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Last year, the Preservation of Electronic Government Information (PEGI) Project — a collaborative effort of which I’m a part — commented on phase I of the draft Federal Data Strategy. This time around, there was a request for comments on phase III, the draft action plan for the Federal Data Strategy and again PEGI submitted comments (grab the PDF here). They were very specific about what comments they were looking for this time around:
In March 2018, President Trump launched the President’s Management Agenda (PMA). It lays out a long-term vision for modernizing the Federal Government in key areas that will improve the ability of agencies to deliver mission outcomes, provide excellent service, and effectively steward taxpayer dollars on behalf of the American people. The PMA established a Cross-Agency Priority (CAP) goal of Leveraging Data as a Strategic Asset with an intended purpose of guiding development of a comprehensive long-term Federal Data Strategy (hereinafter “Strategy”) to grow the economy, increase the effectiveness of the Federal Government, facilitate oversight, and promote transparency (https://www.performance.gov/CAP/CAP_goal_2.html). This notice seeks comment on a draft action plan for Federal agencies to adopt in order to achieve the objectives of this CAP goal. This is the third Federal Register Notice seeking public comment related to the Federal Data Strategy. The previous two notices sought comments on the Strategy’s draft principles and draft practices, respectively.
Please provide comment on the scope and content of the 2019-2020 Federal Data Strategy Action Plan.
- Identify any additional fundamental actions to implement the Federal Data Strategy that are not included in this draft Year-1 Action Plan and explain why.
- Identify any additional actions that would align with or complement ongoing Federal data initiatives or the implementation of new legislation, such as the Foundations for Evidence-based Policy Making Act and explain why.
- Identify any actions in this draft Year-1 Action Plan that should be omitted and explain why.
- For each action, provide any edits and additional detail to ensure that they accurately and effectively describe needed activities, responsible entities, metrics for assessing progress, and timelines for completion.
- For each action, provide information about the implementation resources necessary to ensure success of these Action Steps.
PEGI focused (of course!) on the importance of data preservation and robust metadata, proposing “approaches that will maximize resource use by assuring that the implementation of the Federal Data Strategy will include preservation as a key component.” Read our comments in their entirety and also check out all of the submitted comments on regulations.gov.
There is a lot of activity going on to ensure that government information on government servers does not get altered, deleted, or lost during the transition between administrations. As we have pointed out before, this is not a new issue even if the immediacy of the problem is more apparent than ever before.
Much of the effort going into these activities has to deal with the inherent problems of how federal government agencies create and disseminate information. There is, for example, no comprehensive inventory or national bibliography of government information. Agencies do not even provide inventories of their own information. This makes it hard to identify and select information for preservation. Also, some information is in databases or linked to Web applications that are not directly acquirable by the public. Finally, the "digital objects" that we can identify and acquire are often not easily preservable.
The inherent problem is that agencies are not addressing digital preservation up front. Librarians and Web archivists are left trying to solve the digital preservation problem too late in the life-cycle of information. We are trying to preserve information long after its creation and "distribution" — in the absence of early preservation planning by the agencies that created the information. This is understandable under current government information policies because most government agencies do not have a mission that includes either the long-term preservation of their information or free public access to it. The Federal Records Act [Public Law 81-754, 64 Stat. 578, TITLE V-Federal Records (64 Stat. 583)] and related laws and regulations only cover a portion of the huge amount of information gathered and created by the government. In addition, the preservation plans that do exist are subject to interpretation by political appointees who may not always have preservation as their highest priority.
What we need is a better approach to government information management that includes preservation planning at the beginning of the information life-cycle and that guarantees its long-term preservation and free public access to it even if the agency has no more need for it, or if Congress has no more funding for it, or if politicians no longer want it.
How can that be done?
At FGI, we believe that a long term solution will require a change of government policy. That is why we have proposed a modification to OMB Circular A-130: Managing Information as a Strategic Resource that would require every government agency to have an Information Management Plan.
This seems to us to be a reasonable suggestion with a good precedent. The government agencies that provide research grants already require researchers to have a Data Management Plan for the long-term preservation of data collected with government research grant funding. A modification of A-130 would simply put the same requirement onto information produced at government expense by government agencies that the National Science Foundation (NSF) and other government funding agencies put onto the data produced by researchers with government funding.
Here is an draft of such a requirement:
Every government agency must have an “Information Management Plan" for the information it creates, collects, processes, or disseminates. The Information Management Plan must specify how the agency’s public information will be preserved for the long-term including its final deposit in a reputable, trusted, government (e.g., NARA, GPO, etc.) and/or non-government digital repository to guarantee free public access to it.
We believe that such a requirement would provide many benefits for agencies, libraries, archives, and the General Public. It would make it possible to preserve information continuously without the need for hasty last-minute rescue efforts. It would make it easier to identify and select information and preserve it outside of government control. It would result in digital objects that are easier to preserve accurately and securely. It would accomplish many of these goals through the practical response of vendors that provide software to government agencies. Those vendors would have an enormous market for flexible software solutions for the creation of digital government information that fits the different needs of different agencies for database management, document creation, content management systems, email, and so forth, while, at the same time, making it easy for agencies to output preservable digital objects and an accurate inventory of them ready for deposit in Trusted Digital Repositories (Audit And Certification Of Trustworthy Digital Repositories [ISO Standard 16363]) for long-term preservation and access.
Perhaps most important for FDLP Libraries, we believe that this OMB requirement would provide a clear and practical opportunity for libraries to guarantee long-term free access to curated collections of government information to their Designated Communities. And this, we believe, will drive new funding and staffing to libraries and digital repositories.
Jame A. Jacobs and James R. Jacobs.