ISO 15489 ISO 1 5489 Recor ecor d s M a n a g em en entt – its developm ent a nd sig ni fi ca nce nce SUS USA A N HEA HEAL LY
Abstract This article describes the process of producing ISO 15489 Records Management, and explores some of the professional and other issues that arose for consideration at an international level. It concludes by identifying some of the benefits of the Standard for records management in the UK.
Introduction In this article I shall describe the process of developing the international standard ISO 15489 1 and its associated Technical Report, and some of their contents and assess the Standard’s significance for records management in the United Kingdom 2. F irst, irst, an a n explanat explanat ion of th e abbreviations abbreviations an d acronyms a cronyms I shall use. use. ISO stands for International Standards Organisation, a body based in Geneva that oversees the issue of international Standards. The British Standards Institution (BSI) is the UK NMB (National Member Body of ISO). The ISO Technical Committee under whose auspices we worked is TC 46 and its Records Management Sub-committee is SC 11, hence the reference to TC 46/SC 11. The BSI counterparts are IDT 2 at the Committee level (standing for Information Documentation Terminology) and Sub-committee 17, hence IDT 2/17. Key stages in development of a Standard are production of a Committee Draft (CD), a Draft International Standard (DI S) and a F inal D raft International Standard Standard (FD IS). IS). F inally, nally, the sections making up a Standard are called clauses. Development of ISO 15489 My involvement in ISO 15489 started in July 1997 when I attended a meeting at the BSI offices in Chiswick. The purpose of the meeting was R ecords ecords M anagement anagement J ournal, ournal, vol. 11, no. 3, D ecember ecember 2001, pp. 133–142 133–142
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to discuss future action on internationalising the pioneering Australian Standard AS 4390 3, Records Management. This Standard had been developed in Australia in the early 1990s in response to the quality Standard ISO 9000. ISO 9000 refers to the need for “quality records” to show the operation of a quality system but does not expand on what makes up a quality record. Australian records managers made the connection between ISO 9000 accreditation and good records management and set out to fill the gap, producing what Standards Australia has described as one of its best sellers. AS 4390 had recently been through an ISO balloting process for issue as it stood but sufficient reservations had been expressed by NMBs for ISO to decide that a re-think was necessary. So, a group of records professionals and Standards experts from the UK, Australia, USA, France and Sweden met and concluded that ISO should be asked to set up a new sub-committee to develop AS 4390 into an ISO Standard. This was the start of what was to prove a fascinating if often frustrating project. ISO approved the recommendation and TC 46/SC 11 met for the first time in Athens in May 1998, with the chair (David Moldrich) and secretar y (Peter (Peter Tr esede eseder) r) provi pro vided ded by Au stralia. stralia. T he U K was represe represented nted by Philip Jones and me at this and subsequent meetings; Bob McLean joined the delegation in May 2000 4. Other countries represented at the meetings were Australia and New Zealand, the USA, Canada, France, Sweden, Germany, the Netherlands, Ireland and Denmark. We were joined also by observers from the International Council on Archives and the International Records Management Trust. The UK was represented at the Athens meeting because BSI had decided to contribute to this work and had established IDT 2/17 to shadow TC 46/SC 11, with me in the chair. IDT 2/17 was and is a healthy mix
A working break, Berlin May 2000. From left to right: Michael Wettengel (Germany), Barbara Reed (Australia), Pierre Fuzean (France). 134
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of those who practice records management in both public and private sectors, those who oversee it in government and those who teach it, together with representatives of other interested organisations. TC 46/SC 46/SC 11’s 11’s activity activity has h as not no t b een een confined con fined to its sixsix-mon mon thly th ly meetings. meetings. Much of its work has been done electronically, using email and a dedicated mailing list and discussion database, and the meetings were less for drafting than for negotiation. It soon became clear that different national professional and juridical traditions led to very different views of what the Standard should cover and contain. These differences persisted throughout and it is remarkable that we were able to reach consensus without losing the utility of the finished Standard. What sort of issues caused difficulties? Here are some of them. Scope
Scoping the Standard was an initial and recurring problem. Some countries do not distinguish between records and archives and were unhappy with a time-limited concept of records management. They had real difficulties with the idea that we should focus only on the management of records in their originating organisation, with no coverage of the management of those selected for permanent preservation and archived, either in-house or in an external archives institution. This issue mattered to the U K deleg delegation ation because because other BSI sub-committees sub-committees work work on aspects aspects 5 of archives administration, such as the BS 5454 sub-committee, and we needed to avoid encroaching on their territory. TC 46/SC 11 managed to reach agreement and ISO 15489 does not extend to archives administration. This is stated explicitly in clause 1, Scope, in the following terms “T his International Int ernational Standard S tandard provides provides guidance on managing records records of originating organizations, public or private, for internal and external clients. ... [It] does not include the management of archival records within archival institutions”
while footnote 1 explains: “In some countries, the management of records also applies to archives management. Archives management is not covered in this Standard.”
As for what records management encompasses, the Standard adopts an holistic approach. The definition of records management in clause 3 is
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“field of management responsible for the efficient and systematic control of the creation, receipt, maintenance, use and disposition of records, including processes for capturing and maintaining evidence of and information about business activities and transactions in the form of records”.
Status
There was some debate concerning whether the Standard should be a voluntary code of practice, i.e. a statement of recommendations, or a compliance Standard, i.e. a statement of requirements. The decision had to be made because of the effect on terminology, on which ISO has rules. The verb ‘must’ and others with a mandatory connotation can be used with compliance Standards only; for recommendatory Standards ‘should’ and equivalents is the accepted term. We decided that a compliance Standard would be premature and self-defeating; most organisations need urging towards best practice and would not respond to a document purporting to set mandatory requirements. Furthermore, without enforcement powers and mechanisms it would be futile. Audience
Terminology also affected our decision on whether the Standard should be aimed at records practitioners or general managers and company secretaries. AS 4390 is aimed at both: Part 1 is a high level summary of the other parts which is intended to be read by the managers who seek ISO 9000 accreditation and control the funding of records management, while Parts 2-6 provide operational details suitable for practitioners. We had already agreed not to replicate the AS 4390 division into parts so that option was not open to us. We decided that the Standard should be intelligible to non-specialists but useful for records professionals; it remains to be seen whether we succeeded. The Technical Report, on the other hand, is intended to be read and used by records practitioners. Structure
The structure of the Standard changed frequently in the course of development (one cause of the frustration alluded to above). The major change was the decision in May 1999 to divide the text into two documents, a Standard focusing on principles and outcomes (the what and the why) and a Technical Report (TR) providing procedural guidance, thereby providing an aid to understanding and implementing the Standard (the how). In the event we ended up with a TR that expands clauses in the Standard selectively.
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The clauses in the Standard indicating and the corresponding clauses in the TR (as indicated) are as follows: 1
Scope ope (TR cl claus ause 1) 6
2
Normati Normative ref referenc rencees
3
Term Termss and and defi definiti nition onss
4
Benefi nefits of rec records manage management ment
5
Reg Regulat ulator ory y env enviironm ronmeent
6
Poli Policy and respons responsiibil bilitie ties (TR (TR clause ause 2) 2)
7
Records Records manage management ment requi require reme ments nts
8
D esig esign n and imple implementati mentation on of a records records sys system tem (TR (TR clause clause 3)
9
R ecords manage management ment proces process and control controlss (TR (TR clause ause 4) 4)
10
Monitori Monitoring ng and audi auditing ting (TR clause ause 5)
11
Traini Training ng (TR cl clause ause 6)
The TR also contains a bibliography and two appendices that link the clauses in the Standard to the corresponding clauses in the TR and vice versa. An index is also planned. The two clauses expanded most in the TR are clause 8 (as clause 3,
Working on the Technical Report, May 1999. From left to right round the table: Frank Upward (Australia), Philippe Barbat (France), Anki Steen (Sweden), Ruth Kappel (Germany), Piers Cain (IRMT) and Susan Healy (UK).) 137
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Strategies, design and implementation) and clause 9 (as clause 4, Records processes and controls). TR clause 3 contains a detailed explanation of the DIRKS (Designing and Implementing RecordKeeping Systems) methodology developed by the National Archives of Australia 7. TR clause 4 contains text on (i) the instruments required for RM operations, e.g. business classification scheme, disposal schedules (called disposition authorities), security and access classification schemes and vocabulary controls; and (ii) processes using these instruments, e.g. capture, tu re, reg r egis istr trat ation, ion, classific classificat ation, ion, a cces ccesss and an d security security classifi classification, cation, disposal, storage and use and tracking. Annexes to the Technical Report
We liked the idea of including annexes and contributions were received. For example the UK supplied some model policy documents and disposal schedules. Two factors led to a decision to omit them. The first was the number of additional pages they would involve and the resulting increase in the sale price of the TR. A rough reckoning is £1 for each page of a Standard or TR and if the TR was to be affordable, especially to developing countries, it had to be cut. The second factor was that we could not agree on what was appropriate to an international document that would be translated into other languages. In the end it was decided to leave it to NMBs to add annexes if they wish. BSI has agreed to do this and the UK edition of the TR will include a couple of annexes. Record-ness
There was continuing debate about when a record is a record – or perhaps when a document or information becomes a record. Professional theory concerning capture and registration collided with the reality that the courts in some countries accept as records what records managers might refer to as documents. The Standard represents a workable compromise in setting out the characteristics that records and records systems should possess without overtly contradicting national legal systems. So, records are defined as “information created, received, and maintained as evide evidence nce and information by an o rganization rganization or pers p erson, on, in pu rsuance of legal obligations or in the transaction of business”. Authoritative records, however, are those with certain characteristics: authenticity, reliability, integrity and usability (clause 7.2) and the records systems supporting them have the complementary characteristics of reliability, integrity, compliance, comprehensiveness and systematic (clause 8.2).
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Terminology
ISO Standards are supposed to use authorised terminology where this exists and depart from it only when absolutely necessary. Records management terms t erms are ar e included included in ISO 5127 5127 8 but TC 46/SC 11 found it could not accept all its definitions. So, clause 3 contains some variant definitions on which we were, eventually, able to reach agreement. Appraisal
The word ‘appraisal’ does not appear anywhere in the Standard or the Technical Report. This is because we could not agree what it is or who can do it – a good example of differing national traditions. One strongly held view was that appraisal is the assessment of the value of records (or functions) for historical research with a view to determining which should be preserved permanently. Another equally strongly held view was that it is an assessment of the value of records (or functions) for operational and archival purposes with a view to determining which records should be created and, once created, for how long they should be retained (which might be one or many years or even permanently as archives). The solution: describe the concept and omit the word. So, clause 9.1 (Determining documents to be captured into a records system) and clause 9.2 (Determining how long to retain records) together contain useful and acceptable text without mentioning the term. It was only some months after the text of the Standard had been agreed that we realised realised some of us meant different different things th ings by the th e wor word d ‘retent ‘retention’ ion’ … . Having achieved consensus on the Standard at our meeting in Berlin in M ay 2000 2000 we we were were able to submit it to formal voting by NM Bs as a D IS. To our relief it achieved a 100% ‘yes’ vote, albeit with comments seeking some changes. ISO rules allow a chair to omit circulation of a revised Standard as a FDIS and to proceed directly to publication if a DIS has received a 100% “yes” vote. The chair of TC 46/SC 11 decided to follow this route and at the time of writing (in August 2001) the Standard is being prepared for publication. A formal launch ceremony will take place at the ARMA conference in Montreal on 3 October 2001.( Editor’s note – The launch did take place with a live link to the UK PRO conference at Stratford upon Avon.) The TR achieved consensus at the Stockholm meeting in November 2000 and, with some agreed revisions, was issued for voting by NMBs in 2001. This was successful and, all going well, the TR will be published towards the end of 2001. BSI will publish the UK edition as BSI ISO 15489 later this year. The TR will be published also, and UK purchasers will have the benefit of some useful appendices – model policy statements – omitted from the ISO edition. ( Editors note: the Standard and TR have now been published ). ).
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BSI will be publishing also some guides in its DISC series. Three are in hand already, dealing with business benefits of records management (written by D avid avid Best), Best), performance performance measure measurement ment (written by San dra Park Pa rker), er), and a guide to implementation (written by Julie McLeod). Others may follow, for example a workbook has been suggested. The significance of ISO 15489
In one sense, the contents of ISO 15489 are less important than its existence. The fact that records managers can point to an ISO/BSI Standard for their discipline can be used to improve the image and status of records management in the eyes of those who know little or nothing of the subject. So, buy it and cite it for that reason if no other. But the th e Standa Stan dard rd deserves deserves respect respect for its content s as well well as its exis existence. tence. It is a statement of good practice in records management which records managers should find useful, however qualified and experienced they are. It is also something that can be passed to professionals in other fields when working on projects together, for example ICT professionals when developing new records systems. I think the Standard improves on AS 4390 in two ways in particular. F irst, irst, the t he internationalising internationalising process process has made ma de the Stand ard more suitable than AS 4390 for the UK environment ( Editor’s note: and on the same basis potentially for other countries). The use of ‘records management’ rather than ‘recordkeeping’ as the key term enables a strengthening of the alignment alignment of o f records records manageme ma nagement nt with ma nagement nagement r ath er than with with filing. This fits well with the conception of records management imparted in current university courses and reflected in the draft code of practice under section 46 of the Freedom of Information Act 2000. In addition, the change from the records as evidence basis of AS 4390 to allow also for records as information works better in the UK, where there is a general acceptance that records have value not only to provide evidence of past decisions and actions but also to inform current and future decisions and actions. This is now accommodated. The second area in which AS 4390 has been improved is the teasing out of separate characteristics for authoritative records and for record systems. This should make the text much more useful to those seeking to develop systems with authoritative records. Conclusion In setting out some of the areas of disagreement above I have tried to give a sense of what is involved in developing an ISO Standard and to
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describe its contents in general terms. Achieving consensus required compromise by all involved but I believe it has been to the benefit of the finished documents. What is needed now is implementation of the Standard, assisted by the TR and the BSI DISC booklets, to test its utility. ISO Standards are reviewed every five years so there will be an opportunity to improve or update it if necessary. Use it, and if you identify gaps in the present version, or areas for updating, be prepared to inform BSI when the review begins. References 1.
BS ISO 154 1548 89-1: Informati Information on and docume documentati ntation on – R ecords management – Part 1: General. BSI, 2001 and PD ISO/TR 15489-2: Information and documentation – Records management – Part 2: Guidelines. BSI, 2001.
2.
In descri describing bing the Standar Standar d’s d’s devel development opment I have have drawn on reports reports I prepared for BSI on successive meetings of ISO TC 46/SC 11. The view viewss express expressed ed in this th is articl ar ticlee are mine and not no t those t hose of BSI or m embers of IDT 2/17.
3.
AS 4390 4390:: R ec ecords ords manageme management nt – Parts 1-6 1-6.. Standar Standar ds Australia, Australia, 1996.
4.
Athens Ath ens was the first first of a seri series es of six six-monthly -monthly meeti meetings ngs in such such envi envi-able locations as Washington DC, Paris, Melbourne, Berlin and Stockholm.
5.
BS 5454 5454 R ecommendations commendations for the storage storage and exhibi exhibition tion of archival documents. BSI, 2000.
6.
Claus Clausees 1-3 are common to all all ISO Standards Standards
7.
D IR K S manual is is availabl availablee at www. www.naa.gov naa.gov.au/re .au/reccordkeeping ordkeeping/di /dirks/ rks/ dirksman/dirks.html [10 October 2001]
8.
ISO 512 ISO 5127 Part 1: 1: Docume Documentati ntation on and informati information on — Voc Vocabul abulary ary — Part 1: Basic concepts. ISO, 1983.
9
D raft Code of Practic Practicee on the disc discharge harge of the functions functions of public public authorities under Part I of the Freedom of Information Act 2000 available at http://www.lcd.gov.uk/foi/dftcp00.htm
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Author Susan Healy has worked in the Public Record Office since 1985, for much of that time in the Records Management Department. Before that she worked for ten years in the National Archives of Australia in Canberra. She chaired BSI IDT 2/17 2/17 and led led th e UK deleg delegation ation t o ISO T C 46/SC 46/SC 11 throughou t d evel evelopment opment of the Standard and Technical Report. Susan Healy, Head of Information Legislation Unit, Public Record Office, Public R ecord ecord Office, Offi ce, Kew, R ichmond, ichmond, Surre S urreyy T W 9 4DU. Email Em ail:: susan.he susan.healy@pro
[email protected] .gov.uk
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