Finding

WSA Records Management Services Are Geared to the Paper Environment

WSA has not adapted to accommodate the changing records environment.

Even though information technology is rapidly changing the ways records are created, WSA continues to focus its configuration of records management services on the paper-based environment.  Its services include labor-intensive records scheduling and off-site records storage for state agencies’ paper records.  At this juncture, when agencies are creating both paper and electronic records, WSA must offer services for both paper and electronic records.  However, WSA has not adapted its work processes to accommodate the changing records environment, nor to free up limited resources to address other program needs.  In order to do so, WSA should modify its approach to scheduling records.

WSA is Service-Oriented in its Approach

WSA does most of the work in scheduling records for state agencies.

Statute requires agencies to have records officers, but WSA says their competency varies.

WSA rarely works with program managers.

Although WSA schedules records for local governments, most of its scheduling work is with state agencies.  Furthermore, WSA records analysts prefer to do most of the work entailed in describing agency records and researching the appropriate disposition for them.  They do this even though statute (W.S. 9-2-409) directs state agencies to designate records officers to supervise agency records programs and prepare records for transfer either to the Records Center or Archives South.  WSA records analysts told us that the competency and expertise of these agency records officers varies throughout state government.  As a result, the analysts prefer to do the work themselves, because, “the less work we ask the agency to do, the faster (the process) goes.”

WSA records analysts work with the agencies to develop an under-standing of the programs for which they are scheduling records.  They need to understand the function of the records being scheduled, and what they are documenting.  Analysts research state statutes and rules, as well as pertinent federal laws and regulations to determine how long records should be retained and other disposition requirements.

However, WSA analysts rarely have access to the program managers who best understand the functions and operations of their programs.  Program managers, or other professional staff, may be able to readily provide information that records analysts have to research.  But, according to WSA officials, records analysts do not typically work directly with program managers or anyone with decision-making authority.  As discussed in Chapter 2, electronic records will increasingly remove the support staff with whom WSA analysts currently interact from the recordkeeping process.

Records Scheduling is Subjective

Few record retention periods are set by statute.

SRC members are not concerned with retaining records for as short a period as possible.

Ensuring that records are scheduled to the most efficient and economical disposition is the responsibility of WSA analysts, working in cooperation with the state agencies.  However, scheduling records is a subjective process.  Few Wyoming statutes set record retention periods or other disposition parameters, nor are there national standards for records retention.  WSA record analysts prefer to let the logic of the records materials determine the retention.  Negotiation with agency personnel with respect to their preferences is also a determining factor in how long records are scheduled for retention

The State Records Committee, which has final authority to approve record schedules, is not necessarily concerned with seeing that records are retained as briefly as possible.  Rather, its members are primarily concerned with ensuring that records are retained long enough to satisfy legal and audit requirements.  Yet, WSA records management officials told us that in negotiations with agencies, they were reluctant to press their own recommendations for fear that agencies will stop using WSA services.  Further, they noted that WSA has compromised on retention periods to satisfy the comfort levels of their “clients.”

WSA Schedules Most State

Records Short-Term

WSA estimated the retention periods of state agency records stored in the Records Center.

Almost half have retention periods of five years of less.

Yet WSA says it needs more shelving:  it unsuccessfully requested funds for additional shelving this biennium.

The program’s seemingly chronic need for additional storage, coupled with its service-oriented approach to meeting agency desires, prompted us to question whether WSA may be scheduling records for lengthy retention periods.  This practice would create pressure on WSA storage facilities, and affect local governments’ storage needs as well, since they must store their own non-permanent records.

WSA does not have a management information system that can provide aggregate information about the schedules it creates.  However, program staff was able to estimate the retention periods of state government records stored in the Records Center using their destruction dates.  WSA estimated that:

·         46 percent of records scheduled for destruction had retention periods of between one and five years. 

·         27 percent had retention periods of six to nine years. 

In addition, our review of the retention schedules created in 1999 found that:

·         Nearly 64 percent of the schedules were for periods of five years or less. 

Thus, we concluded that WSA is scheduling most state agency records for retention periods of five years or less, which makes them short-term records.  Further, it appears that the WSA records retention process generally results in records being stored for a relatively short, rather than lengthy, time period.

More Shelving Has Been Requested.  WSA currently says it is experiencing a shelving shortage.  Although the Governor denied the request and the Legislature did not appropriate the funding, WSA requested nearly $100,000 for an additional 14,000 cubic feet of shelving for the 2001-02 biennium.  WSA requested the funds in order to continue accepting records in the Records Center and in Archives South.  WSA received approximately $131,000 in the 1995-96 biennium for 13,500 cubic feet of shelving to meet the same need, which was installed at the end of 1994.

Further, the 1999 Joint Legislative-Executive Revenue and Expenditure Study also suggested that records were being scheduled for too long.  Policymakers were concerned about the expense of maintaining records at both the state and local levels, and surmised that government could realize savings from reviewing retention periods.  However, as WSA officials note, to realize the storage savings and other benefits of a records management program, governmental entities must dispose of records as scheduled.  Unless WSA monitors non-permanent records, as it does those of state agencies in the Records Center, there are no assurances that records are disposed of as scheduled.

Focus on Traditional Services Impedes Progress on Needed Program Changes

Each year, WSA takes in more non-permanent records than it destroys.

WSA has not promoted the use of the electronic format for short-term records.

By concentrating its limited resources on managing records in traditional ways, WSA creates pressure on its facility capacities.  Even though WSA appears to be scheduling a large percentage of state agency records for minimum retention periods, each year it takes more records into the Records Center than it destroys.  From program statistics, we estimate a 770 cubic foot average annual deficit over the last five years.  Program officials cite this deficit as part of the basis for requesting additional shelving. 

The WSA focus on a paper-records environment, which is rapidly being displaced by the spread of computer technology, inhibits it from looking at alternatives for record storage.  For example, as noted in Chapter 2, WSA has not promoted the use of the electronic medium for short-term records, even though there is little likelihood that technology will change before those records reach the end of their retention periods.  WSA officials note that there a very few schedules for electronic records, and that only two agencies have decreased their record volume by using them. 

WSA officials also acknowledge that records analysts are unable to review existing record retention schedules on a regular basis.  They cite a lack of staff and resources as the reason that analysts cannot review schedules every ten years, as would be optimal.  These reviews have the potential to reduce pressures on WSA storage resources.  For example, in 1998 WSA initiated a modification of county court schedules, reducing their transfers to Archives South by 89 percent (300 cubic feet) each year.

Other States Modify Practices to Meet Needs

South Carolina changed its records scheduling approach to free up resources for other needs.

Facing similar circumstances, another state records management program changed its established modes of operation and resource allocation to enable it to address areas of concern.  Like WSA, the South Carolina Archives provided comprehensive records inventories and scheduling services for state agencies.  This left the program with little time to provide regular, ongoing training or to address electronic records issues.

To free up the resources for these priorities, South Carolina refined its record scheduling process.  Instead of record analysts doing the bulk of the inventorying and research work for the entities they scheduled, these responsibilities were shifted to the agencies and local governments.  Coupled with this was an active training and publications program that gave agencies and local governments the basics for handling their new duties.

Similarly, Kansas requires state agency record officers to prepare and submit retention and disposition schedules in cooperation with the records management staff.  Kansas’ records management regulations also call for state agency records officers to periodically review agency schedules and submit requests for needed modifications.  Each records officer is required to be a staff member holding an administrative or professional position, although the record officer duties may be collateral duties to an existing position in the agency.

Statutes and Tradition Prompt WSA to Provide Comprehensive Services

Statutes specify comprehensive records scheduling services.

Changing its approach would require training for agency records officers.

In providing comprehensive services to the state agencies, WSA is following the directives provided in statute.  W.S. 9-2-406 (a)(iii) directs WSA to inspect, inventory, catalog and arrange retention and transfer schedules for all state departments and other agencies of state government.  WSA is choosing to emphasize its role in these functions, rather than calling upon the agencies to develop their records officer positions as described in statute.

WSA officials contend that they cannot shift records management responsibilities back to the agencies because WSA lacks the authority to obtain the necessary support from those agencies’ management.  In addition, WSA does not believe agency records managers consistently have the expertise to assume these responsibilities.  Thus, this approach would entail significant records management training that the program is not currently able to provide.

Finally, perceiving resources as inadequate, WSA officials have elected to focus upon what the records management section has traditionally done best:  schedule and store paper records.  Further, they have adopted a service posture that makes the program reluctant to demand more of state agencies.  Program officials cited a concern that agencies will not store records in the Records Center if WSA analysts withdraw assistance.  At the same time, however, they note that program capabilities would be overwhelmed if all agencies requested their services. 

Recommendation:  WSA should reassess its approach to providing record services to free resources for other needs.

Services required by 21^st century records systems are qualitatively different from those that fit the paper environment.

The current WSA approach to managing records is resource intensive, leaving them unable to address other vital aspects of the state’s records management program.  In view of the challenges posed by electronic records, WSA should reassess the manner in which it provides records scheduling services.  The kind of services required by 21^st century records systems are qualitatively different than those that fit paper records needs.  If agency and program officials feel obliged to maintain current services by statutes, they should seek legislation to amend statutes to better fit the current records environment.

In addition, WSA officials should consider shifting more records management responsibility to the agencies.  It is not effective for record analysts to continue working with agency personnel that are being increasingly displaced from the recordkeeping process.  Furthermore, it is not effective for WSA to research information that higher-level program officials already have.  Therefore, WSA needs the authority to ensure that agencies provide the professional input necessary to manage records effectively.  Enhancing the statutory role of agency records managers may be a way to accomplish this.