It’s hard to know whether to react with applause or despair at the Department of Finance’s recently published Position Paper on a Whole of Government Digital Records Platform.

It is very pleasing that the Australian Government is finally talking about the elephant in the room – that the transition to electronic record-keeping systems has mostly failed to deliver on its promises. Instead of improving productivity and compliance, EDRMS systems have been a drag on performance due to the overhead imposed on staff who were asked to self-manage compliance. Worse still, the ‘easy way out’ of simply avoiding capturing records altogether is leading to significant gaps in records coverage by agencies over time.

The use of EDRMS systems should have only ever been a stopgap solution during the transition to fully digital business processes. EDRMS systems have few of the advantages of fully digital workflows, while having none of the advantages of physical paper. While most EDRMS vendors do include workflow capabilities, few agencies have had the funding or discipline required to build the workflows to support business processes and enforce their use.

From this perspective, it is worrying that the Australian Government is going to attempt to roll out a highly integrated, whole of government EDRMS solution. The proposed solution - to centrally capture everything and then apply “automated” indexing, classification, and disposal of documents  - is misguided. Applying retention decisions at a document level of granularity is not warranted, and will deliver minimal benefits while retaining substantial risks from incorrect disposal.

We do not need better tools for managing documents as records. Rather, we should be moving away entirely from the concept that a “document’ is the natural structure for a ‘record’.

Business areas have increasingly adopted new generations of systems with the help of ICT departments that are not designed with documents at their core. As I wrote back in 2015, “in a post-document world … [line] of business systems supporting core government business assemble screens on desktops, tablets, and mobile devices on demand from a complex and interwoven mesh of structured and unstructured data from local and cloud-based systems ...”

From a strict legal construction of the Archives Act 1983, it is the underlying databases driving these business processes which are the ‘documents’ needing to be managed as ‘records’, not any specific grouping of data.

This completely upends the normal way we think about retention and destruction. In many cases, even if we were to try and apply a 20^th century mindset to record-keeping there is often no meaningful way to disaggregate the data in these systems into ‘documents’. The data is intrinsic to the operations of businesses process, and the business processes are intrinsic to the operations of the host system.

If we accept this premise, determining what to do with an operational system at the end of its life becomes critical. The Position Paper just barely mentions the Australian Government Records Interoperability Framework (AGRIF), an acknowledgement that structured data can’t just be exported into a document format for reuse, but to call the detail provided “skeletal” is an insult to skeletons.

The National Archives provides guidance on how to preserve paper documents, art, photographs, maps, plans, physical objects, books, films, microfiche, CDs, DVDs, tapes, disk drives, and gramophones – but nothing on how to preserve technology business systems and the data held within them.

It’s a glaring oversight. When old systems get switched off, what happens to their records? If decommissioning is caused by a migration to a new system, business data does get migrated – but these migrations always happen outside of almost all systematic record-keeping controls. In most cases, provenance and historical change data just gets thrown away. Is this laissez-faire approach to data migration over time good enough for the National Archives? They don’t say.

Despite all this, the concept of a cloud-based, whole of government document record-keeping system does have some merit. There will always be low volume, ad hoc scenarios that are document-based. Taking away the high licensing costs and management overhead of individual EDRMS systems for these scenarios makes sense.

However, the Pareto principle would suggest that 80% or more of records should be systematised into native digital processes, and 20% or less may have a valid home in any whole of government solution.

There needs to be much more effort put into having a practical plan for record-keeping, archiving and preservation of systems and structured data in our new data-centric world, and much less time worrying about the old world of documents – whether they are electronic or not.

Stephen Bounds is an Information and Knowledge Management Specialist with a wide range of experience across the government and private sectors. He is founding director of consulting firm knowquestion, a specialist in delivering Information Management, Knowledge Management and Information Technology solutions.