File 8000-38

ELEMENTS OF AN

 ARCHIVAL ELECTRONIC RECORDS PROGRAM

	Prepared by:

Sheila Powell
Special Projects Officer
Records Disposition Division

15 November 1995

	TABLE OF CONTENTS

1. 	Introduction	3

1.1	Background	3

1.2	Approach 	3

2.	Critical Success Factors for an Archival Electronic Records Program	6

2.1	Mission of Program	6

2.2	Adaptation to Change	7

2.3	Responsibility and Accountability for Program	8

3.	Common Elements of Archival Electronic Records Programs	8

3.1	Archival Appraisal	8

3.2	Active Archival Involvement in Standards Development and Systems Design	9

3.3	Reference Services	11

3.4	Investment in Staff Development	11

3.5	Program Evaluation	12

4.	Archival Electronic Records Program Strategies	14

4.1	Custodial Approach	14

4.2	Distributed Custody Approach	16

4.3	Combination of Custodial and Distributed Custody Approaches	19

5.	Conclusion	21

Endnotes	22
Appendix One -- Glossary
Appendix Two -- Bibliography

1.	Introduction

1.1	Background

The Senior Management Committee of the National Archives of Canada (NA) has established the development of an integrated program for the acquisition and preservation of electronic records as one of its strategic outcomes for the years 1995-98.  The National Archives was a pioneer in the field of archival electronic records programs, establishing its program twenty years ago.   It has since been a strong influence on other programs at large archives, and current and former members of its staff, including Katharine Gavrel, John McDonald, Terry Cook, and the late Harold Naugler, have been among the most influential thinkers on electronic records issues.  Over the past two decades, significant changes have been made to the NA electronic records program in an effort to keep up with changes in technology and the recordkeeping environment in the federal government.  There remains, however, a need for self-evaluation and change if the program is to be able to ensure the preservation of the increasingly large portion of Canada’s archival heritage that is created and maintained in electronic format.

To this end, the NA has embarked on a series of activities that will lead to a strategy for a revised electronic records program.  One of these activities, the result of which is this report, is the development of a prototype of an archival electronic records program, based on a review of the relevant archival literature, and of the elements of such programs at other major archives. The prototype set out in this report will be compared with the existing elements of the NA program, which are outlined in a separate report.  With additional analysis from an outside expert on electronic archives, the project team will prepare options for an integrated electronic records strategy for the consideration of the Senior Management Committee.
 
1.2	Approach 

The original intention of this report, as assigned by the Director General of the Archives and Government Records Branch, was that it would set out non-institution specific elements of an integrated electronic records program.  These elements would be “best practices” according to the archival literature, and together would constitute a prototype electronic records program against which the existing National Archives’ electronic records program would be assessed.   Once work on the report was underway, it became apparent that while there is some agreement in the literature as to how certain discrete functions should be carried out (such as preventive preservation techniques for magnetic recording media), there is no single prototype of how an integrated archival electronic records program could or should operate, no one “best” way to do any of the steps involved.

First of all, it is important to define the terms archival electronic records program and preservation.  For the purposes of this report, an archival electronic records program (also referred to as an electronic records program) is a system of policies, procedures, and activities, planned and carried out by an archival institution, the goal which of is the preservation of records in electronic format designated as being of archival value.  Also for the purposes of this report, preservation of electronic records consists of the actions taken to keep electronic records readable and/or interpretable.  Please see Appendix One for more detailed definitions of these and other terms.

The majority of the literature on electronic records consulted for the preparation of this report was archival, that is, it was written by practising archivists, archival managers, or archival theorists. It also became clear very quickly that the literature rarely deals with micro-level issues such as accessioning or processing of electronic records, and therefore does not hold out any immediate solutions to these sorts of technical problems.  Where technical issues are addressed in the literature, the rapid changes to the technology and the pioneering nature of much of the writing means that solutions offered, even as recently as three years ago, can now be viewed as obsolete or unworkable.  The trend in the literature, especially as written by the managers of archival programs such as the New York State Archives and Records Administration, Australian Archives, and the Archives Authority of New South Wales, is to deal with macro issues, particularly the examination of the overall direction of archival electronic records programs for planning or “re-engineering” purposes, and proposals for the direction that the programs should take.

The author has concluded, therefore, that instead of a single model for how an archival electronic records program can be established, there are a range of options, based on the environment in which an archives operates.  This report will set out the author’s understanding of the archival and management issues surrounding the operation of an electronic records program.  Consequently, the report offers broad management strategies for consideration, not immediate solutions to particular issues within the National Archives.

Hypothesis 

As archives and archivists grapple with how they will preserve electronic records, they find themselves questioning fundamental archival practices and traditions as they apply to all media, from the definition of a record to concepts of archival value to the role of archives as the custodians of records.  It is increasingly apparent that electronic records will be the catalyst to a far-reaching re-examination of the missions and mandates of archival institutions, and of the role of archives and archivists in institutions and in society in general.  The critical question facing archives is not whether electronic records should be handled as a special medium or integrated into existing practices for all other records:  the question that must be answered is how archives and archivists will remain relevant in the face of continuing, fundamental changes to our society’s recordkeeping practices and the challenges these changes pose to archives’ accountability and cultural responsibilities.

Archives, therefore, are at a crossroads without a road map.  The author contends that the answers to the question of which way to go must be found within the archives’ internal and external environment:

•	the archives’ enabling legislation or authority
•	the mandate and acquisition policy of the archives
•	the financial and human resources available to the archives
•	
•	the nature of the archives’ relationship with its parent institution and/or donors 
•	the archives’ internal culture (its history, traditions, management style, etc.)

While it is clear that all current assumptions about the policies and practices of archives relating to all media must eventually be addressed, archives must waste no time in coming to grips with the immediate problems posed by electronic records.  An examination of the environmental characteristics listed above will lead an archives to identify the direction that its archival electronic records program will take.  The broader issues relating to all the archives’ activities will become clearer as the immediate problem of electronic records is addressed, and archives will be well-positioned for more in-depth self-examination into the next century. 

Approach Taken in Report

Once the overall direction of the program has been established, the archives can then determine how it will approach each of the tasks involved in an electronic records program. The combination of how a particular archives decides it will operate its program can be called a strategic approach.  This report sets out strategies for how an electronic records program could operate; the elements have been grouped into three possible approaches for ease of description and discussion in section four.  The three strategic approaches addressed in this report are as follows:

1.	Custodial Approach

2.	Distributed Custody Approach

3.	Combination of Custodial and Distributed Custody Approaches

The discussion of each strategy sets out how each component of the program should operate according to  the parameters of the approach (not all components are applicable to all approaches).  The components addressed are:  the archives’ relationship with the creating agency, archival appraisal, acquisition, control, processing, description, preservation, reference and diffusion, and human, technical, and information resources.  The advantages and disadvantages of the approach, and any other relevant issues are also considered.

The discussion of the three approaches is in Section Four, Archival Electronic Records Program Management Strategies.  In the complex world of archival electronic records programs, the reduction of the variables to three general strategies might appear simplistic; there could, of course, be any number of variations and combinations of the elements necessary to an archival electronic records program, each combination forming a different strategy.  The important point is that the elements of a program cannot be analysed, planned, or carried out in isolation from one another, or from the larger context in which the electronic records program and the entire archival institution operates.

Section Two, Critical Success Factors for an Archival Electronic Records Program,  discusses three broad elements that must be present regardless of the specific direction chosen for the program.  Section Three, Common Elements of Archival Electronic Records Programs, addresses the elements of an electronic records program that should operate in the same manner (such as archival appraisal on the basis of functions performed by an agency), again, regardless of the particular direction chosen for the program.  There are also two appendixes to this report.  Appendix One is a brief glossary of terms.  It is recommended that readers examine the glossary before reading the report, as some of the terms may be unfamiliar, or may be familiar archival terms used in a slightly different context in relation to electronic records, such as the term preservation.  Appendix Two is a bibliography of the literature consulted during the preparation of this report.

Some comments on a draft of this report indicated that some AGRB staff believed that this report did not acknowledge that all archival activities relating to electronic records should be performed in conjunction with records of all other media.  The author of this report agrees that electronic records must be integrated into all “normal operational processes of the institution,” as stated in the directions given to the participants in the activities leading to the development of the NA electronic records program by the Director General of AGRB.  Nevertheless,  electronic records pose particular challenges that must be addressed, and it is outside the scope of this report to deal with issues relating to records of other media.

The report does not make specific reference to issues relating to Geographical Information Systems (GIS), Computer Assisted Design (CAD), or other graphic electronic systems.  It is assumed that the program elements discussed here are generic in nature, and apply to all aspects of an electronic records program. 

A companion report has been prepared by Ann Martin of the Government Archives Division that sets out current National Archives activities and initiatives relating to electronic records.  The author of this report on non-institution specific elements of an electronic records program has therefore  endeavoured to avoid any references to National Archives-specific programs and policies. 

2.	Critical Success Factors for an Archival Electronic Records Program

There are three basic management prerequisites for the success of any archival electronic records program:

2.1	The archives must establish a mission for its archival electronic records program.

An archives must define the mission of its electronic records program and of the archival institution as a whole, and use the resulting statement of purpose and identity to determine how the program will operate.  This definition must take place before any other aspects of how the program will operate are determined, as the nature of the program must conform to its overall purpose and identity.  David Osborne and Ted Gaebler state in their influential book Reinventing Government that “Clarity of mission may be the single most important asset for a government organization,” and that it “can drive an entire organization, from top to bottom.”  This is precisely what any archives should do when establishing an archival electronic records program.
The stated purpose of the program should be specific enough to provide  meaningful direction for  its operation, but should also allow for it to respond to technological change (see next prerequisite for success). The purpose and identity of the program will in part be determined by its enabling legislation or policy, the needs of its sponsoring agency and that of any other clientele, its budget, and other internal and external factors.  For example, an archives must decide if its archival electronic records program is only to preserve records, defined in the glossary in Appendix One as evidence of the transaction of business or the conduct of affairs of the archives’ sponsoring agency, or if it will also act as a data library by preserving and providing access to data accumulated by the sponsoring agency.   An archives must also determine if electronic records will be preserved only to support the continuing business needs of its sponsoring agency, or for social and cultural purposes as well.

The archives must decide whether it will deal with electronic records in an integrated fashion throughout the range of its programs (such as appraisal, description, and reference services), or if it will treat electronic records as a special and separate medium.  Looking to the external environment, the archives must also determine the role of its program in relation to other institutions that preserve electronic records, data, or publications.  This will prevent duplication in preservation between the archives and other institutions, and ensure that the needs of record creators and users are met by the appropriate institutions and in the most efficient and cost-effective manner.

2.2	The program must be prepared and able to adapt to current and changing organizational, technological, social, and economic conditions.

Individuals responsible for an electronic records program must recognize that the world of electronic recordkeeping and information systems is constantly changing due to technological advances and the increasingly complex uses of these systems by record creators, and that  this unrelenting change must be met with a willingness to experiment with different ways of doing things, including different ways of organizing work, and not with a reluctance to make decisions in case they turn out to be wrong.   The archives must also recognize that change occurs not only in relation to technology but also in relation to public policy and society itself, and that these non-technological changes can also have an impact on the success and relevance of its electronic records program.

While the archives is affected by changes taking place in its environment, it must also be prepared to initiate change itself, when such change would enhance its ability to preserve records of continuing value.  This includes amending the archives’ mandate when it is no longer adequate to allow the archives to do its work of preserving records.  Even as serious a move as changing enabling legislation should not be ruled out; in some jurisdictions, legislative change might be required in order to ensure the preservation of electronic records. 

2.3	A person or a group of persons takes responsibility for and is accountable for the operations of the archival electronic records program

In an integrated electronic records program, functions related to electronic records are performed in all areas of the archives.  These sectors play an important role in the success of the program.  This is a great strength, but it can also be a weakness.  Because responsibility for the program is divided up among a number of functionally-defined areas, it may be difficult for one area to understand the role of another area in the working of the program.  This could lead to a lack of appreciation for the contribution of the various people and units that make up the electronic records program.  It could also be easy, in difficult times, for any of the managers involved to avoid responsibility for problems and for putting them right.  One solution to these problems is for one person or group of persons to assume or be assigned a coordinating role.  The coordinator(s) would facilitate continuing communication within the archives in order to enhance an appreciation for the contribution of all staff members; ensure that the integrated program operates as planned; and  take the required actions if things are not going as planned.  Responsibility and accountability could rest with the head of the institution, a delegate of the head, or with a steering group composed of senior managers.

3.	Common Elements in Archival Electronic Records Programs
 
This section  addresses the elements of an electronic records program that should operate in the same manner regardless of the particular direction chosen for the program.  

3.1	Archival Appraisal 

The need to cope with vast quantities of records has been a constant problem for archivists throughout this century. In recent years, the exponential growth in the amount of recorded information produced by governments, other organizations, and individuals has led to much new thinking on the subject of appraisal.  The need to integrate electronic records into our theories and practices has been part of this process.  Many archives have rethought their approaches to appraisal and to records disposition.  There is still a need to address two important aspects of appraisal in relation to electronic records:  appraisal according to function; and appraisal for continuing, not necessarily permanent, value.  

Appraisal According to Function

As will be discussed in section 3.2 below, there is unanimous agreement in the archival literature reviewed for this report that there must be active archival participation in the design of electronic information and recordkeeping systems in order to ensure that archival requirements are taken into account at the very outset, and built into the systems.  What is not as frequently addressed in the literature is how archivists are to determine which systems will be required to include these requirements.  It is unlikely that many archives will have the resources necessary to ensure it has input into the design of all systems used by its sponsoring body.  There must, therefore, be a means of determining which systems are of high enough value to be targeted for archival requirements before the system is actually designed.  The best way to determine the systems of value before they are created is to perform “macro-appraisal” in order to determine which functions performed by the organization are of high enough significance at the present time to warrant on-going preservation of the records created as a result of those functions.  As macro-appraisal theorists state, the archivist can assume that if the function is important, then the records created as a result of the carrying out of that function are important. 

Once the important functions have been identified, the archives is in the position of being able to alert the organization to the need to involve the archives whenever recordkeeping systems are designed or redesigned in support of those functions.

Appraisal for Continuing Value

A recurring theme of the literature is that archivists must discard their notion of “permanent value” in favour of a concept of “continuing value.” Some archivists argue that the cost of maintaining a series of electronic records for archival purposes must be taken into account when the archival value of a set of records is assessed; this assessment must be done on a continuing basis, after the initial assessment has been made.  The argument is also made that it is impossible to determine now what will be of permanent value, because concepts of what constitutes value change over time.  Archivists must therefore be prepared to make an initial designation of continuing or long-term value in order to protect records, and must also be prepared in the future to reassess that decision in light of changes that have occurred.  The concept of continuing value is especially relevant to electronic records.  The Australian manual Keeping Archives states: “Particularly in the environment of electronically created and stored records, information must be demonstrated to have a continuing value to the next generation before adequate resources can be justified to keep the records readable.”  An electronic records program must therefore be prepared to reappraise electronic records to ensure that their continued preservation is warranted, and ensure that records creators are aware that this reappraisal will take place.

3.2	Active Archival Involvement in Standards Development and Systems Design 

Another aspect of electronic records programs that receives virtually unanimous approval in the literature is that archives should be actively involved in the planning and design of electronic information and recordkeeping systems in order to facilitate the long-term preservation of electronic records.  This archival involvement can take place on a number of levels.  Archives can participate with industry and  national and international standards organizations in the development of standards for the creation and interchange of electronic data and records and for metadata.  Archivists can also engage in research into electronic records systems in order to be able to provide advice to clients that are planning to establish electronic recordkeeping systems, or enter into partnerships with record creators and/or industry in order to develop systems that can facilitate the creation of true records and preserve records for the long term.

At the system-specific level, archivists can endeavour to exert influence at the system design or redesign stage in order to promote the inclusion of measures to enhance the long-term preservation of records of value.  It is generally acknowledged that disposition practices used for “traditional” records are not suitable for electronic records, because it is inefficient and often impossible to reconstruct the context of the creation and use of electronic records and the original structure of the records at the end of their life cycle.  The purpose of archival requirements for electronic recordkeeping is to ensure that adequate information about the context, structure, and content of the records is built into systems, ensuring that the system comprises a recordkeeping system.  Other requirements  could be built in to ensure that disposition occurs at the right time, according to archival needs. Archivists should determine which systems they will target for such involvement through functional appraisal (see section 3.1 above).    

The archival electronic records program may choose to assert its role through case by case involvement in system design, or through general regulations, applicable to all agencies within its purview, that would compel agencies to take certain steps at the design stage and throughout the life of a system to ensure compliance with archival requirements for preservation and access.  The route the archives chooses will depend on its relationship with the agencies in question, and the other environmental factors discussed in the introduction to this report.

Archives that collect records created by individuals and organizations outside of their sponsoring institution (i.e. the collection by a government or university archives of the records of bureaucrats, faculty, writers, or associations) also need to play a more active role in the creation of electronic records of archival value in order to ensure their preservation.  In many cases, contact between archivists and such donors takes place some time after the creation of records has started; in the case of individuals, often just before or after death. By that time, electronic records created by these donors will likely be unreadable due to software and hardware obsolescence, or the readability would be difficult and costly to reconstruct.  Archivists involved in this sphere of acquisition should therefore employ the same general techniques as their counterparts in the institutional setting and endeavour to make contact with potential donors as early as possible in the creation phase.  Australian manuscripts archivist Adrian Cunningham suggests that archivists should try to make contact as soon as it becomes apparent that a person’s achievements are worthy of documentation in archives.  He recommends that archivists give potential donors advice on the creation and maintenance of electronic records, citing the example of the Australian Council of Libraries and Information Services (ACLIS), which has printed a brochure and has taken out advertisements in publications aimed at writers urging them to print and keep copies of drafts.  Cunningham also urges archives to take periodic transfers of records in order to safeguard them, if possible, rather than wait until late in the donor’s life to accept a transfer of all the records at once.  He points out that this approach is already used for certain types of donors, such as writers, by many manuscript repositories for records in non-electronic format.  

Interchange standards and backward compatibility capabilities in software are also relevant to archives collecting outside of their sponsoring agencies.  Archivists should explore methods for influencing software manufacturers to provide the means to read all previous versions of a software,  or at least making individual software users aware of the long term problems of backward compatibility.  Software aimed at replacing photo albums and family scrapbooks is now on the market.  One of these programs, Echo Lake, available from Toronto's Delrina Corp, allows for the compilation of text, photos, drawings, sound, and video. Unless the issue of standards is addressed by the industry (hopefully with the input of archives), archives will lose a valuable source of documentation on the lives of  the ordinary and extraordinary alike.

3.3	Reference Services

The increasing creation of records in electronic format is being parallelled by a trend to greater use of computers by researchers.  The archival literature has focused more on giving networked access to information about holdings and to the digitized holdings themselves, and less on the implications of giving researchers access to records that are software dependent and available only in electronic form.  In their study “Scholarly Communication, Information Technology, and Archives,” Avra Michelson and Jeff Rothenberg discuss the use by scholarly researchers of a range of computing technology, from the participation in listservs for the discussion of research interests, to browsing university library catalogues on the Internet, to the use of hypermedia for the electronic publishing of research papers.  These examples illustrate relatively straightforward ways of adapting information technology for activities (chatting with colleagues, browsing a card index, and publishing in a journal)  that were previously carried out without advanced technology.  The authors are particularly concerned with the needs of a community that is generally very conversant and comfortable with information technology.  

The authors do not, however, explore other important implications.  For example, how should archives deal with non-computer literate people who want access to records in order to protect their rights as citizens or hold governments accountable for their actions, when the only relevant records are in electronic format?  How will archives make all potential users aware of the existence of electronic records?  How will it  make the records usable?  Are archives actually discouraging use of electronic records by failing to improve methods of giving access to them?  While some archival electronic records programs have experience in giving researchers access to non-confidential data sets, there appears to be less experience with reference issues related to more complex and/or confidential records.  While electronic records programs will probably not have to contend with a heavy reference demand for some time, the time will come, and programs should start to prepare for how they (or the agencies that maintain custody of records of continuing value) will deal with reference demand. 

3.4	Investment in Staff Development

It has become a cliché for an organization to say that its employees are its most important asset.  It is true, however, in the case of electronic records programs, where the development of the staff’s knowledge of electronic records issues is an important investment.  David Bearman, among others, has stressed that it is crucial for archivists to be able to communicate with the designers of electronic recordkeeping systems in order to ensure that archival requirements are understood and implemented.  He emphasizes the unique skills required of archivists to assist record creators in the establishment of true recordkeeping, as opposed to information, systems:

Recordkeeping systems-oriented thinking not only gives archivists a tool that supports documentation, appraisal, preservation, and retrieval, it defines for them a unique role among information professionals as defenders of records rather than processors of information.  It defines special skills which archivists can learn in their educational programs and apply in their professional lives and which are not the province of the other information professions.

Bearman believes that archivists do not yet have an adequate understanding of recordkeeping systems.  For those archivists who understand the composition of a good recordkeeping system, it is likely that this understanding is based on knowledge of manual systems.  Archivists must acquire the new skills necessary to impart this knowledge to records creators, users, and system designers of electronic recordkeeping systems.  Practising archivists who have not acquired these skills in their archival training will have to learn them through other educational opportunities. The skills that are required are not just related to technical specifications, but also include understanding  an organization’s recordkeeping requirements, business process engineering, corporate accountability, and risk assessment decisions. 

Employee development can take many forms: formal training, the sharing of experiences among staff members, attendance at and participation in workshops and conferences on electronic records, independent research, mentoring relationships, and on-the-job experience through job rotation are just a handful of the methods that can be used.  Employees of an electronic records program also need access to up-to-date literature on electronic records and archival science through a traditional library and through newer sources of information, such as the Internet.

3.5	Program Evaluation

Entrepreneurial public organizations are learning organizations.  They constantly try new things, find out what works and what doesn’t, and learn from the experience.  But if an organization doesn’t measure results and can’t identify success when it happens, can it learn from success?  Without feedback on outcomes, innovation is often stillborn.  
David Osborne and Ted Gaebler, Reinventing Government, pp.  150-51.

The concepts of strategic planning and other management techniques aimed at creating and getting effective programs off the ground are well-accepted in most institutions.  Less accepted and implemented is the concept of program evaluation, the purpose of which is to take stock of programs in order to determine if they are working as intended and, if not, what changes are necessary to get the program back on track.  

Osborne and Gaebler’s influential 1992 book Reinventing Government stresses the importance of determining if a program is working as it should by measuring the results and outcomes of the program, not its inputs.  Results are produced by the processes that are put in place in order to achieve specific program goals; outcomes are the impact of results.  Results should be tracked, and are a good indication of the success of the processes that are in place in order to achieve goals.
For example, for an electronic records program, an accurate measure of its success would not be the amount of money that is spent on it (an input), but the number of archivally valuable electronic records series that are acquired (a result); not the number of electronic files accessioned (an input), but the number processed and available within a specific period of time (a result).  These are crude examples, but it is crucial that regular and consistent (the same unit of measurement is used every time) measurement of results be conducted by all work units in the electronic records program.  This measurement need not be a full-blown audit, but should be accomplished through the regular reporting that is done throughout the year in most organizations. 

Outcomes are much more difficult to measure, as they are the impact of an entire program as expressed in its mission statement.  The true impact of a program may not be felt for years (or even decades, in the case of archives) after implementation, and the intended impact may also be very difficult to quantify.  An archives that is determining the mission of its electronic records program  or rethinking its overall mission may wish to phrase its mission statement in such a way that the outcomes of the program can be measured -- most, if not all, of the outcomes should be quantifiable and should be recognizable after a relatively brief period of time, i.e., after one to five years -- in order that the value of the program can be proven to the archives’ resource allocators.

What should an archival electronic records program do when the measurement of its results and outcomes shows that the program is not achieving what it is supposed to?  Osborne and Gaebler insist that successful organizations learn from their failures.   In the fast-changing world of electronic records, there will always be risks associated with any decision or action taken by an archival electronic records program.  The key is that the program continually assesses the effectiveness of its activities in meeting the program’s goals, and that when things go wrong or mistakes are made the program learns from the mistakes and continues to move forward.

NB:  The emphasis on measuring outputs in order to assess the degree of success of a program does not preclude keeping track of such inputs as what the program costs.  Such information is necessary to calculate the cost effectiveness of a program, which must always be taken into account when a program is evaluated, especially archival electronic records programs, which usually entail a large investment in computer hardware and software and expert advice.

4.	Archival Electronic Records Program Management Strategies 

The previous sections have examined some of the basic management principles and fundamentals of archival practice that all archival electronic records programs should adopt. This section outlines elements of three distinct strategic approaches for how an archival electronic records program could operate.  They are intended to be considered in the context of the success factors and common program elements set out in Sections Two and Three.  The approaches are hypothetical constructs formulated by the author, based on the various approaches set forth in the literature, and are presented here as prototype options for the purposes of discussion.  The approaches offer broad management strategies, not specific directions for how programs should be delivered, nor recommendations for how programs should be organized for the purposes of program delivery. They do not comprise specific recommendations for adoption by the National Archives.

4.1	Custodial Approach

In this approach, the archival electronic records program operates as would any other archival program for non-electronic records, with all the basic archival functions of appraisal, acquisition, arrangement/processing, description, preservation, and reference service performed by the archives.  The program assumes ultimate responsibility for the custody and preservation of all records it designates as having archival value; that is, regardless of any long-term retention of electronic records by particular agencies, it is accepted that all electronic records having archival value will eventually be transferred to the custody and control of the archives.

Supporters of the custodial approach to archival electronic records believe that taking electronic records out of the custody and context of the creating agency into the custody and control of an archives is the only way to imbue the records with true archival value.  Ken Thibodeau, head of the U.S. National Archives and Records Administration (NARA) Center for Electronic Records, has written that there must be a “categorical separation between the operating environment in which records are originally created and the archival environment,” and that “archival value is not only enduring value; it is value apart [emphasis in original] from the original context.”  What constitutes an archival environment?  According to Thibodeau, it is one in which there are “adequate controls to guarantee that records will be preserved and that they will not be altered.”  In order to have the “archival environment” for electronic records as envisaged by Thibodeau, the custodial electronic records program must be able to provide all required services to the records to have the “value-added” effect of custody within an archives, i.e. processing, description, and availability to researchers, and all must be done promptly and extremely well.  Members of the National Archives staff have commented to the author of this report that Thibodeau no longer holds these views; nevertheless, the view that archival custodianship imparts a special kind of value to a series of records is significant, and Thibodeau appears to be alone in making this point in print in relation to electronic records.

A further advantage of the custodial approach is that all parts of a recordkeeping system (electronic, paper, graphic) are kept together in the same institution.  While proponents of non-custodial arrangements for electronic records would point out that technological developments render the physical location of archival records irrelevant from the point of view of the user, the symbolic importance attached to the bringing together of all parts of a recordkeeping system in a single repository should not be minimized.

Relationship with Record Creators

Like any other type of  archival electronic records program, an archives using the custodial approach must play a role in the design of systems of archival value.  In this approach, the archives must be completely sure of the requirements that it wants to be embedded in such systems, in order to ensure that all of the archives’ needs for custodial purposes are met, i.e. that migration to the archives’ system can be accomplished as efficiently and inexpensively as possible, while maintaining the functionality or context of the original records, and that adequate metadata is provided to serve as, or provide the basis for, the archival description.  All disposition authorities and/or transfer agreements must stipulate the transfer specifications, and the archives must keep these conditions up to date in order to avoid costly delays and problems upon transfer.  The timeliness of transfers of electronic records must also be monitored closely by the archives to ensure that records are transferred when they are supposed to be transferred, as any significant lag between active maintenance by the creating agency and the transfer to archival custody could result in the accidental erasure or natural deterioration of records or software obsolescence problems.  The archives should also monitor transfers to ensure that they are spaced out over time in order to prevent the creation of a backlog due to too many transfers occurring at the same time. 

Processing and Preservation

A custodial archival electronic records program must possess or have access to all the hardware and software required to process and preserve access to the electronic records in its custody.  It must maintain appropriate systems to gain access to the records, and be able to migrate the records to successor systems upon obsolescence, and at the same maintain the evidential qualities of the records over time and technological change.  In this regard, the electronic records program must establish its own standards for what is an acceptable loss of contextual or formatting information upon migration. The program must have a large enough budget to carry out a complex in-house preservation program or to contract the preservation program to a service provider.  The archives must also employ, or have access to, people with the technical skills to perform all tasks relating to the preservation of the records.

The basic components of archival processing of electronic records have not changed significantly in the eleven years since the publication of Margaret Hedstrom’s Archives and Manuscripts: Machine-Readable Records, one of the Society of American Archivists’ Basic Manuals.  The same basic steps of initial copying into archival format, and proper storage and maintenance are included  in the New York State Archives and Records Administration’s recent “Proposed Program to Preserve Electronic Records in SARA Holdings.”  The technical activities that must be undertaken to preserve electronic records physically (as opposed to ensuring their readability in the face of software dependency and obsolescence) can be grouped into five principle areas: creation, validation, storage, maintenance, and monitoring.  At the creation stage, the archives receives the electronic records from the creating agency and transfers them onto the storage medium used by the archives (still in most cases nine track magnetic tape) and into a standard data storage format, if possible (usually ASCII).  The archives makes sure the tapes onto which the data files are copied are of acceptable quality.  Two copies are made, one working copy, one preservation copy that will be stored separately.   At the validation stage, the working copy is checked to ensure that it is readable, then verified against its metadata (which will also have been acquired from the agency) to ensure that the contents are understandable.  NARA’s Center for Electronic Records has developed the Archival Electronic Records Inspection and Control System (AERIC) to automate verification, which has been a largely manual task.  The archives must then store its tapes in optimum storage conditions for temperature, humidity, and security.  Maintenance entails regularly inspecting tapes to ensure they have not deteriorated and copying the data onto new tapes on a regular cycle.  Monitoring involves taking appropriate steps to ensure that the above tasks take place when they should and are done properly.  Another aspect of monitoring is ongoing research to keep abreast of technological developments in order that the archives can improve its practices.

These tasks may appear complex, but they are simple compared to the steps that must be taken to retain the functionality of records as originally created and used within an electronic recordkeeping system, and to maintain both the readability and functionality of the records as they are migrated forward as software and hardware change over the years.  Custodial archives will have to determine how they will maintain the readability of  records such as complex documents (electronic documents that must be read using two or more different kinds of software, often incorporating graphics and even sound).  Even today’s relatively straightforward office systems create documents that are dependent on proprietary software in order to be read and understood.  In order to meet all of its technical requirements, a custodial archives must either take it upon itself to be aware of technological developments and be able to adapt them for its use, or be prepared to pay consultants and service bureaus (if indeed they exist) for their expertise and services.

4.2	Distributed Custody Approach

In the “distributed custody” approach, also known as the non-custodial approach, only the functions of providing recordkeeping advice, appraisal, and possibly description (see below) are carried out by the archival electronic records program.  All other archival operations, including custody, preservation, and reference service, are performed by the creating agency, or in some cases by a successor agency that uses the records created by its predecessor (the “using” agency), or by an agent of the creating agency.  Unlike the custodial approach described above, the archival institution assumes no responsibility for the actual preservation of electronic records of continuing value, other than monitoring agency compliance with archival standards for preservation; ultimate responsibility is devolved to the creating agency, its successors, or its delegates.  Supporters of the distributed custody approach argue that it makes technological sense to leave software-dependent records in the hands of the creators, because they are most likely to be able to maintain access to the records through forward migration. 
The emphasis in the distributed custody  approach is on the archives as regulator, setter of standards, and coordinator of the distribution of information about records: the archives establishes functional requirements to ensure that electronic recordkeeping systems are designed to protect the evidential quality of the records; the archives sets standards for the preservation of accessibility of records and  monitors agency compliance with the standards; the archives develops an information locator system to allow one-stop shopping for electronic records at a large number of agencies.  An archives that chooses the distributed custody approach must possess sufficient authority to be able to require creating or “using” agencies to maintain their electronic records for future use, and must be able to enforce compliance with preservation standards designed to keep the records readable and interpretable.

Relationship with Record Creators, including Records/Information Management and Information Technology Personnel

As in the previous custodial approach, the archival electronic records program must also become involved in the  planning and design stage of recordkeeping and information systems that have archival value in order to ensure that agencies take into account the costs of maintaining systems on a permanent basis. 

Archival Appraisal

Again, similar to the custodial approach discussed above, archival involvement at the design stage necessitates the identification of recordkeeping and information systems of archival value at the design stage or earlier, which means that archival appraisal must be based on the function(s) that the system supports.  Appraisal decisions in this approach must be completely justifiable, as they entail compelling another agency to retain records long after they cease to be of active use for operational purposes.  The archival electronic records program cannot risk forcing other agencies to retain records unless it is completely clear that the records are indeed of continuing value.  Agencies may balk at being required to maintain, at their own expense, records that the archives  has identified as valuable.  The archives, therefore, must be able to justify its appraisal decisions according to a sound set of appraisal criteria.  In this scenario, it is unlikely that archivists will be able to hedge their bets by preserving records that have slight or only potential value.  Indeed, archivists may well  identify fewer records for continued preservation than they do at present, and  records of possible archival value may be lost.

Preservation

In theory, the distributed custody model entails no physical acquisition and no control or processing activities on the part of the archival electronic records program.  Some proponents, such as the Australian Archives recognize that the archives will be forced to act as the custodian of “last resort,” which would necessarily entail the archives having, or being able to gain access to, the capacity to preserve the records.

Description and Reference

While the archives will not be required to provide direct access to electronic records that have not been accessioned into the its holdings, the archives does assume the responsibility to provide, or coordinate the provision of, information about electronic records of continuing value that are in the custody of other agencies.  The archives may choose to lead the development of a locator system for users to gain access to information on records located at a number of decentralized sites, along the lines of a Government Information Locator System (GILS).  It must also be remembered that the archives may well house the non-electronic records of the same agencies (although a strictly non-custodial approach could also choose to leave non-electronic records in the hands of the creators).  The archives would need to adapt descriptive practices to allow for the matching of records housed in the archives and corresponding parts of same recordkeeping system in electronic format that are held by the creating agency. 

Other implications

The distributed custody model assumes that an agency will be able to care for its electronic records of enduring value.  The model, therefore, would only rarely be  applicable to the archives of private organizations and individuals, the majority of which cannot be maintained by the creator or a successor organization.  An archives with a program for the acquisition of the records of organizations other than the parent, or sponsoring body, or of individuals would have great difficulty preserving that portion of the record of its donor community that is in electronic format.

This approach is also best-suited to a purely-institutional archives -- an archives that preserves records created only by the parent body for purposes of on-going use and accountability.  Archives that also preserve records for informational or cultural purposes, or that are “collecting archives,” do not fit as well into the approach of distributed archives.  It is less likely that an agency would be willing to preserve records for which it had no particular use and which it was required to preserve for the purposes of people or groups outside of the creating organization.

Rick Barry, formerly the Chief of the Information Services Division of the World Bank, and now a consultant, supports the concept of distributed custody, while raising a number of caveats about how a national archives can implement the idea.  In a message posted to the ERECS-L listserv, a discussion group on electronic records on the Internet, Barry comments on Australian Archives’ decision to adopt the distributed custody strategy for the preservation of electronic records. Barry notes that moving to distributed custody will require a major shift in direction for most archives:

Thus, a major consideration in successfully implementing the “forth [sic] option” of distributed national archives means also gearing up to the non-trivial task of providing the national archives with new skills and infrastructure implicit in such actions as noted above, e.g. obtaining staff skilled in the fields of training, information management and engineering, wide area networks, open systems standards (X.500), and probably including distance learning approaches to training.

Barry writes that “Unless legislation or other high-level government policy with teeth in it is in place, there is a serious risk that the distributed approach will fail or a least partially fail.” 

4.3	Combination of Custodial and Distributed Custody Approaches

This approach combines aspects of both the custodial and distributed custody approaches.  Some electronic records will be acquired and preserved by the archival electronic records program, and others will be retained and preserved by the creating agency.  The archives neither assumes ultimate responsibility for the preservation of all electronic records of continuing value, nor does it devolve all responsibility to the creating agencies.  Rather, decisions as to the custodial future of electronic records are made in cooperation with creating  agencies according to the degree of appropriateness of the custodial strategy to a particular series of electronic records, based on a range of factors, such as the agency’s electronic  recordkeeping capabilities and its organizational culture. 

Because the decision as to whether to acquire electronic records is based on the nature of each particular case, the combination approach can be used in archives that are concerned only with the records of their sponsoring institutions, as well as archives that both deal with the records of their sponsors and collect records from individuals outside the sponsoring institutions and from other organizations.

Key  characteristics distinguish the combination approach from the other two:

•	Under the custodial approach, an archives may permit the long-term retention by the creating or “using” agency, due to factors such as the technical complexity of the electronic recordkeeping system or limited financial and human resources on the part of the archives, but the ultimate goal of eventual transfer to the archives is never surrendered.  Under the combination approach, the agency commits to a responsibility for the preservation of electronic records equal to that assumed by the archives for records in the archives’ custody.  
•	Under the distributed archives approach, all records are left in the custody of the creating or “using” agencies, and only in extraordinary circumstances would the archives acquire electronic records.  The combination approach recognizes that in many real situation this approach will not work, but also recognizes that in many situations it will work.  It is the establishment of  clear and explicit criteria that must be met in order for an agency to be considered suitable to retain records of continuing value that renders the combination approach a realistic and pragmatic alternative to the distributed archives approach. 

An archives that adopts the combination approach must establish a set of criteria by which it will measure the degree of appropriateness of either acquiring a series of electronic records or allowing them to remain with the creating agency.  The factors identified by the New York State Archives and Records Administration’s “Building Partnerships” project as incentives for the establishment of good record-keeping practices by state agencies are also indicative of the suitability of an agency for the permanent custody of its electronic records, and can serve as the starting point for the development of a set of criteria for whether an agency should retain custody of electronic records of continuing value.  These factors identified by the New York State Archives are:

•	a clear legal requirement for records retention
•	need for access to quality records, data, or information to support ongoing program functions
•	use of records by parties outside the program area or agency
•	high degree of risk associated with poor recordkeeping
•	high visibility of the program or function
•	demonstrable benefit from effective recordkeeping
•	an organizational culture of stewardship for records
•	an organizational culture that accepts electronic recordkeeping

The National Archives of Canada has developed criteria for determining if a series of electronic records identified as having archival value should be allowed to remain in the custody of the creating agency for a long period of time.  Terry Cook of the NA discusses the criteria and accompanying policy in a recent article in David Bearman’s publication Archives and Museum Informatics.  The NA will not acquire records when:

•	cost or technical factors make it impossible to acquire records at present
•	there is a continuing and long term operational requirement for the records, which includes the provision, by the agency, of “elaborate or extensive reference services”
•	reference service on the records can best be provided by the agency, rather than the NA
•	statutory provisions prevent transfer to the NA

Other implications

Because this approach combines aspects of the custodial and distributed custody models, the archival electronic records program must be in a position to put resources into both the up-front work involved in monitoring the preservation of records kept in the creating agency and the back-end work of processing records and providing reference in the archives.  This requires that archivists possess a wide-range of skills and the archives must have adequate computer equipment  in order to perform all of the tasks, while the other two approaches could allow the archives to concentrate on some tasks and put fewer resources into others.  For example, under the distributed custody approach, the archives does not perform any of the work related to preservation.  Resources could therefore be funnelled into participation in systems development, or into the monitoring of preservation within agencies.

5.	Conclusion

The world of archives and archival institutions is sufficiently complex to render the task of setting out prototype archival programs extremely difficult; describing programs that frequently exist only in the minds of archival theorists is nearly impossible.  The main message that this report has endeavoured to impart is that an archives must choose an approach to electronic records that fits the  mission of the archives, as well as the environment in which the archives operates.  This is not to say that the archives can thus avoid facing up to changing its internal culture or even its external environment.  The archives must, however, be pragmatic in choosing a method of facing its responsibilities for electronic records that can be implemented within reasonable limits.  The task of designing or redesigning an archival electronic records program is one of the most exciting challenges that archivists face at this time.  It is hoped that the program elements and approaches outlined in this report are of help in meeting that challenge.

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