

Moving beyond the clean room posited in the wording in statutes,
regulations, and codified guidance can lead to realistic recommendations
for improvement in handling records. Whether implementation is possible or
not, the very acknowledgment of cultural biases can relieve or at least
mitigate stressors.  This especially is the case at the upper ranks, where
C Suite officials apply contextual sophistication to look beyond the nuts
and bolts of procedures and consider the big picture.  Although such bodies
are rare these days, I see support from expert, bipartisan, high level
commissions as having great value in such considerations.

As someone who has spent most of my Federal career holding security
clearances and working with national security classified records, I
appreciated seeing acknowledgement of cultural bias in this 2012 report
from the Public Interest Declassification Board (PIDB).  PIDB members noted
oif agency classifiers in their 2012 Transforming the Security
Classification System report (link in my March 7 post):

"In order to effect the cultural shift implicit in these recommendations,
guidance should assume that classification decisions are made in good faith
and should afford a ‘safe harbor’ for classifiers who adhere to proper risk
management practices and, when unsure, decide not to classify.
Classification training should address the culture bias that favors
classification, and often over-classification, through coordinated,
consistent education that underscores the responsibility to not classify in
the presence of doubt.

Classifiers face incentives that bias their decisions toward
classification. They should be encouraged and rewarded—and at least not
punished—for good-faith decisions that certain information should remain
unclassified."

This is not inconsequential, given the budgetary impact of safeguarding and
handling security classified information and later assessing it for
declassification. The PIDB also offered its assessment of declassification
as it appeared to the board in 2012:

"Declassification is a complex and time-consuming process, typically
performed in a culture of caution without much attention to efficiency and
risk management.  Sequential referral of classified records for review by
each agency that claims an “equity” in the record takes a great deal of
time.  Agencies are reluctant to share their declassification
guidelines, impeding efficiency that could be realized from greater
interagency coordination and collaboration. Because declassification is not
seen [by the creating agencies] as a way to serve the national security
mission, the public’s right to know what its government does is not
well-served."

My question for you in the RM context is this.  There are multiple
stakeholders in the handling of unclassified records as assets to private
and public sector organizations.  I often hear and see the legal or
technological perspective in some of the meeting announcements by members
of various records associations here and on Twitter and other sharing
platforms.  Yet there are other stakeholders as well, some of whom may work
with you.  Are all their voices being heard by the C Suite?

Have any of you participated in conference sessions or blogged about
internal or external elements that create or constrain "safe harbor" in
RM?  I don't mean "defensible deletion," which is an important element is
handling RM risk.  Bur rather acknowledgment of stakeholder bias in your
workplace--which can be bias not to create or retain records or conversely
to create and keep them?  And how to reconcile such competing dynamics in
considering long term impact on institutional memory?  (If long term impact
is debated, at all; I recognize short term impact, including external reach
in litigation or public access, can loom large here.) Or why such debates
do or do not occur within records creating organizations, depending on
which stakeholder's function drives top level decision making on RM
policy?  And comfort level for the top in using "honest broker" policy
briefers in the C Suite?

And do you see "safe harbor" in your workplace to discuss internally and
convey candidly to the top levels the impact of the type of safe harbor the
PIDB envisioned for national security classifying officials. as a way to
reduce risk aversion?  Or (and this seems to me an unusual situation, akin
to the status of the PIDB in 2012), to discuss its value in public?

Maarja
[log in to unmask]
Washington, DC
@ArchivesMaarja
Blog:  Archival Explorations https://urldefense.proofpoint.com/v2/url?u=https-3A__archivalexplorations.wordpress.com_&d=DwIFaQ&c=pZJPUDQ3SB9JplYbifm4nt2lEVG5pWx2KikqINpWlZM&r=b5NZPQUb9_r2rQ3Zd74ATT3aSs9yKyRnJLOhqJvd7fE&m=U7ibooBUJ2OumjWinbIqmOBeZ9oAUzKklh6pr_vN1LM&s=iFOqqvWQ7f-KgzHO2TUcpSL4yf6Lv-xnVuYKOmKYN4s&e=

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