As she warmed to her main message, the Information Commissioner urgently stressed the ever greater need for well- trained information managers, archivists and record keepers in the face of an increasingly complex digital landscape, where boundaries are blurred and news can be faked with consummate ease. Without good, accurate, accessible information management systems, the whole underpinning of democracy is threatened with greater risk of reliance on oral government.
The Information Commissioner referred to Sir Alex Allan’s 2014 government digital records and archives review, sharing his views on The National Archives programme of Information Management Assets (IMAs). She would like to see IMAs moving from a voluntary to a mandatory requirement. The Cabinet Office’s recent response to the review was welcomed. It saw the need for change in the culture of information management and for review of the existing legislation.
The focus quickly moved to the importance of the Duty to Document and whether or not this needs to be legislated, with oversight and consequences if people fail to document key decisions.
“I am talking about a positive duty in law to create records of significant decisions, actions and events. That means records explaining and providing context to why a specific course of action was taken.”
Communication through Smart phones, instant messaging and other areas of social media, including private accounts, all provide valuable evidence about the context and circumstances which lead to specific government decisions. The difficulty is how to avoid the salient digital records from being forgotten or deleted. The ICO will be looking into the scale of this problem and how best to move forward.
Staff will need time and resources to become trained in managing the information in these varied digital environments and they need time to develop practices around being alert to decisions being made here and subsequently taking the steps needed to keep a record of that communication.
Lastly, the Information Commissioner addressed the other driver for records management – the protection of personal data, noting the opportunities of the EU General Data Protection Regulation (GDPR) for further ensuring data protection for individuals.
It was the Information Commissioner’s passion for the Duty to Document, however, that provoked the most discussion and was indeed the highlight of this stimulating and thought provoking talk.