A few days ago, an esteemed colleague asked me for my opinion on a records policy that she had drafted and that had received some criticism from the professional community. This post is part of my answer.

Before starting to draft we must place ourselves in the context of the organization and in the purpose of the policy. In principle, a policy is a document that contains a statement of intentions by the top management of an organization with respect to a specific topic; but within this same definition there are at least two different interpretations:

1) A policy in the context of the implementation of management systems standards (MSS), is a short document that establishes the guidelines of the organization regarding an aspect, in this case records management, that is intended for all the people who work in the organization, since that is what should make the policy possible. It is the type of document that must be written when it comes to implementing the UNE ISO 30301: 2011 Standard on Management Systems for Documents . It is written in a language that is understandable to all and in pre-intranet times it was hung on the walls of the offices so that everyone could keep it in mind. That being the case, this type of policy is best not to go beyond a single page. When several management system standards are implemented within the same organization, the ideal is that the management system is integrated, which means that in many cases it is also an integrated management policy. That is, a document that covers different aspects of management, including records management. Being a short document does not mean that it is easy to write, since it must express the intention of the top management with clear and precise concepts. Of course, the management system is not based only on the policy document, but there are other levels of documents in which it is developed, defined and detailed, each of them with a different audience, according to the scope and purpose of the same.

2) A policy conceived as a technical document that includes the principles and rules for the creation, capture and management of records and that serves as the basis for the implementation of operating schemes, document management models or regulatory developments. These are detailed documents, with technical components whose comprehension is not available to anyone, and which are written by specialists for specialists. They are reference documents in change processes, which detail the decisions made regarding different technical aspects and that are necessary to guide an implementation process. This type of policy is what seems to have been imposed in different countries as a mandatory element for public administrations. In Spain, the Interoperability Technical Standard (NTI) of Electronic Document Management Policy or in Colombia Decree 1080 of 2015 "By means of which the Single Decree of the Culture Sector is issued" have opted for the term "records management policy" for this type of technical content. With this approach, great technical documents have been written, which in many cases exceed 150 pages and where all the details that serve to implement the policy are included in the main text or in its annexes. After having started reading many of them, I think it can be said that it only makes sense when you are directly involved in the process for which they were conceived, and that these are documents of reference rather than declaration of principles. As these are difficult documents in the two cases mentioned, in which the existence of the policy is mandatory, help has been provided in the form of templates or guides, which sometimes produce the opposite effect to the desired, as policies are drafted by “copy pasting”. I can affirm with knowledge that these kind of policies are useless.

When someone reads a records policy to approve and/or criticize it, they have already placed themselves in one of the two conceptions described, therefore, they will not understand a "policy" made with the other vision. The big peril is that those responsible for drafting a policy wanting to make a "mix" of the two visions, staying in "no man's land" and being criticized by all.

But, what is the solution when the organization is in a context where a technical policy is required, but at the same time the organization wants to implement a standard such as ISO 30301? For me it is a question of denomination and, therefore, should not waste too much time in discussions about what is or is not a policy. The two levels are necessary and meet completely different objectives. In some of my projects where these conditions are met we have called the technical document in another way, establishing within it that it acts as an electronic records management policy in compliance with current legislation.

Digital transformation requires records analysis and appraisal to be able to determine the information that must be created and fixed to document theprocesses and activities of the organization and, at the same time, define the requirements to manage it.

Laying the foundations on how to do this analysis and carry it out has become a major activity of my consulting work in the recent years. Taking this experience as a starting point I would like to share some  learned lessons in this post.

It seems that, the larger and more technologically advanced organizations are, there is an innate tendency to "disorganize." The division into areas or organizational units that well-meaningly seek to perform better and automate their tasks leads to a lack of overall vision. When records analysis begins, including the several areas and processes, contradictions and different ways of doing things jump very quickly into the light. It is relatively frequent that in any implementation of any computer tool records requirements are defined without considering any kind of general guideline, which results in different solutions to solve equal situations. Hence the title of this post as an old joke about a collective sex session: "order, order" is the first thing is needed.

This is reflected by understanding how the organization works and, above all, seeking synergies with other sorts of analysis that are surely being carried out inside the organization. Although sometimes in a project’s environment, it may seem that this is complicating it, but finally results in a benefit for the organization, that is what records management seeks. Examples of other general analyses that I have come across lately are: the definition of processes in an ISO 9001 implementation environment, the definition of the procedures for the "Administrative Information System (SIA)" of the Spanish public administrations or the conceptualization of a Portal for clients and users. But perhaps the most important thing is to establish clear guidelines to apply records requirements when certain process is automated or a techonological tool is implemented.  An intelligent comment I recently heard said that if the guidelines were made they would act as a riverbed, water would always go through the same place simply because it is easier than trying to change the course.

This also means that records analysis must be tailored for each organization. The archivistical tradition for this type of analysis is a very solid base, but it cannot be imposed at the cost of being isolated. We must consider that the analysis that has been done in archives has traditionally been one of self-consumption and has served to organize paper fonds once an activity has been completed. When the organizations go towards the fully digital environment, this way may not serve us.

I have taken part on many discussions on the definition of processes (procedures) and their relationship with records series. For me, and for many others in this field, the "one-to-one" relationship between process (procedure) and records series should be natural, but for that we surely need not to strictly follow the series defined for paper archives.

Likewise, I think there is a lot of potential in the classification schemes used in records management. As ISO 15489: 2016 states " classification schemes primarily exist to link the records to the context of their creation", and therefore represent the functions, activities and processes of the same. Any need in the organization to classify areas, functions and processes can use the same tool. That is why when talking about the "record classification scheme" an alert must be produced. The functions’ classification table or simply the organization’s classification is much better.

Another important lesson is that records management instruments or controls (metadata schemes, access and permission rules, disposition authorities ...) are not the goal of records management, but the means we use. Usually I repeat as a mantra "If the instrument is not useful it will have to be changed".

And in any case, we always need, when proposing how to comply with the requirements of records management, to find the balance between standardization (with equal needs propose the same solutions) and the necessary flexibility that allows the optimization of work processes.

^{Note 1:As in other occasions, for the sake of good understanding and traslation, I have used the term records analysis to describe what in ISO 15489: 2016 in English has been called "appraisal"}

^{Note 2: When I wrote this post I just realized what an absorbing task records analysis is. I’ve been over a year without posting in my blog!}