Tweeting is forever says PROV
Every Tweet, Google Plus update or FaceBook friend request from a Victorian public servant is now destined for the archives, under a new pronouncement from the Public Record Office Victoria (PROV) that “social media posts created or received by public officers in the course of their duties are public records and must be captured, managed and disposed of in accordance with PROV Standards.”
Announcing its Recordkeeping Policy: Social Media, PROV has determined that Victorian government agencies must “Safely retain social media records in a readable format for the minimum period of time required by the relevant PROV disposal authority.
It notes, “Requirements for record creation, control, storage and disposal contained in the Public Record Office Victoria (PROV) Standards are not media-specific and apply equally to social media records. The resulting records should be captured in a timely manner, as it may not be guaranteed that they will remain available online. Records should also preserve the context in which the social media was used. Agencies have a responsibility to ensure full and accurate records of their actions using social media are made and kept.
It says that while “Social media is increasingly used for conducting business by the Victorian government. Confusion over whether social media use is or should be captured and managed as public records has resulted in the need for this PROV policy.
“The (Victorian) Public Records Act 1973 defines a public record as “any record made or received by a public officer in the course of [their] duties.”
This definition includes all messages sent, and responses received, by public officers when carrying out their duties, regardless of the:
- Medium used to send or receive the social media record
- Account name used to send or receive the message
- Role or seniority of the public officer sending or receiving the message.
It includes Facebook, LinkedIn, Myspace Flickr, Youtube, blogs, Twitter and even forums, wikis, discussion boards and groups (e.g. Google groups, Whirlpool)
The PROV paper notes that “The level of resources and effort required to capture and manage social media records will depend on a risk assessment of the use of the social media.”
“Social media posts created or received by a public officer(s) should be captured as close to the point of creation as possible or as soon as practical afterwards.
It also requires that a record derived from social media should contain:
- The content (the information that is sent or received) including representation of the format (text, visual, sound or video);
- The context in which the record is used, the business purpose of the social media record and its relationship to the business of the agency (purpose of the record);
- The structure of the social media post;
- Where possible, the original content, otherwise a text log of entries; and
- The metadata associated with the record.
Metadata requirements are similarly strict, with PROV expecting that these cotain:
- The date and time the message was sent or received by the public officer or agency representative;
- For messages sent by the agency, the name of the public officer that sent the message, who authorised the social media message (if relevant), and to whom it was sent (at a minimum a group address is sufficient)
- For messages received by the agency, the public officer and account name that received the message, the person to whom it was sent, and the name used by the person who posted the message (for privacy reasons, no attempt should normally be made to determine the actual identity of the sender)
- The purpose of the message (the relationship between the message and other records; why the message was sent or received; what it was in response to)
- The name of the social media application that the message was created on.
The question of what content and context should be captured for social media records to be full and accurate is a risk management decision. The agency must determine if the social media post, is in itself an accurate record, or if the agency post along with other users’ interactions form the most accurate record.