The agency records officers are responsible for meeting NARA's guidance on electronic records management. But it will come to the web managers to execute the guidance by establishing and maintaining recordkeeping systems and processes that are embedded in the day-to-day website operations.
NARA has not communicated web recordkeeping duties clearly and actionably to web managers, despite NARA's good effort.
Federal web managers want to know what their duties are for recordkeeping. However, a review of relevant laws, policies, and NARA guidance is an overwhelming task. NARA offers a site for its guidance and regulations, which suffers from a classic case of information overload:
NARA Bulletins cover the most important information, but tellingly, NARA has even issued a bulletin for the sole purpose of listing NARA bulletins! It includes links to over 30 guidance documents, requirements, and practices that federal agencies should be applying to their electronic and web records.
The sources from NARA that do include good information are generally too vague or abstract to help web managers do the day-to-day recordkeeping.
The most actionable guidance NARA offers is in its New Guidance for Implementing E-Gov Act 2002. The key requirement is, "By September 30, 2009, agencies must have NARA-approved records schedules for all records in existing electronic information systems."
To archivists, this is meaningful guidance. But this alone does not tell federal web managers what they need to know—what to do with web records to be in compliance. There is a gap here, because retaining records as "long as needed" and approving "schedules" are not as concrete as other federal web policies with clear guidance like, "images on webpages must have alt text".
NARA's abstract guidance must be turned into concrete steps for each agency. Agency records officers, web managers, and NARA are supposed to work together to do this for each agency. So far this has been done at few agencies.
The solution is for agency records officers to take the lead and actively start collaborating with their agency's web management to meet NARA's guidance. This will yield the web records management processes agencies need to follow.