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mission statement or mandate – and formal regulatory requirements such as policies and procedures that define TDR operations, providing the TDR with the formal parameters for preserving digital records. In order to assess whether or not this assumption in the standards is true, the regulatory requirements of OAIS and RAC are analysed below. Table 5.1 provides an overview of the relevant regulatory requirements in OAIS and RAC, which are then discussed in more detail.

TABLE 5.1: SELECTED OAIS AND RAC REQUIREMENTS PERTAINING TO REMIT AND REGULATORY FRAMEWORK³⁸⁸ with its charter and scope. The charter may be developed by the archives but it is important that Management formally endorse archive activities.’ (2-9)

Management should also support the OAIS in establishing procedures to regulate the TDR’s operation and ensure that the repository is

properly used and engaged by Producers as well as Consumers. (2-9)

At a very basic level, the definition of a TDR must start with ‘a mission to provide reliable, long-term access to managed digital resources to its Designated Community.’(19) 3.1.1. The repository shall have a mission statement that reflects a commitment for the preservation of, long term retention of, and access to digital information. (21)

OAIS offers a more high-level conceptual framework for TDR operations than RAC. It is therefore quite general in its stipulations concerning remit and regulatory framework, only requiring some level of management support for the digital repository. The RAC requirements are much more precise, requiring, for example, a specific mission statement that explicitly or implicitly calls for the preservation of information.³⁸⁹ Yet there is no guidance in either standard on how to assess the adequacy of a remit. This is

388 Page references for OAIS are based on the section numbering provided in the 2012 standard. For RAC it is based on the pagination of the BSI version of the standards.

389 TC20/SC 13, ‘Audit and Certification of Trustworthy Digital Repositories’., 21.

left to the judgment of the institution during a self-assessment and to the auditor during accreditation. As stated in Section 1.6 of RAC: ‘Conformance to these metrics, as with all other such standards, is a matter of judgment’.³⁹⁰ In the next section we will examine the applicability of the OAIS and RAC requirements for remit, in order to understand the realities of applying these standards.

5.2.1.2 Remit and Regulatory Framework in Practice

Three of the case study repositories have formal responsibility for the care and

management of digital public records within their respective jurisdictions. These remits are detailed in their enabling legislation: The Archives Act 1994 (National Archives of Finland), the Archives Act 1992 (National Archives of Norway) and RCW 40.14

Preservation and Destruction of Public Records (Washington State Digital Archives). The UK Public Records Act 1958 (The National Archives) does not specifically identify digital records in its legislation, but it does interpret ‘records’ to include ‘not only written records but records conveying information by any other means whatsoever’. ³⁹¹

At first glance the format of a public record does not seem problematic given that RAC stipulates that a remit may be implied, not explicit. There is disagreement among standards developers on this point, however. During the testing of RAC, some test sites were disqualified by RAC developers because they did not have a clearly articulated remit in place that tasked them with responsibility for the long-term preservation of digital records.

[A]ctually the only place in our list that had a true mission out of those five/six places we went to that had a true mission as an archives, a long-term archive was [names institution] […] the other ones were all data centres and the way their mission was written was they were serving the scientists, […] but it was much more in the present. Now they all thought they were a long-term repository […]

390 TC20/SC13, ‘Audit and Certification of Trustworthy Digital Repositories’., 18.

391 Government of the United Kingdom, Public Records Act, 1958. Section 1(1) and Section 10 (1), respectively.

and that it was their mission and when you looked at the actual mission

statement it wasn’t and then when it isn’t you have to look at whoever they are answering to what are they thinking.³⁹²

The question becomes, what constitutes an authoritative remit for OAIS and RAC, especially since RAC states that remit can be implied? A lack of clarity about what comprises remit may exclude organisations like TNA from becoming TDRs. Although having a remit is an important element in managing an archival organisation or a TDR, it should not be a required metric for evaluating repository operations; after all, remits, like policies and procedures or laws, can be created but sometimes they cannot be enforced.³⁹³ The ambiguity of the concept of remit becomes quite problematic, especially as an articulated remit, in the form of a mission statement, mandate or charter, is supposed to serve as the foundational document for TDR operations.

Both OAIS and RAC have a limited definition of remit and neither standard includes substantive discussion on the role or impact of recordkeeping on the integrity of digital records or on their preservation. The standards simply provide a reference to ISO 15489.³⁹⁴ However, the consensus in the archival profession is that archivists need to advise on the management of digital records from the point of creation to transfer in order to help protect the integrity of the records.

However clearly their remit is articulated, all the case study institutions do have a role in either advising or directly influencing digital records management. The different legislation in each jurisdiction allows varying degrees of archival control over

392 Interview 21, 19 October 2012

393 International Records Management Trust, ‘Managing Records as Reliable Evidence for ICT/ E-Government and Freedom of Information in East Africa- Uganda Country Report’ (International Records Management Trust, September 2011), accessed 10 September 2013, http://irmt.org/portfolio/managing-records-reliable-evidence-ict-e-government-freedom-information-east-africa-2010-%E2%80%93-2011. In Uganda, an FOI law was developed in order to meet international donor requirements, however it was not enforced by the government and thus has not had any effect on citizen access to information or freedom of information in the country.

394 TC20/SC13, ‘Open Archival Information System- - A Reference Model.’, 1-5, TC20/SC 13, ‘Audit and Certification of Trustworthy Digital Repositories.’, 83.

recordkeeping. Two specific approaches to recordkeeping control – direct and indirect – were examined as part of this thesis research.

The direct method is exemplified in Norway and Finland, where both national archives have issued functional requirement standards to control the creation of digital records in information management systems.³⁹⁵ These functional requirements for recordkeeping systems – known as SÄHKE in Finland and NOARK in Norway – provide specifications for systems designers and vendors on the design of information

management systems. These requirements dictate the types of security measures, metadata requirements and other digital information documentation elements that must exist in order for government information systems to produce digital records that have integrity and authority. Vendors in Norway and Finland are required to adhere to these standards before they can market their information management software to government ministries and departments.³⁹⁶

As the digital archivist for the National Archives of Finland stated: ‘Typically in these [information management] systems we have strict functional requirements for records management systems [and] what kind of functionalities they should have in the process to produce those strictly defined metadata elements’.³⁹⁷ Of the two standards, NOARK is the older, having been put into practice at the National Archives in the 1980s.³⁹⁸ Mandatory compliance with NOARK and SÄHKE is recent, however, dating from 1999 (NOARK) and 2006 (SÄHKE).³⁹⁹

395 Interview 13. 21 September 2012 and Interview 14, 17 February 2013.

396 Interview 13, 21 September 2012. Interview 14, 17 February 2013. See also for Norway: National Archives Service of Norway, ‘NOARK 5’., 9.

397 Interview 13, 21 September 2012

398 Interview 14, 17 February 2013. Initially NOARK was intended to govern the operations of electronic registry systems particularly the police registry systems and statistical programmes.

399 National Archives Service of Norway, ‘NOARK 5.’., 9.Henttonen, ‘Creating Recordkeeping Metadata’., 71Pekka Henttonen, ‘A Comparison of MoReq and SAHKE Metadata and Functional Requirement Standards’, Records

The direct methods used in Norway and Finland to control digital records production, and thereby help guarantee a record’s integrity, may not be feasible for all institutions, but the approach does create a closer link between archival management and the processes of records creation and production. A further advantage in these Nordic models is that compliance by software vendors is mandatory, guaranteeing, to some extent, a standardised method for creating records and metadata.

The indirect approach to recordkeeping control can be seen in WSDA and TNA. The statute governing archives and records management services in the State of Washington assigns functions and powers to the state archives, but digital preservation and records management sit in two separate departments within the institution. In practice, the departments work closely together, and the strength of the relationship between the digital repository and the electronic records management unit helps to ensure that the integrity of digital information is maintained.⁴⁰⁰ As the WSDA Digital Archivist noted, the relationship between records manager and archivist is important: ‘I’m concerned with all archival records but with electronic I like to be involved from the beginning, from

creation, so that we make sure that they’re being arranged and managed in a manner that will make it easy to transfer them to the archives.’⁴⁰¹

At The UK National Archives (TNA), the Information Management and Practice Division provides advice and guidance to government departments on records

management and records transfers. Traditionally, departments have transferred records to TNA after 20 years, and the long gap between records creation and preservation

Management Journal 19, no. 1 (2009): 26–37., 26.

400 Interview 3. 18 and 19 July 2011.

401 Interview 3, 18 and 19 July 2011.

raised the risk that digital records might be lost over time.⁴⁰² In order to address the preservation of digital records prior to transfer, TNA developed the Digital Continuity programme,⁴⁰³ which involves sending an information management consultant (IMC) to work with departments to help develop digital continuity plans and to ascertain whether the proper measures are in place to guarantee the continued accessibility to and

integrity of records until they come into the custody and control of the archives.⁴⁰⁴ In a few instances digital records are slated for immediate transfer to the archives, such as, in the TNA, with records of special commissions like the Leveson Inquiry on ethics and practices in the British media or special events such as the 2012 Olympics.⁴⁰⁵ Unlike Norway or Finland, though, neither TNA nor WDSA have the statutory capabilities to compel compliance with any recordkeeping standards. Instead they must rely on the more indirect methods of guidance and persuasion to help ensure digital records are adequately managed.

Direct and indirect control over digital records management have different consequences, particularly when it comes to the transfer of records into digital

repositories. The lack of a connection between the definition of remit and the need for recordkeeping controls to ensure the integrity of digital records may result in records lacking in authenticity and reliability. This oversight may stem from the origins of TDR

402 In August 2013, TNA announced that it was changing its legislated transfer dates from 30 years to 20 years. See the following press release for more information: National Archives of the UK, ‘Files from 1983 Released as 20-Year Rule Transition Begins | The National Archives’, accessed 12 February 2015,

http://www.nationalarchives.gov.uk/news/866.htm.

403 Interview 10, 10 October 2011 and Interview 11, 14 September 2012. See also: National Archives of the UK, ‘Digital Continuity Service | The National Archives’, Digital Continuity Service, accessed 2 December 2013,

http://www.nationalarchives.gov.uk/information-management/our-services/digital-continuity.htm.

404 Interview 10, 10 October 2011 and Interview 11, 14 September 2012

405 National Archives of the UK, ‘Inquiry into the Culture, Practices and Ethics of the Press (Leveson Inquiry): Transcripts and Evidence’, digital record(s), (2012 2011), LEV 2, The National Archives, Kew. National Archives of the UK,

‘London Organising Committee of the Olympic and Paralympics Games: Publications’, file(s), (2012 2004), LOC 6, The National Archives, Kew.

standards in the space data community, which was primarily concerned with the preservation of mission data not with the management of that data prior to ingest.

The existence of a formal remit – such as enabling legislation with clear

articulation of digital records management – can have a major effect on the capabilities of case study repositories to influence digital records management, thus influencing the design and capabilities of digital repositories. OAIS and RAC use the existence of a remit as the first authoritative metric for measuring whether a repository can be considered

‘trusted,’ but as demonstrated in this section, there are ambiguities with the concept and application of a remit. Is simply having a high-level remit sufficient to qualify a repository for certification? What constitutes a certifiable remit? These points are not made clear in either standard, thus making it difficult to measure success accurately.