Electronic Recordkeeping

Functional Requirements for Evidence in Recordkeeping:  Further Developments at the University of Pittsburgh

As this issue of the Bulletin documents, many organizations worldwide are using the requirements in the development of standards, policies, procedures and systems. However, we at the University of Pittsburgh are also continuing our efforts to support, refine and extend them. To demonstrate its commitment to furthering research in the area of electronic records, the University of Pittsburgh authorized the creation of the Center for Electronic Recordkeeping and Archival Research (CERAR) at the School of Information Sciences earlier this year.

CERAR

The Center (http://www.sis.pitt.edu/~cerar) evolved as a result of the overwhelming successes of the Functional Requirements project. Just as the Functional Requirements evolved as an interdisciplinary research project engaging both the Department of Library and Information Science (DLIS) and the Department of Information Science and Telecommunications (DIST), so, too, CERAR is carrying on this tradition. Under the directorship of Richard Cox, associate professor in the DLIS, and Kenneth Sochats, assistant professor in the DIST, CERAR's mission is to provide leadership by promoting research in all aspects of electronic records systems and fostering implementation of the results of that research. Through research, education, publication, lectures, workshops, consulting and networking, CERAR aims to support information professionals, individuals with recordkeeping responsibilities and other stakeholders concerned with recordkeeping issues. Although officially established at the university, CERAR is dependent on outside funding and is actively investigating research opportunities.

CERAR hopes to explore questions such as the following, either on its own or in partnership with others:

• Are there other sets of functional requirements that need to be identified? For example, is there a difference between the functional requirements for evidence and those for accountability or organizational memory?
• As a meta standard, how does the metadata model relate to other standards, such as ISO 9000?
• With regard to legacy systems, is metadata mining really possible and how effective is the metadata model in aiding in this process?
• Does a functional, as opposed to structural, approach run counter to organizations?
• What strategic opportunities are being missed that organizations may be able to take advantage of in terms of implementing the Functional Requirements?

Refining the Application of the Requirements

One example of research to refine the application of the Functional Requirements and their resulting metadata involves the construction of a matrix approach to implementing the requirements. The project is being carried out by a CERAR staff member, although no CERAR funding has been required. Perhaps one of the most frequently asked questions with regard to implementing the framework is the extent to which the Functional Requirements must be met. It may be misconception to believe that all the requirements must be fulfilled for all record types in all contexts in order for something to be considered a record. Instead, it may be more realistic to assume that there are a variety of factors that affect the degree to which the requirements need to be met. Specifically, does the business process from which the transaction derives and the organizational context of the process itself influence the extent to which each requirement must be satisfied?

Recently, David Bearman and the author conducted a thought experiment that resulted in the construction of a matrix to visualize how each of the Functional Requirements is affected by similar business processes carried out within different organizational contexts. It is our hope that such an approach, once it is further refined, will make the requirements easier to apply.

The matrix represents an intellectual exercise using four generalized business processes in four different organizational contexts. For example, the inventory control process may be carried out in a variety of contexts, such as a retail sales company, a public service organization, a public utility or a research and development environment. It is evident that the role of inventory control is not equally important within each type of organization.

In a public service organization, for instance, the process may only manage such things as office supplies and forms. Records reflecting this function are therefore not likely to require or justify the same level of care to preserve their evidentiary value as might be the case for mission critical systems. This does not mean that the Functional Requirements should not be applied to records reflecting this process in this context, rather that there is no need to satisfy the requirements to any unusually high degree.

By contrast, in a public utility, such as a nuclear power plant, inventory control is much more important. Major issues of health or national security may be involved. As failure to maintain records properly carries much stronger implications, the recordkeeping system should adhere more strictly to the Functional Requirements. It is hoped that the matrix will help enable users, faced with the regulatory environments within which they operate, to evaluate the degree to which they need to implement the various requirements to manage their business risk.

Conclusion

The University of Pittsburgh, through the Department of Library and Information Science, the Department of Information Science and Telecommunications and the newly founded Center for Electronic Recordkeeping and Archival Research, is continuing to support ongoing projects revolving around the Functional Requirements and other related issues. We look forward to continuing our productive partnerships with other academic centers, government bodies and organizations to meet the challenge of managing electronic records. Through reaching out and partnering with other stakeholders, CERAR hopes to create research opportunities that will engage a variety of disciplines in addressing the need to define the skills required by a new kind of information professional, who will be equipped to manage the technology in a manner that will protect and enhance the value of records essential for the corporate memory, evidence and accountability of modern organizations.

General Category: Records: Captured
6. Identifiable: Records must be bounded by linkage to a transaction which used all the data in the record and only that data.

6a. There exists a discrete record, representing the sum of all data associated with a business transaction.

6b. All data in the record belongs to the same transaction.

6c. Each record is uniquely identified.

Literary Warrant for Functional Requirement #6
This requirement derives from the law, customs, standards and professional best practices accepted by society and codified in the literature of different professions concerned with records and recordkeeping. The warrant is as follows:

Citation American Institute of Certified Public Accountants. Statements on Auditing Standards 55.

Consideration of the Internal Control Structure in a Financial Statement Audit

Pages 10

Extract The accounting system consists of the methods and records established to identify, assemble, analyze, classify, record and report an entity's transaction and to maintain accountability for the related assets and liabilities. An effective accounting system gives appropriate consideration to establishing methods and records that will identify and record all valid transactions.

Citation EDI Security, Control, and Audit by Albert J. Marcella, Jr., and Sally Chan (Massachusetts: Artech House 1993)

Pages 97

Extract

1. The basic document must contain all the components that together constitute legally acceptable evidence of a completed action.

2. The documented proof of completed business transactions must be created, processed and retained to comply with corporate policy and business practice and with external statutory and regulatory needs.

Citation "Open Document Architecture (ODA) Raster Document Application Profile (DAP)" Category: Software Standard; Subcategory: Graphics. Federal Information Processing Standards Publication 194 (U.S. Department of Commerce/Technology Administration and National Institute of Standards and Technology, 13 March 1995)

Pages 14

Extract Every document interchanged in accordance with the ISP must include a document profile containing information which relates to the document as a whole.

Citation 21 CFR Sec. 1304 .02 Definitions

Extract The term readily retrievable means that certain records are kept by automatic data processing systems or other electronic or mechanized recordkeeping systems in such a manner that they can be separated out from all other records in a reasonable time and/or records are kept on which certain items are asterisked, redlined or in some other manner visually identifiable apart from other items appearing on the records.

Metadata for Functional Requirement #6

V.A.2. Content-Incorporated [Optional*]

Contains identifiers of records incorporated into the content or the actual data contained in these records.

I.A.2. Transaction-Domain-Identifier [Mandatory]

Uniquely identifies the domain from which the record originated with sufficient specificity to identify the transaction type and the organization responsible.

I.A.3. Transaction-Instance-Identifier [Mandatory]

Uniquely identifies a transaction instance with date, time and necessary sequence identifiers.

III.A.1. File-ID [Mandatory]

Identifies each file that makes up the record. This affords the ability for the system to bring together all of the parts to form the whole.

Production Rule for Functional Requirement # 6

<RECORDS Identifiable (6.0) :

<Equal Identifier(RECORD)  Identifier(TRANSACTION)>(6.0a)
<RECORD Unique> (6.0b)