Feedback on Exposure Draft of the Standard for Electronic Recordkeeping Systems (30 June 2004)

This comment on the Exposure draft of the Standard for Electronic Recordkeeping Systems is submitted on behalf of the Archives and Records Association of NZ Council.
 
The standard represents an extremely useful addition to the toolkit of record-keeping professionals in New Zealand.  By setting out an authoritative standard for evaluating electronic recordkeeping systems, it will provide support to those looking to implement such systems, giving them a level of confidence that they have considered all the appropriate aspects.  It will assist them in discussions with the IT industry by providing an objective, respected benchmark against which to evaluate systems. Having a public, authoritative NZ standard should also assist the IT industry, who will know in advance the expectations their systems will be required to meet.

On the whole, the format of the standard is clear and easy to follow.  The division of the requirements into "shoulds" and "musts" is useful.  The standard should, however, be very careful about putting certain requirements into the MUST category if the standard is to become mandatory and agencies to be audited on compliance.
 
Even if the standard is not mandatory, some items appear to be in the wrong category.  For instance:

• [Page 26, 4.10] Under the MUST category here there is a requirement to log all unauthorised attempts to access  aggregations.  This presumably assumes that the security model may not prevent unauthorised access, otherwise it is not clear why all unauthorised access attempts must be logged, when many could be accidental.
• [Page 34, 6.6] Under the MUST category is the requirement "to control and record access to non-electronic aggregations . . . which are comparable to the features for electronic aggregations ".  Given that, in many environments, it would be virtually impossible to control access to non-electronic records to the same extent as the electronic because they are physical, movable objects outside the system, we would encourage re-examination of this item.

The text is supported by good examples or explanations where appropriate, although one or two could usefully be added to explain such terms as "agency retention period" [page 30, 5.6] which may not be clear to those not working in the archives field.
While the English in which it is written is not always 'plain', once the document has been carefully edited to pick up typographical and grammatical errors and complete sentences where currently the meaning has to be deduced (e.g. page 26, 4.18 "re-classification of an electronic file aggregation the classification scheme"), we are sure it will be relatively easily read and understood by those would find it a useful tool.

Joanna Newman
on behalf of Archives and Records Association of New Zealand
30 June 2004