Guidance on Managing Social Media Records

Guidance on Managing Social Media Records


>>Thank you for joining us for Guidance
on Managing Social Media Records. This is a Records Management Seminar,
delivered by the United States National Archives and Records of Administration’s National
Records Management Training Program. In this session, Beth Cron introduces
and explains [inaudible] guidance on managing social media records. Now, let’s join the seminar.>>Today is the Guidance on Managing
Social Media Records online briefing with Ms. Beth Cron. Beth Cron is a records policy analyst at the
National Archives and Records Administration. She’s a member of the Records
Management Policy Section within the Office of the Chief Records Officer. The Records Management Policy Section has
produced guidance on managing email records with the Capstone approach, cloud
computing, and email archiving applications. Beth is a 2008 graduate of the school of
information at the University of Michigan, and she specialized in archives
and records management. She currently serves as the vice chair
of the Society of American Archivists and Records Management Roundtable. Okay. With all of that said, I will
now pass it over to Ms. Beth Cron.>>All right. Well, thank you everyone
for taking the time today to attend this session or to watch this Webinar. So, first of all, I’ll address
the numbering on this slide here. So you can see it says NARA Bulletin 2014-XX. So this was intended to come out, and
then we all had a little shutdown. So we’re expecting that this
bulletin will be coming out very soon. So you should watch the Records Express Blog
and our Web site to see when that comes out. So our agenda today is to review this
soon-to-be released bulletin on guidance on managing social media records. So what we’re going to do is
review the purpose of the bulletin. Define what social media records
are for the purpose of the bulletin. Then we’re going to identify the changes
for managing social media records and some possible ways to
address these challenges. We will also talk about scheduling social media
content, implementing social media capture and records management responsibilities. NARA’s Records Management Policy Team
developed this guidance with input from subject matter experts from across
our agency, the National Archives, including our Office of General Counsel. We also requested feedback from the
public on the Records Express Blog, so you may have seen it posted
there a while back. And we also requested feedback
from the Federal Records Council. We then incorporated this
feedback into the bulletin. So this bulletin supersedes or replaces
the 2010 Guidance on Managing Records in Web 2.0 Social Media Platforms. There are some small differences between the
two bulletins, and two bigger differences that I wanted to point out today. First, this new bulletin includes more
information on capturing records created when Federal agencies use social media. Second, the previous bulletin said
that content may be a federal record. We changed the language to now say that content
on social media is likely a federal record. So I just wanted to point out
these two differences for you. The bulletin contains high-level requirements
and best practices for capturing records created when Federal agencies use social media. Federal agencies are currently using
many different social media platforms for many different purposes. And what we heard is that they
needed more guidance for capture. So while we all may be aware of the most common
social media platforms, let me give an overview of how we define social media for
the purposes of this bulletin. Social media includes blogs. Wikis. Social networks. Photo libraries. Virtual worlds. Location-based services and
also video-sharing sites. What social media does is includes various
activities integrating Web technology, social interaction and user-generated content. So we know that agencies use social media both
internally and externally to share information, support their business processes and
to connect people to the government. Social media also allows
individuals to collaborate. Create. Organize. Edit. Make comments on. Combine and share content. So the reason we have Twitter,
YouTube and Facebook on this slide is that they were all identified in a GAO report
titled “Federal Agencies Needing Policies and Procedures for Managing and Protecting
Information They Access and Disseminate.” This report identified these three tools as
the most commonly used social media platforms in use across the U.S. government. However, we do know that many other social
media tools are being used in agencies as well. An interesting thing is that you can look
up the various tools that are being used in the government on GSA’s
social media registry. And what you can do here is you can
put in a url, and you can verify that a social media account is managed
by the U.S. federal government. And so you can see also other tools
that are being used by other agencies. You can look up accounts
that are managed by agencies. Elected officials. Heads of agencies. Or members of the President’s Cabinet. So it’s an interesting tool
if you’re looking for agencies that are using the same tool as your agency. It is possible that many
individuals don’t consider content in social media as a record at this time. However, we encourage and urge agencies
to consider the definition of a record and the management implications of that. So social media content that meets the
definition of a federal record must be managed in accordance with all applicable
laws and regulations. The statute and its implementing regulations
place responsibility with each agency to determine what federal
records they create or receive. So to get to answering the question of if
social media content is a federal record, we included a series of questions in
the bulletin that agencies should ask. And if the answer is yes
to any of these questions, then the content is likely a federal record. So what we basically have here is
the list of non-exhaustive questions that can help agencies determine the record
status of their social media content. So if you go through this list
and ask yourself these questions, if the answers to these questions are yes,
then the content’s likely a federal record. So these include, does it contain evidence
of agency’s policies, business or mission? Is the information only available
on the social media site? So that it is, it would not be
available on any other agency Web site. Does the agency use the tool to
convey official agency information? Is there a business need for the information? So if you had to look at this list and if you
had to quickly consider these questions now, I’m curious if you’d say that you have
social media content at your agency that meet the definition of a federal record. So if this isn’t something that you know at this
time or it’s not something that you’ve thought about or had discussions at your agency, then this could be one of
the takeaways for discussion. We also talk in the bulletin about the fact that
there is functionality built into social media, such as the ability to comment or something
or in the interactive piece that may, in fact, provide added functionality
and value to the content. Social media content may be
a federal record when the use of the social media provides
this added functionality. That is, for example, can receive comments and
respond on a piece of policy or information. And this is more of a social interaction. So it may provide more record content that would
just be available if something were just posted on any agency Web site, for instance. So additional functionality could
include also enhanced search ability, opportunity to public comment, as I
mentioned, or some other form of collaboration. The agencies have the responsibility
to identify the complete record. And the complete record includes
the content, the context of where that content appeared, and also the structure. And along with any associated metadata. Metadata is information about that content. For example, at a very basic level, this
could include the author and date of creation. If we take the example of Twitter and we look at
a tweet, the content could be the tweet itself and the 140 characters or
less that make up that tweet. The context could be the thread of
responses to that tweet or the replies. And then the structure is captured
in Twitter via the threaded response. And Twitter actually captures a great
number of metadata elements for each tweet. And if you haven’t done that before, it’s
pretty interesting to Google it and to see all of the pieces of metadata that
Twitter does capture in their system. So capturing the content, context and structure and any associated metadata
forms the complete record. This, in turn, ensures that the records have
not been changed, that they were created by the person who supposedly created it,
and when it was reported to be created. The bulletin also describes the many
recordkeeping challenges associated with records created and
collaborative environments. You may also have other challenges
at your agency. This is also a non-exhaustive list. But some that we highlighted
in the bulletin include content that is located in multiple places. So this can make it difficult to determine where
the official record lives or where it’s located. Another is the ownership and control of
data that resides with a third party. So this could be asking the
question of who owns the content. Another challenge is the
identification of records. And as I just said before, is what of the
content on the social media platform makes up a complete record, as well
as what metadata is necessary. Another is development and
implementation of record schedules. This also includes the ability to transfer and
permanently delete records, apply legal holds or perform other records management functions. And one that we chose to address in
this bulletin in more detail is capture. And so this includes the capture
of frequently updated records. As we know, that all social media
is dynamic and it often changes. And this also poses a challenge for the
ability to apply the record schedule and determine when the cut-off is. And as I mentioned before,
capture of complete records. Making sure that they’re captured in a manner
that ensures that authenticity and availability. One that we thought of is that
public expectations could be that all Web content is both
permanently valuable and accessible. So there could be this idea that it
will all be available in the future. And I think we saw an example of this with folks
turning to Internet archive or other places, when a number of federal Web sites
were down during the shutdown. And the last challenge I’ll
address today is the handling of records containing personally
identifiable information or PII. So it’s a good question to ask at your
agency how they’re handling social media that contains personally
identifiable information. And that will most likely be
addressed in a social media policy. So what are some of the ways
to address these challenges? Agencies need to establish, also
identify processes and policies and also the recordkeeping
roles for identifying, managing and capturing social media records. So some of the areas to include are addressed
when developing these policies, procedures and also the roles and responsibilities. Include identifying records. Define ownership of those records for content. The terms of service agreement with the
social media provider and what that may say. Communicating these policies internally to
the agency and also externally to make sure that those in the agency know the
policy, and the public is also aware. And then monitoring the use
and value of social media. It could change over the course of
an agency using Twitter or Facebook. And then, finally, monitoring changes
to those terms of service agreements. You’ve probably heard about these social media
providers often will change their public terms of service agreements, and these could
have implications for agencies as well. In addition, we recommend that agencies
establish a social media working group. This social media working group could
be made up of records management staff. Web managers. Social media managers. Information technology staff. Also, privacy and information security staff. You may want to also include your agency’s
council and any other relevant stakeholders that you may think of at your agency. And so, what the working group would
do is identify complete records and make sure they include the content,
context, structure and any necessary metadata. It would also look at the existing record
schedules, review them and determine if social media records are covered. And if they aren’t covered there, then
they’d have to take that next step of making sure that they’re scheduled. And then finally, discuss records
management issues before rolling out any new social media initiatives or
changing the current use the social media tool. Agencies, as I said, must
identify the official record and determine how it will be managed
when scheduling social media. They also need to keep in mind that some
social media records may be temporary, with the transitory, short
or long-term retention. All temporary, but they could have
different implications for those. And that some social media
records may even be permanent. And one example we give is a blog of an agency
senior official or the head of the agency. So this slide here includes material
that will previously in a decision tree in the superseded bulletin that I talked about. After agencies have identified their social
media records, they should determine whether that existing disposition authority
or record schedule applies. And so this could also include
a general record schedule item. And if that content is not covered
by an existing disposition authority, a new schedule should be developed. It should also identify is content
is enhanced by using social media. So that’s if by using the social
media, the content of value is changed. And if that’s the case, then a new
schedule should also be developed that encompasses the complete record. And that includes the content,
context, structure and metadata. Agencies should also identify if there’s
been a change in the social media tool, in the use of it, and if that affects
the record value of the information. The platform itself could change,
and this could affect the value of the record and what should be scheduled. And then finally, regularly review tools for
their use and the associated record schedules. So this kind of a to-do list
of things to consider. When agencies are doing their day-to-day
monitoring of social media, there may be content that falls outside of what should
be on the site, such as spam. Social media may include content which is
also inconsistent with agency’s comment and posting policies, and this may
also require removal from the site. Some removed content, such
as spam, may be non-record, while other types of content are records that
must have an approved disposition authority. Agencies should consult with their
general counsel about these policies for monitoring content, and
make sure that it’s consistent with their First Amendment
obligations and any federal laws. That brings us to the discussion of
the capture of social media content. We included a broader discussion of
social media capture in this bulletin versus the 2010 bulletin, as we
heard that this is one of the topics that agencies were interested
in hearing more about. I see that there was a question from
[inaudible], and he asked, “By record value, are you referring to the appraisal value?” So, in looking at the records, you
go through and ask the questions of, “Does this meet the definition of a record?” And then you would look at your existing
record schedule and see if those apply. If it doesn’t look like that applies to
that content, then you’d be at the point of drafting a new schedule item
and submitting that to NARA, and then talking about the
appraisal value of those records. So I suppose [laughter] they’re
two different things. So it’s first asking the question
of, is the content a record. And then, if it is, do you have an existing
disposition authority that applies, yes or no? So that’s kind of the decision
tree I was talking about. And if yes, use that schedule. And if not, then have to create a new schedule
that applies to that social media content. So we’re talking about the discussion
of capture of social media content. So once records are identified and
associated with an approved records schedule, agencies must decide how to
manage social media records. One change in this bulletin is the statement
that temporary records that are transitory or of a short-term retention
may not need to be captured and can be maintained in
the social media platform. So this could mean that, if the records
transitory, they have a short-term retention, this could mean that the records could
continue to live on Facebook or Twitter or wherever they live without any
further intervention from the agency. That said, agencies do need to assess their
business needs and evaluate any risks associated with leaving those records in social media. A question that frequently may come
up is, how can I delete records from a social media platform when my
record schedule says it’s time to do so? And this may not always be possible. In a way, it probably defeats
the purpose of social media. So this is a question that agencies should ask
and consider before either using the platform or when looking at their record schedules. So capture is particularly
important for temporary records with either long-term retention or
both those records that are permanent. And these records should be exported or
captured from the social media platform into an agency recordkeeping system. The options for capture will depend on the
technical configuration of the platform. This will depend on which tool is being used. As we said, it’s important to
capture the complete record. And what’s been determined as a complete
record may also affect the choice of capture tool or how that capture is done. We’ve included this bulleted list
in the bulletin as various methods for capturing social media records. So these are the general methods of doing so, and we don’t include specific
tools in the bulletin. So the first option is using a Web crawling
software to create local versions of the site. An example of this HTTrack, which is
an open source freely available tool that can be used for Web crawling. And it’s typically used for
the archiving of Web sites. Another option is using Web capture tools to
capture content and migrate to other formats. So this includes services such as
Hanzo, Iterasi, Smarsh or ArchiveSocial. And these are fee-for-service. You can read their literature and see that they’ll capture the full
package of social media content. Another option is using platform-specific
application programming interfaces or APIs to pull content from sites. The platforms may change
their support for their APIs. For example, Twitter had recently, earlier
this year, turned off their support for RSS, and this was a way that some people may
have been capturing their Twitter content. So this is something to remember, that
the platform could change their support, the support that they provide
to developers or for export. Since then, people have found
ways of getting around that. Another option is using RSS feeds, aggregators
or manual methods to capture content. And then the final one on the list here
is using tools that are actually built into the social media tool to export content. Tools such as Twitter, Facebook
have export options available. And so agencies should look at
this export that they provide and see if it captures the
complete record for their purposes. Agency needs may also affect
the selection of a capture tool. We recommend that agencies provide training
to those who are responsible for managing that content that they know how
and when to use the capture tools. That is, if it isn’t automated
at an agency level. Some of these tools could capture
content at an agency level. You put in all the feeds into the
tool, and then it could capture them. But if that’s not the case, if
it’s a distributed responsibility, then the staff that are responsible
should have training on how to do that. Agencies may also need to work with
third parties, either the provider of the social media platform or a
capture provider, to implement capture. As we also discussed in the previous bulletin, agencies are responsible
for managing their records. And at a minimum, these responsibilities
include the ability to identify and retriever federal records that are
created and maintained on social media. We’d like to point out that agencies
should be aware, when using tools, whether they are free tools or paid services, that the provider could discontinue
their service or delete information from an agency’s account. Just something to aware of and to consider. On the flip side, agencies could also
stop using a social media platform. But in either of these situations, the
agency is still responsible for capture and records management responsibilities. One thing we point to in the bulletin is trying
to make use of the capabilities of the provider. So agencies should determine if
the provider can export a copy of the complete records,
as the agency defines it. One suggestion I’ve heard from agencies in the
past is to just go ahead and ask the provider if they are able to give an export
or a copy of the complete record. And if they can do that,
then that’s very helpful. If they cannot, then the agency is responsible for implementing capture
requirements via another method. So if they can provide the export,
then instructions for notification or when this should happen and any export
requirements should be given to that provider. Another situation that could happen is
that the provider could go out of business, the social media tool, or it could
be bought by another company. And instructions for notification should also be
included for this type of situation in the terms of service agreement, which
we’ll talk about now. So as we included in the last bulletin
and also the cloud computing bulletin, we’ve included this general
clause for use in terms of service agreements for
social media providers. This clause is also included in the federal
friendly or the federally compatible model terms of service agreement that is maintained by GSA. GSA has negotiated terms of service agreements
with a number of social media providers and it includes these on a registry
on their howto.gov Web site. But it’s still up to the agency
to negotiate their own agreements or choose to use the GSA agreement. And on that Web site, GSA provides
guidance on negotiating terms of service agreements with providers. Keep in mind that even though
a tool may be on that list, your agency may not have approved the
terms of service agreement for that tool. Each agency considers its own
policies, needs, expectations, practices and conducts a legal
review before signing any agreements. So if you’re not sure, I would check
with your general counsel to be sure that there’s an approved agreement
or if someone in your agency asks. So some things to note. Agencies must determine any capture-related
issues, and then include those in agreements with providers when possible
or when is necessary. This clause in front of you does not
include any stipulations about capture, and agencies that have contracts
for cloud computing guidance or services should follow
this recommended guidance. And as I said, agencies will have additional
business legal security requirements that they should consider
in the procurement process or should be included in
agreements when possible. We also included a question in this
bulletin to explain how it relates to the larger managing government
records directive. So as I’m sure most of you are aware,
the directive was issued last August by the National Archives and OMB, and is the
beginning of an Executive Branch wide effort to reform records management policies and
practices, to develop a 21st century framework for the management of government records. So while this bulletin that we’re talking
about today isn’t mandated by the directive, there are several actions required by
the directive that will assist agencies when addressing records management
challenges that are raised by social media. These related projects include the updated
transfer guidance that will be coming out before the end of the year and a
project for Goal A3.1 and the directive to investigate automated technologies. To manage diverse collections of digital
records, and that also includes social media as part of that research
into automated technologies. You can find out much information on this
project on the NARA records management Web site. It’s linked from the records management section. We also mentioned that there will be
updated general records schedules, and this was part of a five-year
effort to revise and update those. Some other resources that we include in the
bulletin that I want to draw your attention to is A White Paper on Best
Practices for Social Media Capture. This provides some best practices
and a non-exhaustive list of available tools for social media capture. As we’ve mentioned before, the Records
Express Blog is the place to go for any new guidance or upcoming events. You can also see updates on what
the Chief Records Officer is working on with our agency partners on
different records management activities. Some other resources. There was a report from 2010 on
Federal Web 2.0 Use and Record Value. It’s more an assessment of the
record value of social media records. You can take a look at that. Also, the toolkit. This is where we collect records
management guidance and best practices, and that’s available on NARA’s Web site. And also an FAQ about records management. So I wanted to take just a few moments to also
mentioned that White Paper on the best practices for capturing social media records. And in this White Paper, we looked at
the current state of social media capture in the federal government
at the time of publication. And so that was published in May of this year. We also reviewed agency social media policies
that are available on their Web sites to see how they address the
social media capture. We found a few examples that
we included in the bulletin. And as I said, this was published in May, so
there very well may be updates to some of these. In the White Paper, we also included a list of
tools and services that are available for use for social media capture, and this is a list
of the tools at the time of publication. We found that many of these tools come
and go and their capabilities may change. This is the case often for a number
of the tools available for Twitter. But I would encourage you to take a look
at the section of the paper and to see if you are using any of these
tools, or if there could be some that would be helpful at your agency. So you contact me at my email
address with any questions. And I see I still have Jill Snyder on there. I’m sure she’d be happy to
take any questions as well. [Inaudible] as records officers, how can we
even be aware of the social media content? So if OIT are reviewing and tracking social
media, do we make sure that OIT involves us, the records officer, in the
process of the review? Yes, I’m guessing that’s maybe
Office of Information Technology. So they might be the team or the people that are
responsible for creating content and posting it on sites and also providing comments
and feedback to people that respond. So I think that can often be an issue, is that the records officers may not
be aware of the social media content. I believe as part of the open government,
all agencies have a page on their Web site where they have a listing of all of the
social media tools in use at their agencies. So that could be a good place just to start
to see all of the pages that are in use. I know we have that. At the National Archives, we have a
list of all of the Facebook and YouTube and Twitter channels by location
around the country. So the first step would be, yes, being
aware of the social media content and then making sure that they do involve you. Possibly forming that working group that I
mentioned, and inviting them to the table and talking about the, you know, doing inventory
of what content is out there and making sure that there are record schedules that apply. So that would be a yes to make sure that they involve the records officer
or the records management staff. You may not have to be involved in all
of the review of the content itself, not the day-to-day business of
posting and sharing information. But definitely being involved in the
assessment of if that content includes records. Okay, so Jolene [assumed spelling]
said, “Similar to when we put a notice in the local papers, the record would
be the hard copy notice that we submit. Would it be logical then to convey to our public
affairs group that they do have a hard copy of the message in their files prior
to inputting it into social media?” Well, this is a good part of
that awareness or being aware of how these processes work within your agency. So I’m not exactly how this process works,
but it may be a process that used to be in a paper-based form and
is now done electronically. So that would have to be the decision of
looking at is the paper-based form the record, or is it the electronic process
that’s the record? And I will point out that in the
Managing Government Records Directive, this encourages agencies to move
toward electronic recordkeeping, so that’s just something to consider. But yeah, I think that would be good, to sit
down with the public affairs group and talk about which is the official record and where
things are being kept and who’s responsible for keeping them and who’s
responsible for doing the capture. Next, we had a question from
Stacy [assumed spelling]. She said, “Just like with search and other needs
that all agencies need, GSA provides a tool for all agencies, helpful for smaller
agencies with small social media staff. Can NARA work with GSA to identify a tool
to capture records and provide tool support? Also, is NARA working with GSA on a TOS
for tool capture that there are separate from the SM tools available to us?” Okay, I’m not sure which tool you refer to,
but they provide a tool for all agencies. So they provide generally , in their Web
services part of their page, they include topics such as social media and that’s where they provide the social
media registry and other tools. Can NARA work with GSA in identifying a tool? So, we are not currently working with
GSA to identify tools for capture. That’s still something that is in
the responsibility of the agency. We did talk to GSA at one point, when
we were developing the White Paper. I had conversations with them about different
tools that they had used as an agency. And it was still a work in progress, trying to figure out which tools provide the
best capture of their social media records. And so, kind of the White Paper
is an assessment of where we were in this year, talking about these things. And these discussions will continue to evolve,
and we’ll continue to look at capture tools and what’s out there and what’s available. And we’ll try to find a place to put these
so that everyone can be aware of them. And then, it’s still at the individual
agency level to work out terms of service agreements for capture tools. GSA works on terms of service for the free
social media tools, and this is separate from a procurement process that each
agency would have to do at their level. So we’re not working on a terms of service
agreement for any social media capture tools. Shelly [assumed spelling]. “So are you saying that NARA will revise the
GRS to include social media dispositions?” The revisions of the GRS are
underway, and that’s something that that team reviewed and
that they’re considering. It’s a challenging thing to do,
as each platform is different and agencies use may differ
from agency-to-agency. But that is something that they’re
considering trying to work on. But at this point, there is not a GRS, so
agencies are responsible for identifying and scheduling their social media content. Let’s see. Gill [assumed spelling] said, “Has NARA
looked into GovDelivery to perform all of the social media tasks,
including Web capture?” I don’t think we have. So this is separate. There’s the NARA actually capturing
their social media [inaudible], and then we do the policy
side for federal agencies. So I don’t know if NARA’S internal records
management or social media team has looked at GovDelivery [inaudible]
we’ll explore that, definitely. “Does NARA use a specific tool for
capturing social media content?” NARA’s social media team and records
management staff are, I believe, still investigating a number of tools, and I
know that they’ve experimented with using– why am I blanking on the names now? They have used ArchiveSocial and tried a number
of other tools to capture social media content. So that’s separate from my office,
the work that they’re doing. But they are trying different
things to see what works. Okay. Looks like Gale [assumed
spelling] had a question. “My agency currently uses HootSuite to
manage our Twitter and Facebook posting. We sat through a presentation on GovDelivery. It’s supposed to be one-stop shopping. It’s something we need to
check further into ourselves.” That’s one that I know NARA has looked at too. Thank you for that information. It’s always good to know what agencies have
tried or what’s worked and what hasn’t worked. I’d also be interested in
hearing any feedback on that. Okay. “It may be good to have a NARA
site to share social media policies that have been developed by agencies like you.” Oh, okay. That’s a good idea. That’s a good idea. Thank you, Victor [assumed spelling].>>So this does complete today’s briefing. So thank you so much for joining us. Beth, did you have any final
words that you wanted to say?>>No, just thank you.>>Thank you for joining us. We hope you found this seminar useful. For more information about the U.S.
National Records Management Training Program, please visit www.archives.gov. Also, our current workshop
schedule for both face-to-face and Web-based training is
available online at NARA.learn.com.

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