BEST PRACTICE STRATEGIES NARA/OMB MANAGING GOVERNMENT RECORDS MANAGEMENT DIRECTIVE Mark Mandel, CRM, CIP, ERMm, BPMm, CDIA+ Records Management Solution Architect OpenText Public Sector Solutions 2 M-12-18 Deadlines NARA/OMB M-12-18, the Managing Government Records Directive, has the following key deadlines for federal agencies: • 2016 – all Email must be managed electronically in a records management system – no more "print and file" • 2019 – all permanent records must be delivered to NARA in electronic format only 3 NARA Automation Plan The NARA Automation Plan states, “Although the Directive uses the term “records management” and this report inherits that language, NARA recognizes that well-conceived automation can improve the management of all government information for a wide range of information governance purposes. These include information security, privacy, eDiscovery, Freedom of Information Act (FOIA), and proactive disclosure of government information as part of open government and open data programs. While records management is stressed here because of this report’s origin in the Directive, the greatest efficiencies and improvements in effectiveness will be achieved if agencies consider the automation of their information management in a holistic way.” 4 The Solution: Agency ECM Strategic Plan • Implement an Agency-Wide Enterprise Content and • • • • • • Records Management System Manage All Records Policy with One Integrated Electronic Records Management System Single Unified Enterprise Repository Disaster Recovery Infrastructure Cloud or Virtual Services Integration with Business Applications, E-mail, Office Applications Apply Governance to All Records – Content Lifecycle Management 5 NARA/OMB Managing Government Records Directive “The current federal records management system is based on an outdated approach involving paper and filing cabinets. Today’s action will move the process into the digital age so the American public can have access to clear and accurate information about the decisions and actions of the Federal Government.” President Obama Benefits: • Reduction in Cost Related to Storing and Filing Paper • Reduction in Cycle Times and Cost for Transactions • Increased Access to Information • Complete Audit Trail of Transactions • Compliance with FOIA, Privacy Act and eDiscovery • Unified Repository Reduces Information Silos • Supports PortfolioStat Model 6 Concept of Operations – Best Practices • Records Management is Transparent to the End User • ECM – with embedded RM - is Integrated with Existing Applications and Email • User Interface Best Suited to the End User • • • • • • SharePoint Email ECM ERP BPM Business Application • E-mail Journaling with Auto Classification • E-mail Treated as Another Document Type • Document Management with Versioning Federated Search SharePoint FOIA / Privacy Act Copyright © 1995-2007 Open Text Inc. All rights reserved. Auto Classification E-Discovery Slide 21 E-mail ERP BPM 5015.2 Record Centers Mobile Fax/Copy Social Enterprise Storage and Cloud Services Disaster Recovery Infrastructure 7 8 IRS Email Under Scrutiny 9 VA Cancels Email Cloud Contract "The OIG wanted new contract language inserted into all VA cloud contracts designed to facilitate access and visibility into the system, preserve emails and increase the security rating under the Federal Information Security Management Act. There was pending guidance from NARA on records retention that would affect the disposition of email storage. It was determined that the necessary changes were out of scope with the … contract, and it was terminated." 10 There Are Many Approaches to Managing Email • Different approaches serve the needs of different stakeholders in different ways • It is important to understand the different approaches and their strengths vs. weaknesses • A short-sighted approach that does not meet the needs of all stakeholders will likely need to replaced later on 11 Email Requirements Competing Priorities; Multiple Stakeholders Requirement Stakeholder Optimize production Email system IT Consolidate multiple Email systems IT Lower operational and storage costs IT Provide oversight for compliance Legal FOIA Legal eDiscovery Legal Email stored with business records as part of the audit trail of transactions Business, Audit, RM Capstone RM, Legal, Archivists 12 Email in the Cloud Three levels of maturity • Level 1 – Email in the Cloud, no Records Management Requirement Stakeholder Meets Requirement Optimize production Email system IT Yes Consolidate multiple Email systems IT Yes Lower operational and storage costs IT Yes Provide oversight for compliance Legal No FOIA Legal No eDiscovery Legal No Email stored with business records as part of the audit trail of transactions Business, Audit, RM No Capstone RM, Legal, Archivists No 13 Email in the Cloud Three levels of maturity • Level 2 – Email in the Cloud, with Email Archive and Records Management, but not integrated with ECM Requirement Stakeholder Meets Requirement Optimize production Email system IT Yes Consolidate multiple Email systems IT Yes Lower operational and storage costs IT Yes Provide oversight for compliance Legal Yes FOIA Legal Yes eDiscovery Legal Yes Email stored with business records as part of the audit trail of transactions Business, Audit, RM No Capstone RM, Legal, Archivists Yes 14 Email in the Cloud Three levels of maturity • Level 3 – Email in the Cloud, with integrated ECM Requirement Stakeholder Meets Requirement Optimize production Email system IT Yes Consolidate multiple Email systems IT Yes Lower operational and storage costs IT Yes Provide oversight for compliance Legal Yes FOIA Legal Yes eDiscovery Legal Yes Email stored with business records as part of the audit trail of transactions Business, Audit, RM Yes Capstone RM, Legal, Archivists Yes Level 3 Email Pyramid "Capstone" Role Based Classification Permanent Enterprise Connect Business Records Auto Classification Transitory Records Process Automation ECM Repository Auto Classification Big Bucket Temporary Records And Transitory 16 Key Issues to Address in Your Email and ECM Solution • Classification strategies to minimize user involvement in declaring records • Managing growth of content to reduce storage costs • DoD 5015.02-STD 17 Folder Classification Inheritance When adding a document to a folder that has classification inheritance enabled, all items in that folder inherit the same classification. Add Document 18 Process Driven Classification Documents can be classified as part of a business process 19 Role-based Classification Documents can be classified according to the group to which the user belongs 20 Auto-Classification Automatically classify high volume, low-touch records such as E-mail and file system content. Transparent Step-by-step tuning guide and feedback Defensible Built-in statistical sampling and quality assurance 21 5015.02-STD Demystified • Baseline • Chapter 2, Mandatory Requirements • Chapter 5, Transfers • Chapter 6, Non-Mandatory Features • Classified - Chapter 3 is Management of Classified Records • FOIA/PA - Chapter 4 is Managing Records for the Privacy Act and the Freedom of Information Act The Joint Interoperability Test Command (JITC) provides a list of certified products. DoD organizations may only purchase records management products that are on this list 22 5015.02-STD This should be a requirement in your enterprise architecture. Why? • It sets metadata standards for all records • It defines the best methodology for destruction of electronic records at the end of their lifecycle • It provides a standard approach for transfer of records from one agency to another, and for transfer from an agency to NARA • It defines requirements for classified records • It defines requirements for FOIA and Privacy Act solutions This approach promotes consistency across all agencies and NARA 23 JITC RMA Register List of Certified Products under 5015.02-STD 24 My agency is being tasked with moving to digital recordkeeping, but it is an unfunded mandate. There is no budget for Records Management modernization. Where do I find the money? • Even in these tough economic times, agencies are spending money in their IT budget • Their top priorities include Records Management, but they don't call it that • The key is to align your plans with your agency top IT priorities 25 What are the Priorities for Federal Agency IT Spending? Key Requirements and Market Drivers U.S. Federal Government • • • • • Cloud First Storage Costs Cyber Security Compliance (eDiscovery, FOIA, HIPAA, 5015.2) Audit Readiness Managing Government Records Directive A foundational element for meeting agency IT priorities 26 Cloud First Steven Van Roekel, U.S. Chief Information Officer, Office of Management and Budget "With information technology at the core of nearly everything the Federal Government does, we must use IT as a strategic asset and drive cost savings to pay for new and emerging technologies that can fundamentally improve the way government does business and delivers services to the American people… We recently issued new guidance to help agencies manage their investment in IT and drive low-value spending into more innovative efforts. The initiative—known as PortfolioStat—focuses on improving agency portfolio management to better deliver what we purchase and build." • Cloud First – Shared Services Strategy • Data Center Consolidation 27 Storage Costs The Deep Web The Public Web Only 4% of Web content is available via search engines like Google 7.9 Zettabytes Source: The Deep Web: Semantic Search Takes Innovation to New Depths The Deep Web ~96% of information is inside the firewall 80% of data is unstructured Information is trapped in application silos Content is doubling every 90 days 28 Cyber Security Federal Agencies Hacked • • • • Red October Anonymous WikiLeaks AntiSec 29 Compliance Governance, Compliance and Risk Canadian Electronic Evidence Act ATIP SEC 17a-4 HIPAA Electronic Ledger Basel II Capital Accord Storage Law 11 MEDIS-DC DoD FOIA/Privacy Act AIPA ISO/PRFTR15081 GDPdU & GoBS & DOMEA FDA 21 CFR Part 11 Sarbanes-Oxley Act NF Z 42-013 Federal Rules of Civil Procedure Financial Services Authority MoReq 2010 VERS BSI PD5000 30 Audit Readiness DOD Financial Improvement and Audit Readiness (FIAR) FIAR Plan priorities were established in August 2009 and require the Components to first focus on improving processes, controls, and systems supporting information most often used to manage the Department. This is the starting point for achieving the goal of obtaining auditable financial statements. To achieve these objectives, the FIAR priorities are: • Budgetary information • Mission critical asset information The program objective is full audit readiness by 2016. 31 Cost Savings Examples • In 2010, Federal agencies spent nearly a half billion taxpayer dollars on processing FOIA requests. Source: FOIA.gov. • PortfolioStat could save or help the government avoid spending $2.5 billion over the next three years. In the first year alone, agencies saved or avoided spending $300 million. • Cobell v. Salazar is a class-action lawsuit brought by Native American representatives against two departments of the United States government. The case was settled for $3.4 billion in 2009, with $1.4 billion going to the plaintiffs and $2 billion allocated to repurchase land and return it to communal tribal ownership. • The Government Accountability Office said in January 2013 that it could not complete an audit of the federal government, pointing to serious problems with the Department of Defense. 32 BPM Example - Current Process Costs 33 Future Process Costs Savings of $38,848.60 per transaction 34 A Proposed Blueprint Basis For an Agency 5 Year Strategic Plan 1. Perform a Complete Records Inventory • Paper, Film, Digital • Content Sources, Storage Locations, Systems of Record • Develop volume counts, document all issues 2. Constitute a Steering Committee • Include top officials, including CFO, Legal, IT, Records Officers, FOIA, Business Units • Sign Off on Records Schedule, Strategic Plan, Funding • Meet Quarterly 3. Update your Records Retention Schedule • Big Bucket, No More than 20 Record Series, 10 or less is optimal 35 A Proposed Blueprint Basis For an Agency 5 Year Strategic Plan 4. Create Collaboration Site for All Things Records • • • 5. Conduct Agency Wide Taxonomy Study • 6. Post events, policies, schedules, links to content, online courses, FAQs, Progress Against Strategic Plan Records Officer User Group to Meet Quarterly – include related roles such as FOIA, Privacy, Security, Legal Ongoing Training on Policies, Procedures, and Technology Develop Standardized Search and Index Criteria Move File Shares to Document Management System, Place Under Version Control – Eliminate PST Files 36 A Proposed Blueprint Basis For an Agency 5 Year Strategic Plan 7. Document Your ECM/RM Enterprise Architecture • Enterprise Content/Records Repository, DoD 5015.2 STD • Enterprise Storage Architecture • Content Capture and Ingestion • E-Fax, E-Signature, E-Filing • Records Policy – Content Lifecycle Management • E-Discovery, FOIA, Full Text and Enterprise Search • E-Mail Classification, E-Mail Archive • IM, Social Media, Mobile • Disaster Recovery Infrastructure • Integrate with Existing Applications (ERP, HR, Case Management) • Integrate the ECM/RM EA with the Agency EA 37 A Proposed Blueprint Basis For an Agency 5 Year Strategic Plan 8. Digitize Paper Records • • • • • Scan Paper That is Frequently Accessed Scan on Demand Digital Copiers Central Scan Centers Outsource 38 A Proposed Blueprint Basis For an Agency 5 Year Strategic Plan 9. Implement Agency Wide Document/Records Management System 9. Establish Central Repository 10. Basic Feature Set 11. Establish RM Policy 10. Integrate with Existing Systems • • • • E-Mail ERP Case Management Migrate Data From Other ECM Systems 39 A Proposed Blueprint Basis For an Agency 5 Year Strategic Plan Add Advanced Features 11. • • • 12. 13. Workflow/BPM E-Discovery Auto Classification Ensure Funding for Ongoing Operations, Backfile Scanning Move Paper Based Processes to Constituent Self Service Using Electronic Forms 40 Strategic Plan Timeline 41 Key Take-Aways Get started with your ROUG and Steering Committee Involve the SAO Start your inventory if you have not already Start your taxonomy study if you not have already Modernize your records schedule Get funding by aligning your ECM solution requirements with agency IT priorities – don't call it Records Management! PortfolioStat E-mail Management Cloud First Security Audit Lower Operations Cost Make your enterprise architecture drive deployment decisions MARK MANDEL mmandel@uspss.opentext.com 703-347-5944