A Game of M-19-21 Permanent Records Conkers, Anyone?

I suppose everyone had their own particular permanent records distraction that they used to survive COVID. I tried bread-making and baking for a while, but the tell-tale COVID version of the “freshman-15” killed that idea. My wife suggested that we try puzzles, but my staying power for a puzzle is about five minutes, after which I wind up forcing pieces together that clearly have no business being in even remote proximity to each other.

Back before the winter surge, CNN even put together a list of 50 fun things to do in the fall (take your pick), which I personally feel included some highly questionable items. For example…

#5. Build a bonfire. (Probably illegal here in Fairfax County, VA.)

#22. Make leaf placemats. (Uhhh, nope. Think of the bugs.)

#36. Gather chestnuts to play Conkers. (I have spent 65 years not playing Conkers, whatever that is, and don’t think I’ll start now.)

The thing we actually DID wind up doing was binging on a LOT of mystery shows and movies. (The connection to M-19-21, you ask? Wait for it…)

I wish we had kept track of the number of times a records room or an archive featured prominently in the outcome of one of these mysteries. Each time I would I jam my wife in the ribs and said, “See! Another records management plot twist!” Countless times.

Sometimes the archive would resemble the view from that last scene in Indiana Jones and the Raiders of the Lost Ark. Other times, the archive would be a much more pedestrian records room, almost inevitably located in the basement, even in Sponge Bob. In researching this piece I came across a British show with a records manager as the heroineLove, Lies and Records. With a plot summary like this – “Registrar Kate Dickinson tries to balance her personal life with the daily dramas of births, deaths and marriages and the impact they have upon her and her staff at the local Register Office in Leeds” – it is shocking that it only lasted one season. But it is now on my watch list for the next time we log in for one of those “7-day free trials” of Acorn TV (To ponder….can an acorn also be a Conker?)

Indiana Jones, Sponge Bob, Love, Lies and Records

The point here is that Records matter. Archives matter. They are the central means by which a society documents the who, what, when, where, and how of everyday lives and how organizational decisions are made for future generations. It’s what M-19-21 is all about.

But unlike the archives and records rooms in so many movies and television shows, we can no longer assume that stockpiling boxes and boxes of paper will suffice. For one thing, there’s just too much of it. It’s also too hard to find things. And most importantly, as the vast volume of records shifts from paper to electronic, the LAST thing we should be doing is printing out paper to facilitate records management.

All of this is particularly challenging with records destined for PERMANENT ascension to NARA, which are the subject of a new pending rule-making to amend 36 CFR part 1236, Electronic Records Management, establishing standards for digitizing PERMANENT paper and photographic records, including paper and photographs contained in mixed-media records. “We are proposing to amend our electronic records management regulations to add a subpart containing standards for digitizing permanent Federal records so that agencies may dispose of the original source records, where appropriate and in accordance with the Federal Records Act amendments of 2014…”

This rule-making covers only permanent records, which are a relatively small portion of all of the records covered by M-19-21. PERMANENT records, as defined by 36 CFR §1220.18, are those for which the disposition “is deemed permanent on NARA’s standardized records management form. The term includes all records accessioned into NARA and any federal record that has been determined by NARA to have sufficient value to warrant its preservation in NARA—even while it remains in agency custody.”

  • The standards in the proposed rule-making — essentially calling for FADGI 3-Star image quality levels — apply retroactively to digitized permanent records that have not been transferred to the National Archives.
  • If agencies determine their previously digitized records are not in compliance with these standards, re-digitizing may be necessary.

If agencies can’t meet the new proposed standards for permanent records there are three options…

  1. Send the paper versions of the permanent records for storage to NARA’s Federal records centers by December 31, 2022;
  2. Work with NARA to develop an agency-specific records schedule that addresses the previously digitized records, providing authority to transfer the electronic records to NARA and destroy the original source records (this option is available if NARA determines the previously digitized records are acceptable permanent records, even if the scanned versions were digitized to standards that differ from the ones in this regulation); or
  3. Request an exception as part of the agency’s strategic response to meeting the OMB/NARA Memorandum M–19– 21 goals.

Action Items:

  1. Click HERE for a video I created outlining the key new proposed digitization standards for permanent records.
  2. Click HERE for a special backgrounder on FADGI Digitization Standards and what they mean.
#NARACompliance #M-19-21