Ideas for increasing NARA openness and transparency regarding appraisal and scheduling

As noted previously here and elsewhere, in response to the Obama administration’s Open Government Directive, the National Archives issued an open call for suggestions from the public about how they can increase their transparency and become more “open.” In considering how to discuss this issue here on the blog, I found it difficult to structure my response around the broad categories provided in the original call. Instead I think it’s easier to think about how to approach specific functions. And, good archivist that I try to be, my mind turns first to appraisal. If you’re not familiar with how scheduling and appraisal work at the Federal level, you may want to read “Records Schedule Review Process,” an overview created by NARA for Federal records managers. I think there are two specific areas of this process that can be significantly improved to create greater transparency and to “to improve public participation in and feedback on” this National Archives core mission activity.

First, the process for publishing proposed records schedules and receiving public feedback is need of an overhaul. Federal law requires NARA to “publish notice in the Federal Register of schedules proposing (a) the disposal of unscheduled series or (b) a reduction in the retention period of a series already approved for disposal. These notices provide the public with the opportunity to request copies of pending schedules from NARA and provide comments.” Note that the records schedule itself is not published in the Federal Register, only a notice of the schedule. Interested citizens must contact NARA and request a copy of the schedule. While this is certainly not an insurmountable barrier, given the ease with which information can now be made available to the public, wouldn’t it seem more logical to post proposed schedules on NARA’s web site and point to them from the Federal Register notice? This would also allow NARA to create an RSS feed so that interested citizens could notified when new schedules were posted. This appears to me to be a relatively simple way of increasing transparency, not only for NARA but for all government agencies. It’s possible NARA could also engage in a public dialogue with citizens about the comments received on proposed schedules. That idea may be more problematic, but it’s worth considering in the context of increasing opportunities to “improve collaboration.”

Just as I think citizens should have access to all proposed schedules, I believe it is unconscionable that the public does not have online access to the approved records schedules of government agencies. My former colleagues at NARA may think I’m putting it a bit strongly, but that’s my opinion. One of NARA’s most important functions is to determine, in consultation with agencies and the public, which records created by the government are suitable for permanent preservation. But the outcome of that process–the records schedules–are not made available to the citizens, except on request. This is an issue that relates not only to NARA’s own transparency, but also to transparency throughout government. True, some agencies do post their schedules on their own web sites, but by no means all do so. When I left NARA ideas for how to make all the approved schedules available online was still in the discussion stage and I do not know what progress or plans have since been made. However, I think the development of an Open Government Plan for NARA would not be complete without consideration of providing open access to the products of one of its most important functions.

Those are just my initial thoughts, and I’d be happy to hear what you think of them and what you think can be done to improve how NARA supports access to and feedback on scheduling and appraisal. My intent is to publish occasional posts like this one, that focus around different functional areas, between now and March 19 (the date on which comments are due to NARA). If there’s an area you’re particularly keen to discuss, let me know in the comments and I’ll make sure it’s highlighted. (Except that I think that there are many people more qualified than I to discuss how the FOIA process can be improved. That’s one I don’t plan to discuss.) But what do you think? What can NARA improve scheduling and appraisal?

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3 Responses to Ideas for increasing NARA openness and transparency regarding appraisal and scheduling

  1. t says:

    I didn’t realize this was the way NARA worked through their scheduling issues. Multnomah County Records has made retention schedules open to the public for some years now and is working with the County web staff to investigate using a wiki-based process to allow public (as well as department and state agency) interaction during the drafting and revision process. Having the schedules online helps in just the general government information access process as people can get a decent idea of the kinds of information county programs hold. I hadn’t thought of the RSS angle, though. That’s a good idea.

  2. Gina says:

    There’s no RSS feed yet, but Utah has been publishing pending and approved retention schedules for many years, see http://archives.state.ut.us/cgi-bin/src.cgi?RUN-WHAT=SRC. I also had not realized it could be different on the federal level.

    Just exposing the schedules without additional access and commenting tools would be an improvement to start.

  3. Jim says:

    Hey Kate-

    This is a little bit late, and we’re all moving on to other things. I do not follow ArchivesNext all that closely anymore, figuring your good Twitter account will clue me into anything I might care to follow up on. But since you kindly singled me out on Twitter, I thought I’d try to respond from a personal view.

    I found the information provided by Gina interesting, followed up on it, and found it interesting that schedules were put up online- both proposed and final versions. From what I could tell from T’s post, only the final versions are put up, but maybe he could direct me to where proposed schedules are put up? And for both of the commentators, how long has putting the schedules up on the web been standard procedure- both proposed and final?

    It certainly is well within the realm of possibilities for NARA to put proposed schedules online, and I will note that the Record Schedule Review Process does already say,
    “For records schedules of unusual public interest, NARA may pursue additional strategies to elicit public comment, such as posting the entire schedule and appraisal report on the NARA web site (www.archives.gov), sending notices about the schedule to pertinent listservs, and soliciting comment through letters to interest groups, professional organizations, or other entities.”

    Probably not a big step from that statement toward putting proposed schedules online.

    The second part of your post strongly suggests that NARA should be placing all approved schedules of all Federal agencies online. I will note that NARA began an extensive scanning project and in fact now has many scanned copies of schedules and dossiers from the various Federal agencies on-line (within the past 4-5 months), and that it’s a great relief for me not to run downstairs and look for these things in paper format. If it is decided to put these items publicly on-line, it can be done fairly quickly.

    And I think that the Obama administration’s Open Government Directive is a great opportunity to expand the effectiveness of records management throughout the Federal Government. In fact, the Open Government Directive specifically directs agencies to “Publish Government Information Online,” and “link to a publicly available website that shows how your agency is meeting its existing records management requirements (36 CFR Chapter 11, Subchapter B).” You can find this here: http://www.archives.gov/records-mgmt/memos/nwm04-2010.html

    It will probably encourage agencies to place their records schedules on-line, as NARA has recently done here: http://www.archives.gov/about/records-schedule/ and with the GRS, which covers about 40% of all Federal records, found here: http://www.archives.gov/records-mgmt/ardor/records-schedules.html

    I guess there will be some discussion before any decision about putting records schedules on-line is made by NARA management. As you know, in our current legal environment, NARA approves the proposed records schedules. The onus of records management, however, is on the agency head to decide what the record is, decide how to create the record, set up recordkeeping systems, etc.

    NARA is given limited oversight power over records management. I think there has to be some thought as to any implications of publishing schedules on-line. And I guess we are talking about schedules. Or would you want the appraisal, back-up decisional documents, etc. to be published? You are not clear. I think you may not have had a chance to think everything through. Mr. Ferriero, whom we all admire, will have to.

    Just for fun, and more than very quickly, I sought out the opportunity for the “review of records disposition/appraisal decisions,” or “publication of schedules” (and variants- both are my terms) of the Canadian, Australian, and the United Kingdom National Archives/Governments. I may not have found everything. I encourage, invite folks to point out that which I missed.

    On the Library and Archives Canada site, looking for published schedules, I found: “The Records Disposition Authorities Control System (RDACS) – coming soon” and Library and Archives Canada is currently working towards making the system available to the public (http://www.collectionscanada.gc.ca/government/disposition/index-e.html).

    I did not see anything at all concerning proposed schedules.

    On the UK National Archives site, I found something that looked suspiciously like NARA’s “GRS” schedules: http://www.nationalarchives.gov.uk/recordsmanagement/retention-disposal-schedules.htm

    Other than the “GRS,” I found nothing else. I am willing to listen and be guided to an online schedules for individual agencies, and opportunities to comment on proposed records schedules.

    Finally, on the Australian National Archives site, I did locate the records schedules on-line: http://www.naa.gov.au/records-management/keep-destroy-transfer/authorities/list-ra.aspx

    I did not see any opportunities to comment on records schedules. Again, I am willing to be informed, directed, etc.

    Although this is for comparison purposes, I don’t judege anybody, or accuse any institution, the institutions employees, or fellow archivists and records managers, of being “unconscionable.” It’s very sad that you used this term.

    Best,

    JC

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