This post is authored by James A. Jacobs, Librarian Emeritus, University of California San Diego &
James R. Jacobs, Federal Government Information Librarian, Stanford University.
This moment in history provides us with a rare opportunity to go beyond short-term data rescue and set the much needed foundation for the long-term future of preservation of government information.
Awareness of risk. At the moment, more people than ever are aware of the risk of relying solely on the government to preserve its own information. This was not true even six months ago. This awareness goes far beyond government information librarians and archivists. It includes the communities that use government information (our Designated Communities!) and the government employees who devote their careers to creating this information. It includes our colleagues, our professional organizations, and library managers.
This awareness is documented in the many stories in the popular press this year about massive “data rescue” projects drawing literally hundreds of volunteers. It is also demonstrated by the number of people nominating seeds (URLs) for the current End of Term harvest and the number of seeds nominated. These have increased by nearly an order of magnitude or more over 2012.
Awareness of need for planning. But beyond the numbers, more people are learning first-hand that rescuing information at the end of its life-cycle can be difficult, incomplete, and subject to error and even loss. It is clear that last minute rescue is essential in early 2017. But it is also clear that, in the future, efficient and effective preservation requires planning. This means that government agencies need to plan for the preservation of their own information and they need to do so at the beginning of the life-cycle of that information — even before it is actually created.
Opportunity to create demonstrable value. This awareness provides libraries with the opportunity to lead a movement to change government information policies that affect long-term preservation of and access to government information. By promoting this change, libraries will be laying the groundwork for the long-term preservation of information that their communities value highly. This provides an exceptional opportunity to work with motivated and inspired user communities toward a common goal. This is good news at a time when librarians are eager to demonstrate the value of libraries.
A model exists. And there is more good news. The model for a long-term government information policy not only exists, but libraries are already very familiar with it. In 2010, federal granting agencies like NSF, National Institutes of Health and Department of Energy started requiring researchers who receive Federal grants to develop Data Management Plans (DMPs) for the data collected and analyzed during the research process. Thus, data gathered at government expense by researchers must have a Plan to archive that data and make it available to other researchers. The requirements for DMPs have driven a small revolution of data management in libraries.
Ironically, there is no similar requirement for government agencies to develop a plan for the long-term management of information they gather and produce. There are, of course, a variety of requirements for managing government “Records” but there are several problems with the existing regulations.
Gaps in existing regulations. The Federal Records Act and related laws and regulations cover only a portion of the huge amount of information gathered and created by the government. In the past, it was relatively easy to distinguish between “publications” and “Records” but, in the age of digital information, databases, and transactional e-government it is much more difficult to do so. Official executive agency “Records Schedules,” which are approved by the National Archives and Records Administration (NARA), define only a subset of information gathered and created by an agency as Records suitable for deposit with NARA. (It must be noted that NARA cannot guarantee that it will provide online access to even born-digital Records deposited with it.) Further, the implementation of those Records Schedules are subject to interpretation by executive agency political appointees who may not always have preservation as their highest priority. This can make huge swaths of valuable information ineligible for deposit with NARA as Records.
Government data, documents, and publications that are not deemed official Records have no long-term preservation plan at all. In the paper-and-ink world, many agency publications that did not qualify as Records were printed by or sent to the Government Publishing Office (GPO) and deposited in Federal Depository Library Program (FDLP) libraries around the country (currently 1,147 libraries). Unfortunately, a perfect storm of policies and procedures has blocked FDLP libraries from preserving this huge class of government information. A 1983 court decision (INS v. Chadha, 462 U.S. 919, 952) makes it impossible to require agencies to deposit documents with the Government Publishing Office (GPO) or FDLP. The 1980 Paperwork Reduction Act (44 U.S.C. §§ 3501–3521) and the Office of Management and budget (OMB)’s Circular A-130 have made it more difficult to distribute government information to FDLP libraries. The shift to born-digital information has decentralized publishing and distribution, and virtually eliminated best practices of meta-data creation and standardization. GPO’s own Dissemination and Distribution Policy has further (and severely) limited the information it will distribute to FDLP libraries. Together, this “perfect storm” has reduced the deposit of this class of at-risk government information into FDLP libraries by ninety percent over the last twenty years.
The Solution: Information Management Plans. To plug the gaps in existing regulations, government agencies should be required to treat their own information with as much care as data gathered by researchers with government funding. What is needed is a new regulation that requires agencies to have Information Management Plans (IMPs) for all the information they collect, aggregate, and create.
We have proposed to the OMB a modification to their policy OMB Circular A-130: Managing Information as a Strategic Resource that would require every government agency to have an Information Management Plan.
Every government agency must have an “Information Management Plan” for the information it creates, collects, processes, or disseminates. The Information Management Plan must specify how the agency’s public information will be preserved for the long-term including its final deposit in a reputable, trusted, government (e.g., NARA, GPO, etc.) and/or non-government digital repository to guarantee free public access to it.
Many Benefits! We believe that such a requirement would provide many benefits for agencies, libraries, archives, and the general public. We think it would do more to enhance long-term public access to government information than changes to Title 44 of the US Code (which codified the “free use of government publications”) could do.
- It would make it possible to preserve information continuously without the need for hasty last-minute rescue efforts.
- It would make it easier to identify and select information and preserve it outside of government control.
- It would result in digital objects that are easier to preserve accurately and securely.
- It would make it easy for government agencies to collaborate with digital repositories and designated communities outside the government for the long-term preservation of their information.
- The scale of the resulting digital preservation infrastructure would provide an easy path for shared Succession Plans for Trusted Digital Repositories (TDRs) (Audit And Certification Of Trustworthy Digital Repositories [ISO Standard 16363]).
IMPs would provide these benefits through the practical response of vendors that provide software to government agencies. Those vendors would have an enormous market for flexible software solutions for the creation of digital government information and records that fit the different needs of different agencies for database management, document creation, content management systems, email, and so forth, while, at the same time, making it easy for agencies to output preservable digital objects and an accurate inventory of them ready for deposit as Submission Information Packages (SIPs) into TDRs.
We believe this is a reasonable suggestion with a good precedent (the DMPs), but we would appreciate hearing your opinions. Is A‑130 the best target for such a regulation? What is the best way to propose, promote, and obtain such a new policy? What is the best wording for such a proposed policy?
We believe we have a singular opportunity of awareness and support for the preservation of government information. We believe that this is an opportunity, not just to preserve government information, but also to demonstrate the leadership of librarians and archivists and the value of libraries and archives.
(This is the second of two posts about setting long-term goals. The first post is A Long-Term Goal For Creating A Digital Government-Information Library Infrastructure.)
James A. Jacobs, Librarian Emeritus, University of California San Diego
James R. Jacobs, Federal Government Information Librarian, Stanford University