Rizal Technological University Mini Archives: Prelude to Compliance

with National Archives of the Philippines Act

Renilda A. Magsino1,a*, Mary Anne S. Rubio2,b, Ma. Milagros P. Apostol3,c

1
Rizal Technological University, Boni Avenue, Mandaluyong City, Philippines*

2
Rizal Technological University, Boni Avenue, Mandaluyong City, Philippines

3
Rizal Technological University, Boni Avenue, Mandaluyong City, Philippines

a
renilda_magsino@yahoo.com, banne_srubio@yahoo.com, cmila__apostol@yahoo.com

Keywords: Records & information research, archives management, qualitative research, document
analysis research, content analysis

Abstract. This qualitative study was undertaken to develop a framework for a Rizal Technological
University (RTU) mini archives in compliance with the requirements provided for under the
National Archives of the Philippines Law. Information governance maturity level, based on the
internationally-accepted Association of Records Managers and Administrators- International
standard was determined to be able to establish a benchmark. The document analysis and content
analysis methods were used in evaluating primary and secondary data that supported the framework
building. Philippine government-issued materials and internationally published documents were
studied in-depth and relevant information drawn and synthesized. The study revealed that the RTU
was at the second level in the five-tiered information governance maturity level in all the eight criteria
at the time of the study yet found to be ready for the mandatory compliance with the law. Four
common attributes of a record emerged from the document analyses: authenticity, reliability,
integrity and useability. These four qualities were lengthily discussed in the literature and lent
credence and validity in the framework-building.

Introduction

Public records are essential to the administration and operation of all government offices,
whether national or local, including government-owned and controlled corporations, government
financial institutions and state colleges and universities. These records contain information which
allow government programs to function, provide officials with basis for making decisions and ensure
continuity from past to present operations. They document the legal responsibility of government,
protect the rights of citizens, and provide them with a means of monitoring government programs
and measuring the performance of public officials.[1]
 The Rizal Technological University (RTU), as a state university is covered by the provisions
of National Archives Act [2] which took effect upon the approval of its Implementing Rules and
Regulations (IRR) on January 20, 2009. It is therefore imperative that RTU prepare for the eventual
putting up of its mini archives as required under the provisions of the law. Rule 19 of the IRR states
that “each agency shall maintain and operate records storage/ mini archives of non-current records
preparatory to their transfer to the National Archives of the Philippines (NAP), Records Center or to
Archives repository while Rule 20 enumerates the penal provisions for unlawful acts or omission.
These penal provisions are specifically stated under Rule 21 which provides that any public officer
committing any of the unlawful acts or omission shall be punished by a fine of not less than five
hundred thousand pesos (Php500,000.00) but not more than one million pesos (Php1,000,000.00) or
be imprisoned for not less than five (5) years but not more than fifteen (15) years and/or both fine
and imprisonment at the discretion of the court without prejudice to the filing of administrative
charges that would result to such public officer’s perpetual disqualification from public office, and
forfeiture, in favor of the government, of his salary and other lawful income.

Background of the Study

As early as March 25, 2012, the RTU Records Disposition Schedule (RTURDS) [3] submitted
by the then RTU President Dr. Jose Q. Macaballug has already been approved by the NAP and used
as legal basis for all RTU disposal of valueless records since then. This document carries the
following provision: “IMPORTANT: Pursuant to Section 18, Article lll, (RA 9470 s. 2007), no
government department, bureau, agency and instrumentality shall dispose of, destroy or authorize the
disposal or destruction of any public record, which are in the custody or under its control except with
the prior written authority of the executive director”. This RTURDS contains an enumeration of
records series title, the number of years these records are to be kept in active storage and the
mandatory retention period prior to disposition. It is not just a guide for the legitimate disposal or
destruction of records but also serves as the main document in the building of a university mini-
archives for permanent record holdings. This study looked into the development of a university mini-
archives through a framework that takes into consideration the internationally accepted record-
keeping principles and at the same time complying with the requirements set forth in relevant
Philippine laws, rules and procedures on the matter.

Statement of the Problem

Aside from initiating compliance with legal requirements and instilling awareness on the
institutional obligations and penal provisions in case of infractions, this study also explored the
following concerns:
1. Framework for the development of RTU mini archives based on Philippine rules and
regulations taking into consideration international standards and generally accepted
recordkeeping principles;
2. RTU information governance maturity level determined on the basis of generally accepted
recordkeeping principles;
3. Philippine government initiatives to promote the protection, conservation promotion and
popularization of the nation’s historical and cultural heritage and resources, including those
of academic institutions; and
4. The importance of RTURDS in establishing the RTU mini archives mandated under Rule
19, National Archives of the Philippines General Circular No. 1, January 20, 2009 (IRR of
RA 9470).
 Significance of the Study

This study could contribute not only to the promotion of the nation’s cultural heritage but also
to an efficient, effective and economical public governance. Awareness on the legal recordkeeping
practices and proper implementation of records management programs can reduce time, money and
other resources spent for locating lost or misfiled records and facilitate investigations on cases
involving anomalous government transactions by making available authentic and reliable evidences.

Definition of Terms per R.A. 9470

Disposal- refers to the act of selling, burning or any other way of discarding valueless records
in accordance with the provisions of this act.

Disposition- refers to the systematic sorting out of records in the office storage whereby those
classified as valuable are permanently preserved and those which are classified as valueless are
disposed of.

Non-current records- files that deal with completed or adjourned business not needed for
action or reference in continuing agency transactions but have continuing research or historical value
to the government and public.

Public records-records or classes of records, in any form, in whole or in part, created or

received , whether before or after the effectivity of RA 9470, by a government agency in the conduct
of its affairs, and have been retained by that government agency or its successors as evidence or
because of the information contained therein.

Records series- group of related records arranged under a single unit or kept together as a unit
because they deal with a particular subject, result from the activity or have a special form.

Retention period- specific period of time established and approved by the National Archives
of the Philippines as the life span of records, after which they are deemed ready for permanent storage
or destruction.

Valueless records-records that have reached the prescribed retention periods and outlived the
usefulness to the agency or the government as a whole.

Review of Related Literature

Foreign literature

Records are information created, received, and maintained as evidence and

information by an organization or person, in pursuance of legal obligations or in the transaction of
business [4]. ISO 15489 was developed to standardize international best practices in records
management to ensure that appropriate protection is given to all records, and that the evidence and
information they contain can be retrieved more efficiently and effectively, using standard practices
and procedures. This document facilitates the systematic selection and screening of materials that are
strictly identified as public records as defined under the law. It is extremely important that the mini
archives be a repository of authentic, reliable and trustworthy records acceptable as evidence of
public transactions.

In like manner, ARMA International [5], touted as the “authority in information governance”,
defined records as any recorded information, regardless of medium or characteristics, made or
received and retained by an organization in pursuance of legal obligations or in the transaction of
business. The main concern of this document, among others, is to identify the critical hallmarks of
information governance and provide both a standard of conduct and metrics by which to judge that
conduct. This literature was selected because its application is independent of local laws and custom
and can be applied to all sizes of organizations in public and private sectors, across geographic
boundaries. This study used its Information Governance Maturity Model to present solution to
problem number one.

It could be gleaned from the two definitions above that there are two common important
functions of records: 1) created in pursuance of legal obligations and; 2) as evidence of business
transactions, both crucial to the existence and continuity in the operation of any government or private
organization. Discussions on the issues of this study were premised on similar grounds in the two
international documents cited above.

Building a mini-archives requires writing and prescribing policies and convincing

management that this exercise is worth the cost and effort invested. According to Mason [6],
convincing management to accept and adopt a proposed policy is a difficult task. It requires
answering difficult questions, and producing evidence for policy to be able to design an effective
project with a clear, relevant and intellectually worthwhile focus. This book lent credence and
validity to the method used. The analysis and synthesis of documents yield coherent description of
the data needed

Although checking reliability and validity is seldom done in a qualitative research according
to Fraenkel, [7] it could at least be done in this type of study. Validity and reliability was checked
by triangulation or assessing through cross-checking sources of information and taking note on the
agreement between two or more categorizers.

Bowen [8] provided justification on the use of document analysis that these researchers found
helpful for this study. Documents provide context, or data about the data being studied. The
references contain background information as well as historical insight on the historical roots of
specific issues that would contribute to transparency, a fundamental principle in qualitative research.

Transparency of the analysis, according to Stenius, [9] means that the reader is able to follow
the researcher’s reasoning, that he is given the necessary information for accepting the interpretation,
or challenging it. He added that there are three ways of improving transparency and repeatability of
qualitative analysis. First is enumerating the data, second is dividing the process of interpretation
into steps and, third, making explicit the rules of decision and interpretation. The method used in
this study made possible the enumeration of specific data and their sources, thus contributing to the
desired transparency and trustworthiness, attributes for validity in this study.
 Local literature

Since all business transactions of public entities must be reported through their annual reports
to the President of the Republic of the Philippines [10], accurate and complete documentation must
be made available to evidence performance and public transactions. Public records in the context of
its legal definition satisfy these evidentiary requirements.

The importance given to quality of records as evidence, as mentioned above is also apparent
in the RA 9470 definition of public records which reads: “record or classes of records, in any form,
in whole or in part, created or received, whether before or after the effectivity of this Act, by a
government agency in the conduct of its affairs, and have been retained by that government agency
or its successors as evidence or because of the information contained therein”. The word successors
in the NAP Act’s definition of record, however does not appear in the definitions of the two foreign
documents earlier cited. But this word could be crucial in determining the responsible agency over
public records because the Philippine bureaucracy is very vulnerable to changes in the organizational
set-up due to political interventions. RA 9470 was one of the basic documents used for this study.

Research Methodology

Creswell [11] explained that in qualitative research, the inquirer reflects about how their role
in the study and their personal background, culture, and experiences hold potential for shaping their
interpretations, such as the themes they advance and the meaning they ascribe to the data. As officers
involved in records management in their day-to-day work, these researchers could relate to the
problems at hand and their background and interpretation helped in the shaping of the direction of
the study. Gorman [12] likewise encourages qualitative researchers to develop a critical evaluation
of published materials in order to better understand and develop their own methodologies. Silverman
[13] provides a step-by-step guide to planning and conducting qualitative research which were
referred to in the conduct of this study.

The proposed framework for RTU mini archives borrowed its validity from Philippine rules
and regulations and international standards and generally accepted recordkeeping principles.
According to Creswell, an investigator may collect qualitative documents which may include public
or private materials to back up the process. This qualitative study also considered the document
analysis method of Bowen in identifying materials needed in writing the arguments of Mason (p.
173) that would support the framework. Arguments are perspectives, interpretation or line of
reasoning in which the researcher is continually thinking about. The ways of arguing: 1) Arguing
evidentially. This means that the basis of selection of evidence is clear. 2) Arguing interpretively
or narratively. Interpretation must be meaningful or reasonable. 3) Arguing evocatively or
illustratively. Audience must understand what is sought to be conveyed; and 4) Arguing reflexively
or multivocally wherein there must be willingness to critique and question own or others’
interpretation. This study considered number 1, arguing evidentially in the selection of materials.
Public documents such as the NAP Act of 2007 and RTURDS; and institutional records of
the ISO and ARMA International were selected to support discussion for the framework. These
documents were considered appropriate based on Fraenkel’s proposition that generally accepted
practices laid down by international institutions are good materials for qualitative research.
RTU information governance maturity level determined on the basis of generally accepted
recordkeeping principles was evaluated using the template/rubric provided under the “Information
Governance Maturity Model”. This model was part of an information governance standard issued
and published by ARMA International and used by global information management practitioners,
including public and private institutions.
Document analysis method as discussed by Bowen and documentary research procedures by
Mason were referred to in discussing the Philippine government initiatives to promote the protection,
conservation promotion and popularization of the nation’s historical and cultural heritage and
resources, including those of academic institutions. Relevant laws were scanned to select the most
appropriate material to support the discussion. Another method was introduced by Fraenkel in his
discussion (pp 431, 478 and 479) on how content analysis facilitate studies using communications
and documents. Content analysis is a technique that enables researchers to discover and understand
policies and behaviors that are not directly observable nor measurable.
The importance of the RTURDS in establishing the RTU mini archives mandated under
Rule 19, NAP General Circular No. 1, January 20, 2009 (Implementing Rules and Regulations of RA
9470) was determined using content analysis and relied on the generally accepted recordkeeping
principles.

Presentation, Analysis and Interpretation of Data

1. Framework for the development of RTU mini archives, based on Philippine rules and
regulations taking into consideration international standards and generally accepted
recordkeeping principles is shown below:

Criteria per ISO 15489,

Source 1. To the RTU
SELECTION

EVALUATION

TRANSFER

RA 9470 & the Generally

document: Generally Accepted Mini Archives for
Recordkeeping Principles:
RTU Redords safekeeping and
a. created in pursuance
Disposition of legal obligations further evlaution
b. evidence of business
Schedule transactions 2.To the NAP for
c. possessing the those with
following attributes: national/internati
- authentic onal value
-reliable
-with integrity
(trustworthy)
-useful

PROPOSED FRAMEWORK
RTU MINI ARCHIVES
In Compliance with RA 9470

Scanning of the “The International Standards for Information and documentation (ISO
15489)” revealed that the document was developed to standardize international best practices
in records management so that policies and procedures ensure that appropriate attention and
protection is given to records and information that evidence business transactions. Very
pertinent provisions of the ISO enumerate the attributes of records which are:
 a) Authenticity. An authentic record is one that can be proven to be: what it purports to
be, created or sent by the person purported to have created or sent it, and created or
sent at the time purported.
b) Reliability. A reliable record is one whose contents can be trusted as full and accurate
representation of the transaction, activities or facts to which they attest and can be
depended upon in the course of subsequent transactions or activities.
c) Integrity. The integrity of the record refers to its being complete and unaltered.
d) Useability. A useable record is one that can be located, retrieved, presented and
interpreted.

On the local level, the National Archives Act or RA 9470, in its statement of objectives,
supported the ISO provisions on the importance of the four attributes of records enumerated
above. On its version, RA 9470 provides:
a) On authenticity. Numbers (8) and (9) of Sec. 6, Article II provide that the NAP shall
see to it that the office shall issue, transmit and authenticate reproduced copies,
certified true copies or certifications on public archives and for extracts thereof; and
keep a registry of all public records under the custody and control of the NAP which
shall be made available for public inspection.
b) On reliability. Sec. 5 (c) provides, as one of its objectives: mandating government
accountability in ensuring that full and accurate records of the affairs of national
government and the LGUs are maintained and preserved.
c) On integrity. Sec. 5(d) states NAP’s one objective as: enhancing public confidence
in the integrity of public records keeping and management.
d) On useability. Sec. 5 (e) states as one of the objectives: ensuring the accessibility of
public records that are relevant to the promotion and preservation of Philippine
cultural heritage.

After intertwining the contents of ISO 15489 and RA 9470, two of the trustworthy
documents consulted, it was established that the four attributes of records that must be
considered in the building of the framework for an RTU mini archives are: authenticity,
reliability, trustworthiness and usefulness.

2. RTU information governance maturity level determined on the basis of generally accepted
recordkeeping principles.

The “Generally Accepted Recordkeeping Principles” developed by ARMA

International presents the “Information Governance Maturity Model” which is intended for
evaluating and improving an organization’s information governance programs and practices
and enabling it to achieve its goals. It is therefore very important for an organization to
determine its maturity level to be able to build a complete mini archives since the richness
of the holdings will depend upon the organization’s maturity level, particularly on criteria
numbers 7 and 8.
The Information Governance Maturity Assessment below shows the abridged version
of the rubric showing the 8 criteria used to classify RTU level. From the five levels, the
evaluation revealed a second level classification.
 Rizal Technological University
Information Governance Maturity Assessment (Abridged)

The Principle(Citeria) Level

(Narrative description (Narrative description explained below)
explained below)
1. Accountability Second Level
(In Development)
2. Transparency Second Level
3. Integrity Second Level
4. Protection Second Level
5. Compliance Second Level
6. Availability Second Level
7. Retention Second Level
8. Disposition Second Level

Source: ARMA International’s Generally Accepted Record-

Keeping Principles, Information Governance Maturity Model.

The descriptions of the principles in the above table (column 1) are:

1. Accountability. A senior executive (or a person of comparable authority) shall
oversee the information governance program and delegate responsibility for records
and information management to appropriate individuals. The organization adopts
policies and procedures to guide personnel and ensure that the program can be audited.
2. Transparency. An organization’s business processes and activities, including its
information governance program, shall be documented in an open and verifiable
manner, and the documentation shall be available to all personnel and appropriate
interested parties.
3. Integrity. An information governance program shall be constructed so the
information generated by or managed for the organization has a reasonable and
suitable guarantee of authenticity and reliability.
4. Protection. An information governance program shall be constructed to ensure a
reasonable level of protection that are private, confidential, privileged, secret,
classified, essential to business continuity, or that otherwise require protection.
5. Compliance. An information governance program shall be constructed to comply
with applicable laws and other binding authorities, as well as with the organization’s
policies.
6. Availability. An organization shall maintain records and information in a manner
that ensures timely, efficient, and accurate retrieval of needed information.
7. Retention. An organization shall maintain its records and information for an
appropriate time, taking into account its legal, regulatory, fiscal, operational, and
historical requirements.
8. Disposition. An organization shall provide secure and appropriate disposition for
records and information that are no longer required to be maintained by applicable
laws and the organization’s policies.

The assessment (column 2), for RTU Information Governance Maturity Level
(Level 2) for each criterion are:
1. Accountability. No senior executive (or person of comparable authority) is
involved in or responsible for records and information. The records manager role is
recognized, although the person in that role is responsible only for tactical operation
of the existing records management program, which is concerned primarily with
managing records rather than all information assets. In many cases, the existing
records management program covers paper records only. The information technology
function or department is the de facto lead for storing electronic information, and the
records manager is not involved in discussions about electronic systems. Information
is not stored in a systematic fashion. The organization is aware that it needs to govern
its broader information assets.
2. Transparency. The organization realizes that some degree of transparency is
important in its business processes and records and information management program
for business or regulatory needs. Although a limited amount of transparency exists in
areas where regulations demand it, there is no systematic or government-wide drive
to transparency. The organization has begun to document its business and records
information processes.
3. Integrity. Some organizational records and information are stored with their
respective metadata that demonstrate authenticity; however, no formal process is
defined for metadata storage and chain of custody. Metadata storage and chain of
custody methods are acknowledged to be important, but they are left to the different
departments to handle as they determine is appropriate.
4. Protection. Some protection of information assets is exercised. There is a written
policy for records and information that require a level of protection (e.g., personnel
records). However, the policy does not give clear and definite guidelines for all
information in all media types. Guidance for employees is not universal or uniform.
Employee training is not formalized. The policy does not address how to exchange
these records and information among internal or external stakeholders. Access
controls are implemented by individual content owners.
5. Compliance. The organization has identified some of the rules and regulations that
govern its business and introduced some compliance policies and good information
management practices around those policies. Policies are not complete, and there are
no structured accountability processes or controls for compliance. There is a hold
process, but it is not well-integrated with the organization’s information management
and discovery processes, and the organization does not have full confidence in it.
6. Availability. Records and information retrieval mechanisms have been
implemented in some parts of the organization. In those areas with retrieval
mechanisms, it is possible to distinguish among official records, duplicates, and non-
record information. There are some policies on where and how to store official
records and information, but a standard is not imposed across the organization.
Responding to legal discovery and information requests is complicated and costly due
to the inconsistent treatment of information.
7. Retention. A retention schedule and policies are available, but they do not
encompass all records and information, did not go through an official review, and are
not well known around the organization. The retention schedule and policies are not
regularly updated or maintained. Education and training about the retention policies
are not available.
8. Disposition. Preliminary guidelines for disposition are established. There is a
realization of the importance of suspending disposition in a consistent manner, when
required. There may not be enforcement and auditing of disposition. This area is
deemed the strength of RTU.
 3. Philippine government initiatives to promote the protection, conservation promotion and
popularization of the nation’s historical and cultural heritage and resources, including those
of academic institutions.

RA 9470 strengthened the system of management and administration of archival

records of the nation, state universities and colleges specifically cited, among others. The
law’s declaration of policy is clear on the issue of protection, conservation, promotion and
popularization of the nation’s archives. The strength of this law lies in the penal provisions
in case of violation and/or acts of omission. The corresponding fines and penalties could
scare people in charge of records and information keeping and would, in effect develop more
responsible records and information custodians. It was noted in the course of the document
analysis that the archives, which it defines as “public records, papers, periodicals, books or
other items, articles or materials, whether in the form of electronic, audio-visual or print,
which by their nature and characteristics have enduring value, that have been selected for
permanent preservation” is the main concern of RA 9470. In building up the nation’s
archives, its component parts (the government agencies including the state universities and
colleges’ archives) must be strengthened as well. This is the rationale for mandating other
agencies to establish their own mini archives which will serve as the “purgatory” or a
cleansing area from which a “quality” archives shall be drawn.

4. The importance of the RTURDS in establishing and maintaining the RTU mini archives.

After going over the literature and conducting content and document analyses, it was
established that the RTURDS, a document approved by the NAP on March 25, 2012 is the
legal authority for RTU disposition activities. This document is very important because it
emphasizes not only the cultural and historical significance of records in national and
international contexts but also the penal provisions for violations which gives police power
for stricter compliance with the law. This document contains the listing of records series by
the organization showing, for each records series the period of time it is to remain in the office
area, in the storage (inactive) area and its preservation or destruction. It identifies the
permanent records fit to be transferred to the mini archives. This document serves as a guide
for records officers on how to create, organize, maintain and decide on disposition of records
under their jurisdiction and accountability.

Conclusion and Recommendation

Based on the results of the study, the RTU was found to be prepared for the mandatory
compliance with RA 9470 despite its ranking in an international standard evaluation as below normal.
It could be deduced from the contents of the model that the critical point for RTU is the issue on
transparency. This is understandable because of the absence of a specific legislation on freedom of
information in the Philippines. The current threshold for transparency issues are the provisions under
the Revised Administrative Code of 1987 [14] and the IRR of RA 6713, the Code of Conduct and
Ethical Standards for Public Officials and Employees in its Rule IV, Transparency of Transactions
and Access to Information.[15] The strength of the RTU information governance lies on its well-
prepared Records Disposition Schedule.

Since the RTURDS is the institution’s strength, management could build upon this strength
to be able to comply with the requirements on the mini archives. Officials and employees who will
be assigned in the mini archives building should be required to attend seminars conducted by the
National Archives of the Philippines, and not those conducted by private organizations.
 A study on the level of awareness among RTU officials and employees on their
responsibilities and obligations with regards to records and information and the penalties for
violations is highly recommended.

References

[1] Implementing Rules and Regulations, Republic Act 9470.

[2] Republic Act 9470. National Archives Act of the Philippines.

[3] Rizal Technological University Records Disposition Schedule.

[4] The International Standard for Information and documentation - Records Management
(ISO 15489).
[5] ARMA Generally Accepted Recordkeeping Principles- International
http://www.arma.org/docs/bookstore/theprinciplesmaturitymodel.pdf.Retrieved January 1, 2015.

[6] Mason, J. Qualitative Researching 2nd ed. London: Sage. (2002)

[7] Fraenkel, J.R., Wallen, N.E. & Hyun, H.H. How to Design and Evaluate Research
in Education. New York: McGraw-Hill. pp 426 and 485 (2012)

[8] Bowen, Glenn A. Document Analysis as a Qualitative Research Method.

Published online in Qualitative Research Journal, Vol. 9, No 2, 2009
http://search.informit.com.au/documentSummary;dn=252446162410248 Retrieved January,
2015.p. 29 (2009)

[9] Stenius, K., et al. How to Write Publishable Qualitative Research.

www.parint.org/.../isage_2nd _edition_cha. Retrieved December, 2014.

[10] Administrative Code of 1987

[11] Creswell, J.W. Research design : qualitative, quantitative, and mixed methods
approaches John W. Creswell. 4th ed. SAGE Publications, Inc.(2014)

[12] Gorman, G. E. & Peter Clayton (2005). Qualitative Research for the Information
Professional. A Practical Handbook. 2nd ed. Facet Publishing. London.

[13] Silverman, D. Doing Qualitative Research 4th ed. Sage Publication London 2013)

[14] Revised Administrative Code of 1987

[15] IRR of RA 6713, the Code of Conduct and Ethical Standards for Public Officials and
Employees in its Rule IV, Transparency of Transactions and Access to Information