Business Matters: Where RM Should Report to Ensure Effective Electronic Records Management

Unlike any other aspect of business, records management – the act of planning and managing every piece of an organization’s captured information – is an element of every business process. From the articles of incorporation to the penciled notes of a janitor on a work ticket and to employees’ work – and personal – e-mail, that information must be managed from its inception to its final disposition.

Carol E.B. Choksy, Ph.D., CRM, PMP

Therefore, where records management reports within an organization can make the difference between the organization being effective and it collapsing like Arthur Andersen did as a result of its information mishandling connected to the Enron collapse. Especially as the volume of electronically stored information continues to grow exponentially, it is crucial for organizations to ensure that records management is reporting at the appropriate level and to the appropriate area.

Where that appropriate place is will vary for every organization. The hypothesis of a study funded by an NHPRC Electronic Records Research Fellows Grant in 2005-2006 was that the key to records management’s effectiveness is for it to report to the senior executive with the greatest amount of leverage across the organization, whether that person is the executive over finance, legal, compliance, information technology, or another function.

Previous Studies

Because there is no historical literature on this subject, the hypothesis had not been tested. Previous work in this area often used “instant” surveys that were created with online survey tools and blasted by e-mail to members of records-related associations and consumers of records management technology, or it focused primarily on the records manager’s portfolio, or span of control.

Because these surveys were not scientific – for example, they often did not have filtering tools to prevent multiple participants from a variety of levels within a single company from taking the survey or a single participant from completing it more than once – their validity is questionable.

Although the 2002 study that resulted in the publication Records and Information Management: A Benchmarking Study of Large U.S. Industrial Companies did use standard social science methodology, its limitation was its focus on records management’s role in managing the latter half of the information life cycle – which probably reflects the status of records managers at that time. Its conclusions indicated that the primary duties of records managers then were to create retention schedules and manage offsite storage for paper records. Not addressing governance, policies, and procedures except in connection with retention schedules was a lost opportunity.

Project Purpose

The purpose of the NHPRC-funded project, which used standard social science methods, was to learn where some of the largest U.S. companies place records management organizationally, the span of control of records management, and what those companies are doing about managing records. Where records management is located and its span of control probably provide the best measures of whether effective methods for managing electronic records have been implemented by a company.

The NHPRC study differs from other studies of electronic records and records manager’s duties in that it explored the broad duties as well as the context for managing electronic documents successfully within large corporations.

Project Initiation

More than 300 individuals in charge of the records management programs for Fortune 500, Forbes 300, and
Transnational 100 companies in the United States were invited to participate, initially by commenting on the proposed survey. Of those, 33 responded that they would like to comment on the survey, and five later submitted comments.

Project Results

Once the survey was finalized, all 339 potential participants were contacted again and asked to take the survey anonymously. Of those, 48 decided to participate, resulting in the following findings.

Reporting Relationships

Nearly half (47%) the participants in this study report ultimately to the legal department, and only 13 percent report to administrative services. This is the reverse of what was reported in Saffady’s 2002 study, where most participants (34%) reported to administrative services (or business services) and a smaller number (24%) reported to legal.

Although these results could be due to the different companies and participants that were surveyed, it is also possible that corporations are recognizing that records management is as much a legal issue as it is a business process issue and, therefore, are giving it a different focus.

It is also possible, as some anecdotal evidence indicates, that as boards of directors become more aware of records management, they give the assignment to their chief legal counsel, who may also be the corporate secretary.

The next highest number of participants (13%) report equally to administration and information technology, while 9 percent report either to human resources or compliance, and 2 percent report to engineering and to marketing and communications. (In Saffady’s study, 15 percent reported to information technology and 8 percent to the corporate secretary.)

Social Networking

The NHPRC study explored the participants’ advisory roles within their organizations as reflected in their informal networks. It shows their networks to be robust, cutting across their organizations’ activities.

Participants were asked to list those outside the chain-of-command from whom they ask advice and by whom they are asked for advice. The results show there is some parity within these informal relationships in that the participants are both giving and receiving advice.

The study shows that participants are sought out for advice most often by legal, IT, and line-of-business managers, suggesting that while they cannot manage every piece of information themselves, they are relied upon to provide governance, policy, and procedural advice to every part of the organization.

A cordial relationship with IT, where solutions have been sought in the past, and with line-of-business managers, who have had the budgets for solutions, is a positive step toward creating end-to-end life cycle solutions. Having a good relationship with legal is also important because that is where many of the present problems with managing information are.

Establishing a dialogue with the information technology department about electronic records is, prima facie, one of the required first steps to ensuring electronic records are managed appropriately.With an ongoing discussion about electronic records with IT, a robust social network, a role as advisor for many different categories of records, and duties to write policies and procedures for most of the life cycle, the companies these participants are working for appear well-placed to manage electronic records well going forward.

Span of Control

The purpose of Figure 2 is to represent the portfolio of participants’duties in relation to different phases of the information life cycle. This is important because, while records managers have been stereotyped as being involved in managing only the latter half of the information life cycle, the problems of electronic records begin at the creation stage. Those problems stem from a lack of policies and procedures and the use of technologies that are designed to create, distribute, and copy information but not to appropriately organize and store it to facilitate its recall. For an organization to get a handle on its electronic records, it must have a governance structure that begins with policies and procedures.

To put this in context, 20 years ago secretaries were responsible for implementing document control (the creation phase of records), and they had training, procedures, and style manuals to ensure that things were done appropriately. This meant that records management was built into the business process. With the elimination of these positions and the introduction of word processing and e-mail, employees became responsible for creating their own memoranda and correspondence – but the training and manuals were gone, and records management was no longer a part of the business process.

To rectify this, organizations must put into place the appropriate governance, which means records managers must have the position and influence to develop and implement the records management policies, procedures, and training.

Nearly all participants report that they are responsible for policies and procedures for destruction, long-term preservation, and storage of hard copy documents. More than three-quarters report that they also create policies and procedures for document control and management.

Also interesting is how much technology implementation advice is given on long-term preservation (75%), destruction (75%), electronic storage (50%), and document control/management (50%). This demonstrates that the participants are making headway in having significant input into how all documents are managed for the complete life cycle, paper, as well as electronic.

Participants were also asked about their responsibilities for various categories of information. The most significant set of duties for every record category is advisor. More than half the participants have responsibilities to advise on every record category listed. More than half the participants have responsibilities for creating policies concerning hardcopy records, databases, reports, desktop documents (like Word), images, instant messages, and e-mail.

Measures of Success

Overall, the respondents paint a positive picture in the sense that recent issues, such as Sarbanes-Oxley compliance and high-cost litigation involving e-mail, have spurred upper-level executives toward a records management strategy to address the complete life cycle of electronic records. Participants’ measures of succes can be seen in Table 1, p. 61.

Only 4 percent of respondents did not have a positive report of progress. They indicate that the primary problem is IT not wanting to give up control to records management. A variety of other challenges fall into the following categories:

• Change management issues like business process change; consensus about what is needed; culture change; and lack of management support
• Cost issues like budget and limited resources
• Records management education issues like the difference between what is kept and what is ephemeral; the difference between time- and activity-based destruction; getting an accurate inventory; lack of formalized policies and procedures; inconsistent terminology; a lack of understanding that retention is independent of media type
• Technology issues like growth by acquisition leading to a heterogeneous computing environment; keeping the solutions simple; a mindset that electronic storage is inexpensive; rework because electronic systems were implemented without regard to records management issues; lack of availability of an enterprise records management solution; and SAP

Study Conclusion

As records managers appear to have begun to report higher in the corporate hierarchy, their role in the management of electronic records has changed dramatically. Legal and compliance appear to be the best fit for records management because those departments cross corporate boundaries in the same way records management does. However, some records managers in this study reporting to the chief financial officer or to IT report a very high level of cooperation and progress in managing the entire life cycle of all corporate information.

Where should records management report? Clearly, it should report where it will have high leverage within the organization.

Editor’s Note: This article represents only a portion of the findings from an NHPRC-funded study conducted by the author. For the full results, see www.arma.org/pdf/journal/rmreporting.pdf.

Carol Choksy, Ph.D., CRM, PMP, can be contacted at cchoksy@indiana.edu.

 From March - April 2008