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Opportunity for Comment: NARA Bulletin on Managing Social Media Records

by on June 26, 2013


We are requesting comments on a draft of an upcoming NARA Bulletin on Managing Social Media Records.

This draft Bulletin will supersede NARA Bulletin 2011-02: Guidance on Managing Records in Web 2.0/Social Media Platforms and provides high-level requirements and best practices for capturing records created when agencies use social media. This use may result in the creation of Federal records that must be captured and managed in compliance with laws, regulations, and policies.

Please post your comments about this draft Bulletin (.pdf) by July 12. If you prefer to send your comments via email, direct those to jill.snyder@nara.gov.

Thank you for your input!


Comments

Bruce Bailey June 27, 2013 at 8:22 am

I do not see guidance on multiple copies of record material. If the content of s third party provider is deemed a federal record, you give guidance on “exporting” and “capturing” that material to be managed in an appropriate manner. However, what is the status of the same material which may be held by the provider for their own purposes under different management policies and procedures?
You are allowing agencies to create or identify federal records, if temporary record copies are dispositioned under an accepted retention schedule and destroyed/deleted what is the legal status of copies held by the third party or even another agency (see Twitter)? If an agency deems material as a federal record and disposes of it in an appropriate manner, but the copy held by a third party can be used against the agency in litigation or other such adversarial situations, then is the agency not putting itself in harm’s way by merely defining content as a federal record, in a place where it does not have complete control?

Jesse Wilkins, CIP, CRM July 10, 2013 at 11:56 am

Agree with Bruce’s comments. The other major issue I noted was with regards to Section 8 on agency responsibilities when dealing with SM services. The paragraph that begins with this statement, “If the provider can export a complete record, the agency should include a clause in the Terms of Service agreement that stipulates how and when this will occur.”, might work at the US Federal Government level as a whole, as was the case with e.g. Canada regarding privacy, but individual agencies are not going to be successful in negotiating their own Terms with e.g. Facebook.

This guidance has been promulgated elsewhere by other records authorities and associations and it is simply not realistic. That entire section, and the related guidance I referred to, is predicated on the assumption that commercial social media services operate substantially the same as hosted or outsourced services. This is not the case; Facebook provides social media services to an estimated 1.1 billion users world-wide and its terms are of necessity broadly applicable rather than readily tailored to the needs of hundreds of jurisdictions, agencies, and the like.

A better approach would be to ensure that agencies understand the Terms of Service and the ramifications to the records program and take appropriate steps to address them.

Regards,

Jesse Wilkins, CIP, CRM
Director, Research & Development
AIIM International
jwilkins@aiim.org

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