This paper begins by noting that the rationale for records management within an enterprise has recently shifted to emphasize risk management. That is, many now believe enterprises must adopt good records management as part of their essential infrastructure for the basic reason that keeping good records protects the enterprise from harmful damage and ensures regulatory compliance. The paper argues that risk management by itself is an inadequate rationale for enterprise-wide records management because it is essentially a defensive strategy.

The paper develops the view that electronic records management (ERM) within the context of enterprise content management (ECM) fundamentally alters this state of affairs. With ERM fully implemented, an enterprise can begin to realize positive benefits and real cost savings to the information management of essential business functions within the enterprise. The paper presents several examples illustrating that ERM has produced positive benefits to non-records management business functions within the context of ECM. It concludes with the argument that records management will not take its rightful place in enterprise information management until ERM is fully integrated within ECM.

Advocates of good records management have long believed that records management is an essential element of enterprise infrastructure on a par with financial management and human resources management. Records ensure that an enterprise can:

Conduct its business in an orderly, efficient, and accountable manner

Deliver services consistently and equitably

Document its policies, decisions, and outcomes to stakeholders and regulators

Meet its legislative and regulatory requirements, including audits

Protect itself in litigation

Function in a financially and ethically accountable manner

Protect corporate interests as well as the rights of employees, clients, and other stakeholders

Provide continuity of operations in an emergency or disaster

Maintain its corporate and institutional memory

In recent years, the passage of the Sarbanes-Oxley Act of 2002 and the ensuing regulations from the Securities and Exchange Commission have placed emphasis on the risk proposed to private enterprises from inadequate internal controls and the records management to support the internal controls. One frequently encounters statements such as the following:

Records and information are at the core of every transaction any organization undertakes. Therefore any inadequacy in those records and information – including noncompliance with regulations such as the Sarbanes-Oxley Act and international privacy laws – can threaten the organization’s ability to conduct business.

 

The high profile Cobell litigation against the Department of Interior’s Bureau of Indian Affairs, the Federal Bureau of Investigation’s debacle over the records in the Timothy McVeigh case, and the deficiencies in government records exposed by the failure of the Enron Corporation and other large companies have created heightened sensitivity in government agencies to the liabilities inherent in poor records management. More enterprises focus today on the often extremely high cost of discovery during litigation. Both the accounting and ECM software industries seem to dwell on risk management and regulatory compliance as primary motivators for investing in good records management.

In consequence of these developments, the rationale for records management appears to have shifted to emphasize only the following elements.

Document policies, decisions, and outcomes to stakeholders and regulators

Meet legislative and regulatory requirements, including audits

Protect enterprise in litigation

Function in a financially and ethically accountable manner

Protect enterprise interests as well as the rights of employees, clients, and other stakeholders

Provide continuity of operations in an emergency or disaster

Maintain documented institutional memory in case of investigation or litigation

Moreover, in large, complex enterprises dependent on paper-based records systems the statements about the positive benefits of good records management increasingly ring hollow. The National Archives and Records Administration asserts, for example, that records management "contributes to the smooth operation of your agency’s programs by making the information needed for decision making and operations readily available." This statement is difficult to credit where making information "readily available" may require retrieving and examining hundreds, thousands, perhaps even tens of thousands, of paper records.

Those who emphasize heavily the risk management rationale for records management overlook the downsides to their point of view. A risk management rationale, although salutary in its own right, represents a defensive strategy for the enterprise. Its appeal to the enterprise is in direct proportion to the degree to which enterprise decision makers believe the enterprise threatened by internal or external dangers. Risk management wards off danger and nothing more. In and of itself, a risk management rationale does nothing to further the positive pursuit of the enterprise’s goals and mission. In other words, risk management alone does not present enterprise decision makers with an offensive strategy.

It is a familiar observation that management’s interest in records management is in direct proportion to how recent was the last enterprise records management disaster. If the disaster is relatively ancient history or has never occurred within the memory of veteran employees, doomsday warnings of the dangers of poor records management fall on deaf ears. One can well imagine a senior executive, upon hearing that he or she could go to jail for not putting resources behind good records management, responding as follows: "My job is not to stay out of jail; I trust our lawyers will keep me out of jail. My job is to make this enterprise move forward and prosper in the better fulfillment of its goals and mission. Unless you can tell me how records management will enable me to do that, I will not allocate more resources to records management."

Similarly, government records managers frequently argue that upper management must support good records management because it is the law. One can equally well imagine a Chief Information Officer responding: "Don’t tell me records management is the law. Laws drive every resource allocation decision I make. My problem is not to observe a single law on records. My problem is to observe dozens of laws with scarce resources to do so. This condition forces me to set priorities in discharging my legal responsibilities so as to best support the mission fulfillment of this agency. Unless you can tell me why records management should have high priority for mission fulfillment, I will not allocate more sources to records management."

The answer to these arguments is to demonstrate the positive benefits of records management for better achieving enterprise goals and mission. The advent of electronic records management systems (ERMS), and particularly ERMS within the context of enterprise content management (ECM) or enterprise information management (EIM) make it possible to make these arguments in ways not previously encountered.

Several brief case studies will demonstrate how records management yields positive benefits to information management functions to the benefit of the larger enterprise. The case studies are drawn from government agencies because that is the context with which the author is most familiar but they are easily generalizable to non-government settings.

Case 1: The Defense Advanced Research Projects Agency. The Defense Advanced Research Projects Agency (DARPA) manages and directs selected basic and applied research and development projects for U.S. Department of Defense, and pursues research and technology where risk and payoff are both very high and where success may provide dramatic advances for traditional military roles and missions. In its Controllers Office, DARPA implemented an ERMS with reference to a particular procurement document, the DARPA Order. This document contains a summary statement of work for a research project and also the signatures of DARPA officials required to authorize the order. Once a proposed DARPA Order has completed the signature chain in the workflow process, the order becomes the document against which the agency cuts a check for disbursement.

DARPA also has an Executive Information System (EIS) tailored for the agency’s senior managers. The EIS keeps senior management informed on a current basis as to agency progress in meeting its annual performance goals EIS draws information from many sources within DARPA. A key indicator of progress on performance goals is research funds disburse, the data for which are drawn from the ERMS records repository. Access to the records repository is transparent to those using the EIS.

Hence, in DARPA in addition to performing records management functions, the ERMS supports (and saves money for) the agency’s executive information functions.

Case 2: The Nuclear Regulatory Commission’s ADAMS. The Nuclear Regulatory Commission (NRC) implemented in 2000 the Agency-wide Document Access and Management System (ADAMS). ADAMS is an enterprise-wide integrated electronic document management system and ERMS (EDMS/ERMS). Under ADAMS, all correspondence and other paper documents coming into the agency are immediately scanned into electronic format and the paper is destroyed after 60 days. A Document Processing Center (DPC) profiles incoming documents and distributes them electronically. As for new documents NRC staff create, the documents are added to ADAMS by staff with a minimal profile (title, sensitivity, and availability) and profiling is completed by the DPC.

All NRC records that may be made public are replicated to the ADAMS Public Library and the NRC public website. The bulk of web content management in NRC occurs automatically by population from ADAMS.

ADAMS has also streamlined and made more efficient NRC’s adjudicatory and rulemaking processes, making document more readily accessible to staff and the public.

Hence, in NRC in addition to performing records management functions, ADAMS supports (and saves money for) the following additional enterprise functions:

Public information services.

Web content management.

Adjudicatory and regulatory processes.

Case 3: NRC’s ADAMS plus PKI. By law and regulation, NRC requires periodic reporting on the control and accounting of special nuclear material at fixed sites and for documenting the transfer of special nuclear material. NRC has added Public Key Infrastructure (PKI) electronic signature capability to ADAMS. Nuclear facilities can now report securely via electronic mail instead of on paper. Reports are received directly into ADAMS, examined by NRC for accuracy and completeness, and for business proprietary and security classified materials; and when the latter materials are removed, the reports are replicated to the ADAMS Public Library and the NRC public website.

Hence, ADAMS plus electronic signature capability performs records management functions and supports (and saves money for) the following additional enterprise functions:

Reducing paperwork burden on the public

Improving customer relations because nuclear facilities save time and expense by reporting electronically.

Streamlining the feedback loop between NRC and nuclear facilities.

Enhancing the public information function with speedier reporting.

The case studies could be multiplied with other examples. What has occurred in these enterprises is not simply a serendipitous by-product of ERMS. Rather, the enterprises cited above have recognized that their ERMS provides the enterprise with instant access to current and authoritative institutional memory. They have recognized this to be a positive business asset that can be leveraged to support and enhance many other business functions within the enterprise.

In order to cause an ERMS to function properly within an enterprise, records managers and information technology staff must work together to integrate the ERMS with other information content applications. An ERMS accepts and manages the records it imports from other sources within the enterprise. In the most common case, the ERMS integrates with an EDMS. ERMS also integrates with web content management and portal management as well as many other content management functions such as:

Case file management

Electronic publishing

Financial management

Computer assisted design/computer assisted manufacturing (CAD/CAM)

Forms management

And many others

All of the above statements are another way of saying that an ERMS must be an integral component of Enterprise Architecture.

Over-reliance on a risk management rationale to justify records management is one danger that records managers run as they transition records to the information systems environment. Another danger is records managers’ excessive preoccupation with capturing records into records management systems – traditionally the hardest practical hurdle faced – and insufficient attention to the positive uses of records once captured. Is part of the enterprise starting a new program or facing a new problem? Then records managers must attune themselves to ways in which the electronic records repository can support the new program or help solve the new problem.

With an ERMS operating as part of the ECM, the enterprise’s electronic records repository holds information resources that by their very nature have the characteristics of:

Authenticity

Reliability

Integrity

Usability

Information in the e-records repository is therefore known to be accurate and trustworthy and to be the latest official version. Because today’s ERMSs capture records the moment they are created, the information is also current.

As the enterprise, whether governmental or private sector, comes to understand the quality and value of the information held in the ERMS within the ECM, the e-records repository will become a primary place enterprise planners look for information to support lines of business and to solve new problems. The financial savings to the enterprise and costs foregone through re-purposing information already captured and accessible will be readily demonstrable to Chief Information Officers. Emphasizing the positive benefits of ERMS within ECM will bring records management to its proper place in serving enterprise goals and mission.