Stephen Bounds responds to National Archives

Firstly, I would like to thank Ms Lyons for her detailed response to my article (Will feds be ready for 2015 digital deadline?) and welcome the chance to continue the discussion.

I acknowledge that only records created after 2015 will need to be in electronic format to be accepted by the National Archives of Australia (NAA).  My article was referring to backscanning requirements that would arise for agencies that do not complete the transition to a digital recordkeeping environment by 1 January 2015.  For example, if their transition completed in June 2016, there would be 18 months of records that would need to be sourced in their original electronic format or backscanned before they would be accepted by the NAA.  I agree that this could have been worded less ambiguously in the original article.

However, I do dispute the current status of Check-up 2.0 use within agencies.  Check-up is now a mandatory assessment tool which needs to be signed off by the agency/department head, with a resulting report that ranks agencies by their Check-up score.  This leaves little wriggle room for interpretation:  higher numbers indicate the NAA’s belief that the organisation is doing a better job managing records.  Whether you call this score “compliance”, “performance”, or something else seems a little semantic.  To suggest that staff have no incentive to present the work they are responsible for in the best possible light to their superiors seems rather naïve. 

To take just one example, question 16 of Check-up scores the statement “some records are managed digitally” as a 3 while “most records are managed digitally” scores a 5.  This is very open to interpretation!  In my view, making Check-Up assessments mandatory has reduced the tool’s usefulness overall since the capacity for honest assessment by system owners is compromised.

Ms Lyons comments that “It is only when records are not adequately managed in business systems that they need to be integrated with a dedicated records management system.”  This is quite true, but that “only” is precisely where the gaps lie, and where mandatory Check-Up submissions are most likely to gloss over problems.  The Australian National Audit Office (ANAO) released a report in June 2012 report titled Records Management in the Australian Public Service which was quite clear:  Every audited agency had numerous systems containing records which weren’t being appropriately managed.  These systems could be the ubiquitous Microsoft Outlook (probably the single software product which has most damaged the quality of recordkeeping in government over the last decade), shared drives, or other ad hoc business systems.  In fact, I would be surprised to find a single government organisation that was fully compliant with its recordkeeping obligations.

The same ANAO report also highlights the inability of most agencies to “access complete and comprehensive information when it is required for business or legal purposes”.  This is most often a problem for FOI requests, but also arises in the context of legal discovery.  Far from simplifying records management, as more of our records become digital the speed and ease of their creation makes any manual interactions with recordkeeping systems a proportionately greater burden.

I do believe that integrating recordkeeping with business systems is a superior technological solution.  However, my point was that the ultimate solution is one that lies with people, not systems.  I stand by my previous assertion that the effectiveness of government recordkeeping, regardless of any “digital transition”, requires more than anything “a senior management culture in government that prioritises correct and efficient recordkeeping as a KPI worthy of tracking at the same priority as other business processes”.

Stephen Bounds is an Information and Knowledge Management Specialist with a wide gamut of experience across the government and private sectors.  As founding director of knowquestion Pty Ltd, Stephen provides strategic thought leadership in the development and implementation of modern information systems. Contact him at sb@knowquestion.com.au