An FBI Case Study: Incorporate RIM Into System Development Processes Tammy J. Strickler, CRM Records Automation Section Records Management Division, FBI 1

Expanded Emphasis *Presidential Memorandum – Managing Government Records, November “Decades of technological advances have transformed agency operations, creating challenges and opportunities for agency records management.” *Executive Office of the President (EOP) issued the “Managing Government Records Directive”, August

Adding RM Value to IT Projects *IT Governance was established as necessary for proper management of large IT projects in 2004, many years ahead of the 2011 Presidential Directive *FBI Records Management learned the language of IT *FBI included RM requirements in the new automated case management system - Sentinel – the enterprise case management system which was recently deployed *FBI response to data call for the Presidential Directive showed already mature program 3

Changed the Information Management Business Process *Established the “major stakeholders” would include Records Management *Approached the transformation as a “value added” change in process *Established that Records Management is a key player to help manage information, not hinder system development 4

Learning the IT Sandlot *Established records management assessments as an integral part of the IT System Development Lifecycle (SDLC) *Illustrated the impact points within the SDLC *Provided examples of how Records Management can save money during SDLC *Incorporated records assessment steps into the SDLC document templates *RM layer added to Enterprise Architecture as an equal to system security (since 2005) 5

RM as Part of SDLC *Records Management has input at every development milestone *Records Management can provide system owners with cost justifications for data migration or disposition preparations, if needed, as part of their system lifecycle costs *The FBI recognized the importance of managing information and Records Management achieved equal standing as a participant in SDLC reviews 6

Mapping RM into SDLC *Where you see color on the displayed chart is where records management processes interface with the system development lifecycle 7

Electronic Recordkeeping Certification *Early in system development, system owners must decide how they will approach recordkeeping *Integration with the Enterprise RMA *Export final data to Enterprise RMA *Recordkeeping functions integral to system *All legacy systems evaluated under “integral” approach *Evaluation of record declaration, capture, maintenance and use, disposition, and national security classification/declassification management 8

Certification Processes *Use existing system documentation for gleaning system information *Incorporate e-discovery guidance for all systems, even those that do not maintain records, in accordance with the 2006 changes to Federal Procedures *Provide system owners with a Risk Mitigation plan to address shortcomings for recordkeeping 9

Lessons Learned *IT System Owners generally cannot answer RM questions on their own – We use the same terms to describe totally different actions: i.e. archive, record, file *Incorporate e-discovery guidance for systems that do not maintain records *Provide examples of good and bad planning for information management in briefings to Project Managers 10

Open Collaboration between IT and RM *RM now includes IT portfolio managers in all discussions regarding system certification for electronic recordkeeping *RM is included on all IT project review boards at all development stages *RM involves General Counsel and/or Information Security early in system reviews when concerns are noted *Completion of all RM processes are part of Enterprise Architecture compliance for continual O&M of systems and coordination of change requests 11

Acceptance - Internal *Records Management has been accepted as a professional discipline at the FBI *Project Managers now seek out RM involvement during early system concept reviews *Other stakeholders now seek RM impact when they notice it is missing from system documentation (such as General Counsel during Privacy Impact Assessment development) *RM now has support from other stakeholders when RIM issues arise 12

Acceptance - External *Received the Archivist’s Achievement Award for incorporation of records management protocols into electronic system development from the Archivist of the United States *Received acceptance of automation/scanning of some major records collections from the National Archives (and working towards more) *Shared this process and ideology with other federal agencies *FBI Records Management processes are recognized as Best Practices for managing electronic records 13

The Best Practices for E-RM *Records assessments are performed early in system development *Record schedules are developed early in system development, sometimes prior to full system implementation *Shortcomings to meet recordkeeping are identified early in system development, reducing cost of implementation *Records management concerns are addressed before old systems are discontinued and corporate memory is lost *Data migration planning now part of system development *Recordkeeping certification the FBI uses for electronic systems can be found online at manual.pdf 14

Related Projects *Records Management in conjunction with the Office of General Counsel is driving governance of SharePoint site creation and decommissioning *Records management of interagency collaborative websites *Paradigm shift from born-digital-maintained-hardcopy to born-digital-maintained-digital records *Identification of more high-impact document conversion projects to replace hardcopy recordkeeping of temporary records in line with the EOP Directive Part I, para 1.1 *Conversion and embedding other digital data such as audio, video, or photographs within digital versions of textual documents 15

OPM Changes *The President also directed the Office of Personnel Management to “establish a formal records management occupational series” Establishes certified skill sets and training needed for all federal records professionals 16

Questions/Comments? Tammy J. Strickler, CRM Team Lead for Electronic Recordkeeping Certification and Electronic Records Scheduling 17