How to Meet the NARA 2019/2022 Deadlines – PART 3 of 3
The NARA 2019/2022 Deadline is looming. Organizations are scrambling to get organized and meet the deadlines. But, going fully digital isn’t something you can just fly through. There are dozens, even hundreds of questions to consider, from mapping out your content to mapping your new database, to organizing metadata, there’s a lot to do. I’ve covered these details in my previous 2 blog posts about NARA 2019/2022 deadline.
Now let’s wrap up this three-part blog by discussing the ‘day forward’ content and the lifecycles that you can create for your content.
What’s a Records Lifecycle?
Wikipedia defines a records lifecycle as “the records management phase of the records life-cycle consists of creation, classification, maintenance, and disposition.”
In my diagrams (images 3 and 4 below) I will be using NARA’s Universal ERM Requirements categories for sectioning of the lifecycles:
- Metadata, Maintenance, and Use
- Transfer, Disposition, Disposal
In the previous post, I covered the importance of making a plan for your content and making a plan for your scanned-in content. In this last blog post of the series, let’s cover the lifecycle topic in more detail.
Implement a Lifecycle for Day Forward Content:
To begin, let’s take up a simple example of a high-level electronic record lifecycle. See image 3.
Image 1: High-level concept of a record Lifecycle
Using NARA’s Universal Electronic Records Requirement Categories, I created a basic lifecycle of a typical record. Mapping out a high-level flow for your own agency can help you stay organized when creating a breakdown for other record types. Some things you may want to keep uniform throughout your agency, so I always suggest making your own high-level lifecycle first and then making some detailed ones for more specific content types.
Once you have a plan for your content, as I discussed in blog part 2, you can use a detailed lifecycle to help you map out what critical steps need to occur with the content during its “life.” This may only be for “Day Forward” content and may or may not apply to your 2019 and 2022 scanned in content.
But either way, it can be a very important piece to think about when configuring your system to do what you, and the end-users, need it to do. It will also help you stay compliant to mandates going forward.
So, gather your document types and categories and work out a more specific Lifecycle for each. Start with Vital Records or mission-critical processes. See image 4.
Image 2: An example of a detailed record Lifecycle
In this detailed lifecycle (image 4) I show an example of what one agency’s “Project Documentation” is supposed to go through. This can greatly differ from agency to agency, but it helps to map it out. In this example the steps are:
- Content can be ingested in several ways into the Project Library (document creation).
- Project-specific metadata is added automatically (like project name, start date, etc.).
- After some time, the project gets completed and “closed out.”
- The Project Manager creates a Project Archival workflow to get approved for archival.
- The Director of Project Management approves the project closeout.
- Upon approval, the content is moved to the “Archive” folder on the project site making the content still available to those who still have access.
- Due to the rules set on this folder, the moved content is declared as a “record” and sent to the Records Management Site File Plan in the proper Retention Schedule Category.
- A notification is sent to the RM team letting them know that the project was closed out and has arrived for further controls/steps.
- Record specific metadata is added to the content after arriving into the RM site.
- At some point based on its embedded retention schedule, it is eligible for cut-off.
- At some point based on its embedded retention schedule, it is eligible for disposition (Destroy or Transfer per this example).
- Before content is destroyed or transferred it is sent through an approval workflow to the Director of Project Management.
- Upon approval, the applicable Record Management staff destroy the content (or perform the transfer) and create a disposition report and file it along with the disposition certificate.
Remember, this is just a sample I’ve put together. Use it as a guideline, not as an exhaustive list. Each plan will differ based on your organization’s specific needs.
What Can go in a Lifecycle?
A lifecycle can vary from agency to agency, document to document, department to department. So, the answer to that question can be answered with another question – “How many things can be done to/with electronic content?” (SO MUCH!)
Here are some high-level areas to consider. Any one of these, in some way, could be a part of a record lifecycle, several times:
- Ingestion (scanning/imaging)
- Metadata (manual/automatic addition/changing of metadata at different points in the lifecycle)
- Queue processing
- Security changes (addition of markings or downgrade of markings)
- Versioning (up or down)
- User access (granting or retracting)
- Copy/move (from one library/folder to another)
- System integration activities
- Declaring a document as an official agency record
- Cut-off or event declaration
- Reporting (automatic or manual reports)
- Audit log updates/reports
- Legal hold/freezes
You’ll want to think through all of these and make sure you fully understand what your data needs are, and anticipate any changes in the future. It won’t hurt to check more checkboxes here, even if you don’t have a need for some of these stages.
Document Everything (Even Though it’s a Lot of Work)
Creating a detailed lifecycle for your record can be a LOT of work. So, the reasons for creating these may need to be thoroughly justified and prioritized. You may need to start with only vital records and chances are, there is already a lifecycle in place for them it’s just a matter of documenting them so they can be recreated in the electronic world.
Why document them? Well maybe it’s best to sort out the requirements on the lifecycles and their processes in order to configure them correctly and you can’t do that without documenting what the lifecycle for the record is.
But why should we go through all of this work for record lifecycles?
Well, the answers can vary… maybe it is because in order to fully comply with regulatory, fiscal, audit, NARA and retention demands you need to sort out the requirements and lifecycle around your vital records so you can be sure you are meeting all of these demands!
Once you do this, configuring your ECM to stay compliant is much more straightforward. For instance, even if you just had a diagram (like image 4 above) and a set of requirements for each of your vital records lifecycles, you could implement things electronically much faster!
I say “vital records” because to me, that is a logical place to start. But you can do this for all/any of your content based on your own criteria.
An information governance plan can greatly help you with this!
As I stated in part 2 of this blog, it really helps to create an Information Governance Plan. This plan will lay out all of your regulatory, fiscal, audit, NARA and retention demands (and much much more).
Going through all the steps of assessment, planning, execution, documentation, and fulfilling the requirements of NARA 2019/2022, is quite the task.
In my three-part blog series, I hope I’ve helped you understand the complexity and importance of each step. And I hope you’ve seen that there is a system to achieve this. It’s not a copy-paste system, but it’s a solid set of guidelines to get you to full compliance.
There are tools to help along the way. Tools like Alfresco and Ephesoft.
If you haven’t seen my 2 previous posts from this series, here are the links:
Thanks for reading, I hope this can help! Please let me know if you have any questions.