AGENCY RESPONSE         R-B-1 through R-B-5

WSA’S  RESPONSE TO  LSO’S CONFIDENTIAL DRAFT AUDIT REPORT

Attachment

May 2000

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5  First paragraph:  W.S. 9‑2‑401 Definitions include language about local government, as does 9‑2‑405 Classifications of public records; 9‑2‑410 requires activities relating to local government records; 9‑2‑412 refers to 9‑2‑411 and discusses the scheduling process.  Also, change to: AMost of the schedules the section creates for local governments apply to multiple ...@

6  Paragraph heading should just be AArchives and Historical Research@

6  First paragraph under A & H  Research:  In addition to providing proper and secure storage of these documents, Archives processes the records applying basic conservation techniques and inventorying them, and makes the records accessible to government agencies and organizations, and also the public who uses them for scholarly and personal research.

7 Third paragraph:  One person serves as a receptionist for the Archives answering the phone for all of the WSA, along with doing work for the entire program.  The remaining four staff members and supervisor also process collections, develop finding aids, and supervise volunteers, interns, and JTPA temporary employees, including training them.

7 First paragraph under Technical Services: Should read A...consists of three functions: Micrographics, photographic, and paper conservation.@

8 Third paragraph: Should simply be the Aphotograph unit.@

Note: WSA has the only conservation lab in Wyoming that is operational with trained staff.

11 Third paragraph:   During the Barrett Building remodeling, program funds were used to move the offices and collections to and from U.S. West, along with WSA program funds used for the consolidation of records centers and the moving of the microfilm from a leased facility to the Barrett Building.  These moves not only took financial resources from the program, but were also very demanding on staff time to prepare for the moves and the time consuming tasks after the moves.

13 Last paragraph and 14:  All indications are that the volume of paper records is not decreasing, and the volume of incoming or new records must be managed properly, even with decreasing budgets and personnel.  Also, previous reports also discuss the need to increase resources to handle not only paper‑based record keeping systems, but electronic formats as well.  State agency staff are not comfortable with pure electronic information systems, and are retaining paper records as backup, even though the WSA works at eliminating the paper, just as it does with paper that has been microfilmed.  Lack of adequate funding for new electronic information systems

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which is appropriated to the agency of record, does not help the WSA when it comes to working with the paper and electronic media generated by the new system and managing it when the agency contacts the WSA.  Lacking funds to convert current active files, they then become the responsibility of the WSA to manage.

16  Last paragraph before the new section:  Delete Alikely@, as all electronic information system will become obsolete, and have to be migrated to new storage media and current software.

17  Paragraph  headed No Overall State Guidance for Electronic Records:  The last sentence states that AWSA staff view the electronic format as a processing medium only, with paper copies serving as the records.@ does not fully clarify.  When going through the scheduling process, WSA attempts to determine which medium is retained as the record copy.  If the record has short term value, WSA has no preference as to which medium is retained, but will discourage maintenance of duplicate records.  If the record has long term value, WSA may recommend that paper or microfilm be retained as the record copy, because of the vulnerabilities of digital media.  The only time that WSA recognizes Athe electronic format as a processing medium only@ is when paper or microfilm serve as the record copy.  WSA expects state agencies to convert digital records to paper only for  permanent records.

18 Paragraph headed Many State Records Created Electronically Are likely Unscheduled: This condition is not new and not peculiar to digitized records.  An unscheduled record can be recognized at some point in time and the situation corrected, but an un‑managed record can be a real problem, particularly when it is a digitized series.  When an agency begins to store a record series digitally, there is no need for additional scheduling if the information is already scheduled;  it is the information that is scheduled, not the medium.  The difficulty agencies have with digital records is not how long to keep them, but how to manage them.  Specially designed systems  for data bases are normally highly structured and are not a problem.  The most unmanageable area seems to be text documents which are created on computers or received through the e‑mail system.  There are document management systems (EDMS) designed to handle text documents but they are, at this time, quite expensive.  To WSA’s knowledge there are no EDM systems in Wyoming government.  This is generally the condition nation wide.

In the e‑mail classes that WSA conducts, guidance is provided on how to create directories that mirror paper classification systems and comply with records retention schedules.  However, these directories are simply a stop‑gap method,  using an inadequate solution until  EDM systems can be acquired.

18  Last sentence of the paragraph starting AWSA’s  limited program...@: Most of these records do not relate or are part of an electronic database.  Also, the information from records that is maintained electronically, like vouchers and payroll records, still requires the source records to be maintained for audit, and legal and administrative use. 

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19  Second paragraph: At present, WSA has no influence regarding how an agency chooses to create or maintain its records.  State agencies still choose to or must use high volumes of paper.  These records must then be managed.

19  In third paragraph discussing grants, the major reason for not seeking grants is because we don’t have the program monies to provide a 50/50 match which is usually

required. 

20 First paragraph under new section:  The WSA can’t Amanage@ electronic information in every state and local government office.  Only if the information is required to be kept permanently by the SRC, can the WSA attempt to make sure that it is preserved, or force litigation if it is not.  A strategy in the SHRAB report called for adequate budget to preserve electronic data, etc.

20 Second full paragraph which encourages WSA to make development of a short‑term electronic records program a priority: WSA concurs that more and effective use of digital records should be encouraged, but we must also realize that there are records that currently do not lend themselves well to the medium or are required to be in hard copy form for audit or legal reasons.  For example, vouchers are maintained to, among other reasons,  ascertain the validity of signatures.  Game & Fish license selling agent books would be impracticable to convert to film or any other medium.  Family Services client case files have an array of forms, personal notes and other outside input, which make them too a bad candidate for digital storage. There are many other examples that could be cited.

21 Second paragraph which suggests that with the reconstitution of SHRAB and guidance from other states, WSA can implement a more effective training and outreach program.  WSA concurs, but emphasizes that only with additional resources and a properly trained staff can this be achieved.

29 thru 35:  Chapter 4 Micrographics needs to include a  recommendation that a plan needs to be developed and a replacement schedule prepared, to obtain funding to replace equipment that has been used since the program first started, or since 1955.  Only during the last few years, have funds been appropriated for equipment, and then only a small amount compared to what is needed to purchase new equipment.  The demands for replacing computers and software have taken precedence over replacing micrographics equipment.

28 Fourth paragraph:  The quantity filmed per day does not include any quality control of the film.  Also, the records would have to be current, good uniform quality records, and not fragile historical records.  Also, the equipment must be new to avoid down time, and the production rate would have to allow for vacation, sickness,  training, etc.

28 Last  paragraph:  Some rotaries were operational at that time. 

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29 Current calculations put the number of cubic feet in the records center that are scheduled for microfilming at 4,844, not 4,951.  In CY99, we transferred into the RC  515 cubic feet to be m/f. 

This figure does not include the daily records from the SOS’s office including the Enrolled Acts.

31 First paragraph: Technical Services is not in a position to re‑evaluate material, except if the project is too difficult and time consuming, then they may recommend that the records be retained in

Archives which would be less expensive.  Also, 50% should be reduced to 10%, if the writer is referring to records that we m/f for the SOS.  Also, Ain‑house daily use filming@ may refer to microfilm that is created for the daily in‑house use by other agencies and the Archives.

33 See comments relating to page 5 and the discussion about statutes above.

36 Fourth paragraph:  In 1997 WSA told local government offices that files must be weeded of non‑permanent records before transferring to the Archives.  Files that have not been weeded will not be transferred.  However, since WSA staff are at remote locations and can’t take the time to examine all files and schedules, some non‑permanent records may sneak in.  Also, instead of taking the time to weed files, some offices decide not to transfer.  The ultimate disposition and storage conditions for these records is a concern to WSA.

39 First paragraph:  WSA must respond to requests to store paper and electronic records, and this will continue as most electronic records are a product of the paper record, but not all data may be entered into the system.  Also, scheduling electronic information is a difficult, and sometimes impossible, task, which requires a lot more cooperation, time, and training to handle, than do paper records.

40 Second paragraph under heading Records Scheduling is Subjective: The report states that WSA may not press their own (retention) recommendations for fear that agencies will stop using WSA services.  It is more accurate to say that this condition could occur if an analyst thought that a steadfast position would stop the process.  Little would be accomplished if an analyst consistently took a bully position.  While there are sometimes other influences on retention scheduling, the experience possessed by personnel involved in the program is a valuable facet that should not be ignored.  However, an analyst would not permit the writing of a schedule that would permit the destruction of records before a known legal requirement.

43 First and second paragraphs: The report states  how two other states have assigned responsibility to agency appointed records officers to perform records analysis and submit recommended disposition to the record management function, relieving records management to focus on other areas.  The WSA lacks adequate authority to require agency records officers perform analysts tasks. WSA is also concerned that these designees would not have the time and expertise to perform these functions.  Our experience is that records functions are low on agency priority lists.  Also, without following the proper process and scheduling records, the State’s liability payments could increase, caused by improperly scheduled, or no scheduling of records.

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50 First paragraph:  Public records, such as those of Governor Warren, are the responsibility of the State Archives and are currently maintained there. 

50 Third paragraph:  The statement Alack of modern finding aids@ ignores those collections whose

description are described in accessible electronic databases and on WSA’s website.