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Proceedings of the XXXVth International Conference of the Round Table on Archives Reykjavik, Iceland, 10-13 October 2001

Actes de la XXXVe Confrence internationale de la Table ronde des Archives Reykjavik, Islande, 10-13 octobre 2001

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The Functional Approach to Appraisal the Experience of the National Archives of Australia
Why adopt a functional approach to appraisal?
In April 2000 the National Archives of Australia formally adopted a functional approach to appraisal with the launch of the e-permanence campaign. As part of this campaign the Archives issued a range of standards, tools and guidelines, with a focus on recordkeeping, for the use of federal government agencies. Our most recent e-permanence publication is a booklet (Overhead 1) for managers in federal government agencies that sets out the main tasks in the strategic management of records and information and the tools available from the Archives to assist in undertaking the task. So, after fifty years of established appraisal practice what were the key drivers for adopting a functional approach? There were three significant considerations: firstly, evidence that our existing appraisal regime which was records based was ill equipped to deal with the far broader range of recordkeping media in existence in the electronic environment; secondly, the realization that our previous approach to appraisal had resulted in the retention of large quantities of records. Extrapolation of this demonstrated that it would be beyond our capacity to preserve and make accessible records selected as archives; and thirdly, an expectation that appraisal decisions based on functions would be easier to apply by staff in federal government agencies because the link to their administrative context would be clearer. The phrase functional appraisal is a broad intellectual umbrella. The National Archives is conscious that the Australian, Canadian and Dutch approaches while sheltering under this umbrella are distinct in significant ways. The Australian approach was developed and crystallized within the context of the articulation of the continuum model and its four dimensions. Evidence that the existing appraisal regime was unable to deal with the electronic environment We believe that the existing appraisal regime was unable to deal with the electronic environment because it was a records based approach. It involved the survey and evaluation of specific records, an analysis of statutory and legal requirements, administrative history research, an assessment of use and potential use and the grouping of these records into disposal classes. This approach dealt with records post facto and made dealing with records in electronic formats labour intensive and cumbersome. Realization that we were retaining more than could be managed In November 1998 the Archives held 250 kilometers of records identified as archives. This amounts to around 25 million files. By comparison the National Archives and Records Administration of the USA held 577 kilometers and the Public Record Office held 167 kilometers. Our central government was 98 years old at the time, the USAs

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was 200 years old and the UKs far, far older. Another way of looking at these figures is that per head of population we had 5.5 times more than the USA and almost 5 times more than the UK. Even allowing for jurisdictional differences in recordkeeping practices we had to ask ourselves if our records were likely to be five times more significant. We acknowledged that we could continue to manage what we had selected and we could continue selecting in the same fashion. The implications for us were that a greater proportion of our resources would be needed to store the records and that diminishing effort could be invested in preserving the collection and making it accessible. In crude financial terms we spend around 38% of our budget on salaries, 38% on activities, and 23% on Property Operating Expenses. Increasing our investment in storage and physical management would require a commensurate decrease in expenditure elsewhere as we are not operating in an environment that nurtures expectations that budgets will be augmented. The impact of decreasing our investment in documentation would be of concern. We estimate that we hold 25 589 500 items in our collection. At the end of June this year some 2 600 000 items were identified on the item level database. This leaves twenty two million items that we have yet to document on the item level database if we maintain current resourcing levels and technology it will take us eighty years to catch up and this is without factoring in any work on new transfers. Analysis of the extent to which our collection was being used also lead us to question our appraisal decisions. Over the last ten years a third of one percent of the archives available to the public have been used each year. These figures lead us to conclude that unless we could make records accessible there was little point retaining them. It also made us wonder if we were keeping the right records. Why do we expect that appraisal decisions based on functions will be easier for staff in federal government agencies to apply? The functional based approach to appraisal is integrated in a broader recordkeeping framework. This framework guides federal agencies to identify the functions for which their organization is responsible and to base their recordkeeping thesauri and metadata on this functional analysis. If functional analysis is embedded in this way all agency staff should be conversant with the functional framework for their organization and therefore able to recognize and apply appraisal classes based on functions. In the longer term the sentencing of electronic records should become straightforward because the sophisticated search capabilities of the recordkeeping system should allow the matching of records with appraisal classes. Of course, this will depend entirely on information about the content and purpose of the record being adequately tagged in the metadata for the record. How has functional appraisal changed what the Archives does? There are five major changes I should like to mention: partnership with the records creators is now fundamental to the appraisal process and the communication and development of this shared responsibility is an important part of our work; recordkeeping is the focus of our work we are no longer interested in dealing only with the accumulated documentation of agency work; appraisal archivists begin with an analysis of the functions and activities of organizations rather than assessing accumulations of records this analysis means that the need for records, and the possible uses of records, are documented before and independently of the creation of records;

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the concept of risk management has been introduced into decision-making about whether records are selected as national archives; and lastly consultation with stakeholders is now an expected and intrinsic part of the process.

Has functional appraisal changed what Government agencies do? From the perspective of federal government agencies or records creators the major changes are: first, partnership equals responsibility and the respective obligations of records creators and those of the National Archives have been specified; secondly, situating appraisal within recordkeeping requires agencies to view their records in an integrated way and to realign resources and priorities; and thirdly, agencies are expected to consult with stakeholders to determine appraisal values.

Results and issues

Twelve months on the National Archives has signed the first functions based records disposal authority. Over seventy federal government agencies have indicated that they plan to embark on the preparation of a functions based authority and have registered this intention on our work plan. A rigorous assessment of progress against the key drivers for adopting a functional approach may not be possible for another year at least. There are however four preliminary comments the National Archives can offer. Over the last twelve months we have learned or had confirmed that: implementation is a job that is never done; there is interest in, and pressure for, a critical mass of functional authorities; the public is interested in appraisal/reappraisal; and developing the monitoring and compliance regime for appraisal work is vital it is our weakest point.

Implementing functional appraisal

The implementation of the Archives new approach required enormous preparation, which began in 1996. This involved an organization wide staff training and skilling exercise, the development of detailed advice and new tools for agencies, the compilation of manuals and guidance for our own staff, restructuring of our work groups and articulation of how we would go about resolving problems and determining precedents in this new environment. The Archives recognized the crucial importance of engaging the audience for our new approach to recordkeeping and established a team whose responsibility it was, and remains, to communicate with, and educate, pivotal staff in federal agencies. This team worked to identify our key messages and to plan a campaign to convey the messages and promote the products [for example, in our newsletter Memento, and with the production of coasters and flyers]. The Communication and Training team continues to manage our message to federal agencies, provides the training programs of the Archives and has identified key areas of research for us to undertake to ensure that our advice and tools are sensitive to the changing needs of agencies.

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The first piece of research was conducted in June and July 2000 to ascertain the attitudes, perceptions and current behavior toward recordkeeping in federal government agencies. Our objectives were to obtain data to assist the Archives to develop communication and training strategies aimed at improving federal public sector recordkeeping and to provide base data for measuring our progress (http://www. naa.gov.au/recordkeeping/overview/survey_report.html). Later this year we will commission a survey into federal government recordkeeping practices. Critical mass of functional authorities One of the core tools made available, as part of the e-permanence suite last year, was the Administrative Functions Disposal Authority that authorizes the disposal of the common administrative records generated by most federal agencies. In the initial phase of implementing a functional approach to appraisal this Authority has been heavily used while agencies scramble to develop new authorities specific to their core functions. Our observation eighteen months into the new regime is that many agencies, having applied this general Authority, are anxious and perhaps impatient to see finalisation of the authorities specific to their core functions. If a critical mass of such functional authorities does not emerge over the next eighteen months we will, I think, be dealing with soured market perceptions of both the new philosophy and process. Public interest In November last year Lynne Brindley, the Chief Executive of the British Library, remarked in the Times Literary Supplement (17 November 2000, Pulp fiction about the BL, p 15) Disposal is undoubtedly a difficult and emotive issue. She was responding to criticism of the Library for destroying newspapers after microfilming. If the destruction of mass-produced publications for which compact surrogates are available causes such ire what of the disposal of unique and original material? This year the issue of appraisal and reappraisal by the National Archives has made headlines in parts of Australia Overhead 2 and Overhead 3. It has been our practice to make all disposal schedules publicly available once finalized and authorized. It would I think be fair to say that there is little demand to see them. There have however been sporadic expressions of concern about the extent of public involvement in, or influence on, appraisal and sentencing decisions and requests for theoretical consideration of the transfer of Commonwealth records not selected as national archives to private hands. In response to these concerns the Archives has publicised and sought feedback on its directions in, and general criteria for, appraisal Overhead 4. The Australian Standard on Records Management posited a model for appraisal, which has been adopted by the National Archives. The model (Clause 6.4.3) requires appraisal analysts to evaluate potential post-current use of records, by stakeholders with interests in preserving the record longer than the internal users of the organization. This evaluation occurs at two stages. Agencies consult the stakeholders with a business interest in the records in the course of assessing the period for which records need to be retained. The Archives considers these recommendations independently and arranges consultation with a broader range of stakeholders as necessary to determine the records to be selected as national archives. Our federal department of Veterans Affairs has established an active and constructive stakeholder group to advise on a range of recordkeeping issues. The Veterans Records Forum consists of office holders of the peak ex-service organizations. The Forum is convened to discuss issues such as retention periods for records, whether or not veterans case files must be located in the state in which a veteran lives or whether

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storage can be consolidated on one site, and to identify possible risks if certain recordkeeping functions of the Department were to be contracted out. The Archives approach to stakeholder consultation about appraisal is developing and we are learning as we proceed. Our consultation with stakeholders about the value of records is conducted nationally through peak bodies such as the Australian Historical Association, the Royal Australian Institute of Architects, the Institution of Engineers, and the Australian Heritage Commission. Our work in the area of public consultation is in its early stages and my colleagues and I are very interested in hearing about the work that you are doing. Monitoring and compliance regime The Archives has long recognized that even the most rigorous of appraisal processes resulting in a fine disposal authority may not yield the envisaged result if the application of that authority to the records in question is poorly executed. The application of disposal authorities, or sentencing, is largely carried out by federal government agencies many of which contract the work to consultants. In 1998 the Australian Law Reform Commission issued its report on its review of the Archives Act 1983. (Australian Law Reform Commission, Report No 85: Australias federal record: a review of Archives Act 1983, Sydney, 1998 available at http://www.alrc.gov.au/past /index.html#Archives). One of its recommendations (Recommendation 51) was that the Archives should give priority to designing and implementing a simple, efficient and effective monitoring regime of sentencing. The Archives appreciates the need for monitoring sentencing to identify weaknesses in the formulation of functional authorities, any difficulties in understanding and using them and in assessing the quality of their application.

Conclusion
The National Archives is in the early stages of applying functional appraisal. We would be delighted to talk to colleagues in greater detail about our work and to learn from yours. It would be an abrogation of our professional responsibility if, in adopting a new approach, we did not also keep asking ourselves how we measure up against the biggest of all performance measures are we keeping the right records? Globally and nationally governments say they are seeking to create knowledge or information economies. This political and or economic philosophy views social resources in particular ways. Some social resources are viewed as dispensible and allocated to society for consumption. Others are protected as capital goods. The archival community, and national archivists as a sub-set of this community, would I think, view archives as capital goods considered to be part of the common weal because they underpin the intelligent, creative, robust and accountable society in which we want to operate. Archives are vital public resources or social and cultural capital warranting protection and requiring investment. Their value lies in their existence as authoritative evidence available to citizens for legal purposes, research needs, creative endeavour and the pursuit of leisure. If our selection processes are not rigorous and not appropriate we can hardly expect our communities to be prepared to invest in the results.

Anne-Marie Schwirtlich

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Key Bibliographic references

National Archives of Australia, Why Records are Kept: Directions in Appraisal, 2000 at www.naa.gov.au/recordkeeping/disposal/why_keep/contents.html National Archives of Australia, Appraisal Guidelines for Commonwealth Records, 2000 at www.naa.gov.au/recordkeeping/disposal/appraisal/contents.html Russell Kelly, The National Archives of Australias New Approach to Appraisal, Archives and Manuscripts, Volume 29, Number 1, May 2001, pp 72-85

Standards Australia, Australian Standard 4390 Records Management (1996)