U.S. federal agencies must address records and information management (RIM) concerns earlier in the information resources development process, ARMA International President Peter Kurilecz, IGP, CRM, wrote in a Nov. 19 letter to the U.S. Office of Management and Budget (OMB). Kurilecz’s letter was in response to proposed revisions to the federal government’s rules governing information management resources.
As reported in November’s Washington Policy Brief, the updates to “Circular A-130: Managing Information as a Strategic Resource” will be the first in 15 years, and they will cover a wide range of policy changes dealing with technology acquisition, records management, information governance, privacy, and data security.
“RIM has a very important role to play in helping agencies impose discipline and holistic information governance within agency information resources in order to ensure transparency, accountability, and accessibility, and to ultimately preserve government records and our national heritage,” Kurilecz wrote.
On behalf of ARMA International, Kurilecz proposed nine changes to the circular in an effort “to include records and information policies and practices within larger business and IT practices in a way that has not traditionally been considered within government practices and procedures.”
For example, as part of planning and maintaining an effective information strategy, ARMA International recommended the inclusion of safeguards for the accessibility, availability, and transfer of records when upgrading, replacing, or disposing of information systems.
“An ever-expanding challenge of data governance is to ensure that information assets are not inadvertently lost or made inaccessible as technology and systems evolve,” Kurilecz wrote. “Federal information should not be put at risk as a result of a change in information technology.”
Among the other key recommendations, ARMA International proposed that the senior agency official for records management be included in the list of agency leaders responsible for the planning, programming, and budgeting stages for programs that include IT resources.
ARMA International also recommended that agencies be required to assign “clear and documented roles and responsibilities to qualified personnel for the conduct of RIM processes.” This includes “the inclusion of information governance responsibilities in written job descriptions and in policies and procedures setting forth responsibilities and reporting chains, appropriate delegation of authority for transparency, and other records and information governance processes.”
The public comment period on the proposed guidance was originally due to close on November 20, but it was extended to December 5. OMB said it plans to analyze the submitted feedback and revise the policy as necessary.