A new bulletin from the U.S. National Archives and Records Administration (NARA) provides some guidance on managing records in social media/Web 2.0 platforms.
The bulletin builds on existing NARA web guidance documents, including the NARA Guidance on Managing Web Records and Implications of Recent Web Technologies for NARA Web Guidance. It also addresses some of the issues raised in a recent NARA report on federal use of Web 2.0 tools. That report concluded that there was a great deal of uncertainty about how to determine if a social media record is a federal record.
The new bulletin is an effort to address some of those uncertainties. Echoing the report on Web 2.0 use, the bulletin notes:
The principles for analyzing, scheduling, and managing records are based on content and are independent of the medium; where and how an agency creates, uses, or stores information does not affect how agencies identify Federal records. When using web 2.0/social media platforms, the following non-exhaustive list of questions may help determine record status:
- Is the information unique and not available anywhere else?
- Does it contain evidence of an agency’s policies, business, mission, etc.?
- Is this tool being used in relation to the agency’s work?
- Is use of the tool authorized by the agency?
- Is there a business need for the information?
If the answers to any of the above questions are yes, then the content is likely to be a Federal record.
The bulletin goes on to provide some good questions to ask and considerations to make when determining if a social media record constitutes a federal record. FierceGovernmentIT wrote a good summary of the bulletin and reproduced this flowchart (from Appendix A of the bulletin) that explains how to determine if social media records require a records management schedule:
Acknowledging that federal records on third-party websites present unique challenges, the bulletin provides a general records management clause to include when negotiating a Terms of Service agreement or contract with a service provider.
The Agency acknowledges that use of contractor’s site and services may require management of Federal records. Agency and user-generated content may meet the definition of Federal records as determined by the agency. If the contractor holds Federal records, the agency and the contractor must manage Federal records in accordance with all applicable records management laws and regulations, including but not limited to the Federal Records Act (44 U.S.C. chs. 21, 29, 31, 33), and regulations of the National Archives and Records Administration (NARA) at 36 CFR Chapter XII Subchapter B). Managing the records includes, but is not limited to, secure storage, retrievability, and proper disposition of all federal records including transfer of permanently valuable records to NARA in a format and manner acceptable to NARA at the time of transfer. The agency is responsible for ensuring that the contractor is compliant with applicable records management laws and regulations through the life and termination of the contract.
Like many documents that NARA produces, the bulletin is targeted at federal agencies, but it provides some great guidance for any institution using social media. It’s great to see the agency follow up the report on Web 2.0 use with some practical guidelines for determining if a social media record requires archival attention.