Archives and Museum Informatics 11: 259–260, 1997. 259c 1997 Kluwer Academic Publishers. Printed in the Netherlands.

Developing Policy Frameworks: Commentary

In commenting on the discussion, I have been asked to consider not only whathas been said, but what in my view should have been said, but was not. Frommy perspective, that is a good thing. It seemed that the major agreement at theWorking Session on Developing Policy Frameworks centered around the ideathat “development” should be thrust into the background, and the focus put onimplementation. Or, as I heard it said, there is a time for research and a timefor doing, and now is the time for the latter! So, reporting only what was saidconcerning the assigned topic would make for a very short presentation.

The speakers addressed the development of policy frameworks at very differentlevels of granularity. Luisa Moscato spoke of a high level effort to develop a newrecord keeping regime for the whole of the public sector of New South Wales.Peter Horsman described for us the very focused effort to develop and implementan electronic records system for the Dutch Parliament. Greg O’Shea provided thereality check, reminding us – with biblical emphasis – that research is not an endin itself, but must provide concrete outcomes. He also proposed that the “problem”created by electronic records is not technological, but strategic, Thus, the mainissue is development of a strategic approach to record keeping – whether it be insociety generally, whole of government, or in one’s own corporate environment.

The discussion seemed to mainly pick up on Greg’s point that policy andstrategy are fine, but that without implementation they are not worth very much. Aconsistent theme was that research should be done to examine policies already inplace – assessing what works and what does not work, with a view to identifying“best practices”. A deep frustration – and I would say also impatience – withthe research done up until now was expressed. Participants seemed to agree thatthe focus should be on the consensus that has emerged from the research – notthe differences (which have tended to capture the spotlight, but which are seenby many to be irrelevant to the practicing archivist faced with actually doingsomething). One might conclude that there is a need to develop, on the basis ofexisting consensus, a policy framework for the profession itself. While there hasbeen some work done along these lines, for example the ICA Electronic RecordsCommittee Guide, it would seem that more is needed.

Thus, at least two areas for future research are clearly indicated, namely: (1) anexamination of what has worked and what has not worked in the policy framework

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area; and (2) an effort to consolidate existing research into some agreed guidelinesthat could be used to underlie policy frameworks at all levels. Other points I heardmade in the context of the discussion on developing policy frameworks related to:1. The need to consider how record keeping policies should be positioned with-

in the broader context, including whether they should be “stand alone”, orincorporated into broader policies or enabling legislation;

2. The need to develop models appropriate for record keeping, and the importanceof informing such efforts with work done in other professions; and

3. The need to improve training, including issues associated with a growing needfor an archival “superperson”.

Concerning what I did not hear, I would note the following points. Firstly, I foundit curious – particularly in light of the papers presented – that the discussion did notfocus on issues associated with the optimum level at which policy frameworks canand should be developed to ensure electronic accountability and integrity of records.Should these issues be addressed at the organizational, societal and legal systemlevels simultaneously, or are there strategic considerations that would lead to a focusin one area or another? Secondly, there was no focus on what may be the proper roleof systems design, implementation strategies and standards – all of which couldserve as alternatives to policy development as a tool for implementing electronicrecord keeping. Did participants agree that policy development provides the bestchance for success? Thirdly, it was surprising to hear no mention of the challengespresented to policy development by “new” forms of records such as e-mail andthe WWW. Do these present unique challenges to policy development? Finally,I would have expected more discussion concerning costs versus benefits. This isa key matter from the practitioner’s viewpoint, and can often be the determiningfactor as to whether or not policies are implemented.

GERTRUDE LONGInternational Monetary Fund,

Washington, DC, USA

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