 Welcome and thank you for joining today's webinar on the FAQ on Non-Compliant Permanent Digitized Records. Please note this conference is being recorded and audio connections are muted at this time. If you require technical assistance, please open chat with the associated icon at the bottom of your screen and send a message to the event producer. You may submit written questions throughout the conference by selecting all panelists from the drop-down menu in the chat panel. Closed captioning may be turned on by clicking the CC icon at the bottom left of your screen. With that, I'll turn the conference over to Arian Ravan-Baksh, supervisor of the policy and program support team. Thank you, Candice, for that introduction. Good afternoon, everyone, and welcome to our webinar. My name is Arian Ravan-Baksh, and I will be serving as the moderator for today's webinar. First, some housekeeping information. The presentation slides we are using today will be made available on the Digitization Resources page of our website. When we have the recording available, we will be posting a link to it on this webpage as well as on our YouTube channel. A summary of today's webinar and all relevant links will also be shared on our blog Records Express in the coming days. Records Express is where you can also find a series of several posts with additional information about all things digitization. For questions during this presentation today, please use the WebEx chat feature. We will be addressing those questions after the presentation. We will be recording the presentation and speaker remarks, however, we will stop the recording for the question and discussion portion of today's webinar. With all of that out of the way, I'd like to introduce the Director of Records Management Policy and Outreach, Lisa Herlampus. Good afternoon, Lisa. Thank you, Arian, and welcome everybody to today's webinar. We're very excited to have you join us on a conversation that is a very important topic to us, which is related to previously digitized permanent records that may not be in compliance with the standards we recently issued. So the first thing I'll do is I'll take us through our agenda for today. So we'll do a brief introduction slide. I'm going to give a little context as to why this is necessary. And then the bulk of the presentation will be a review of all of the FAQs, all the questions you've asked, and the answers we've arrived at. We're also going to profile another resource related to this topic, which is a decision tree to help you think through the complexity of understanding what do I do if I've digitized records, permanent records, and they don't comply with the standards that were recently issued. So next slide, please. So that's what we're going to talk about. And this who's going to talk. I am so pleased that we have the entire policy and standards team here today. You're going to get to hear from wonderful experts who are quite, have in-depth knowledge on these standards, these questions, and be able to lead us in a really rich conversation. And you can see their names and titles, and you'll get to hear from them very soon. Next slide, please. So this is a webinar is to talk about the answers you've had to questions on what to do with records that have already been digitized, if they do not meet the standards that NARA issued. As a reminder, these are the standards that NARA issued. We pushed these standards out in regulations that happened back in May. And as you can see, I do like this slide, I know it's got a lot of information in it, but it does provide a snapshot of the complexity and the detail that are contained in those digitization standards. Everything from what documentation you have produced relating to a digitization project, to the file formats, the quality management, what to do for metadata. So we've issued a lot of information, and we know that some digitization products will be very close to meeting all of our standards, but they may not have met every piece, and that's what we want to talk about. What do we do about that today? Next slide, please. As the story, I'm just going to repeat a story you've heard me say many times. Why did we issue these digitization standards? Why did we issue them in regulation? Why is NARA going in the direction that we went when it came to how we want to receive, preserve, and archive federal records? Well, came from a lot of different places, but the background you'll find starting in 2014 with the Federal Records Act. It was amended after 15 years, and as part of that amendment, it told the archivists to produce regulations so that we could transfer all electronic records to NARA in a digital form to the greatest extent possible, and we've been since 2014 working on that path, and here we are 10 years later, and we've had memos from OMB and NARA, and we've done tactical work on strategic plans and products that we could issue to help the government get to this vision, and that's where it came from. So we have been moving in this direction for quite some time. Next slide, please. So now, as we've been working to that direction, it was important just to say we heard a lot of questions, and I think that's what we're about to get into. People had questions, you've issued standards, and those standards apply to digitized records that are going to be transferred to NARA. Since they apply to records that are going to be transferred to NARA, what are we going to do if our records don't meet those questions? So we've been answering and having conversations one-on-one. The whole team has been responding to questions we've received, and I'm happy to say we were able to pull those questions together. We heard what you were asking, and we wrote this FAQ. The FAQ was published in November. I hope you had a chance to read it over the holidays and the December time period, if you have or if you hadn't. The link is here on the slide, and I think we're going to drop a link to the FAQ in the webinar. So you can go look at it and thank you, Arian. So you can look at it while we're talking. You can see what we put in writing, and if you have any questions about it, you can talk to us today about it. We're going to cover options for non-compliant digitized records. We're going to talk about accessioning practices, what NARA has done in the past. We're also going to talk about media neutrality. Media neutrality is the concept that we write our schedules not to be specific about what media comes to NARA when we take records in, and yet with our digitization standards, we are being media specific. We are giving a lot of guidance on what we expect for digitized records. So we want to talk about that topic as well. So that's what's coming up, and next slide please. I think now I get to hand it off to your first speaker, Mike Horsley. Over to you, Mike. Thank you, Lisa. I'm Michael Horsley, and I am a senior electronic records policy analyst and responsible for writing the technical standards for the digitization regulations. So non-compliant digitized records are those that do not meet the standards in the regulations. Agencies may have ongoing digitization projects that continue to generate non-compliant digitized records. NARA recognizes that it will take agencies time to implement the digitization standards for permanent records. The FAQ provides answers to questions that apply to any digitization work that does not comply with the digitization standards. You have may also heard of the term previously digitized, so we're using these terms not interchangeably, but we're focusing on it. Next slide please. So when digitizing records, agencies end up with two versions. The source records in paper or analog form and the digital records. Both versions are federal records as defined in the regulations. Source records are the records from which a digitized version or digitized record is created. The source records should be the record copy that was in use in the course of agency business. Digitized records are the records created by converting paper or other media formats to digital forms that are of sufficient authenticity, reliability, usability, and have the integrity to replace the source records. Because both versions are federal records, each version must be covered by a disposition authority, either an agency record schedule or a general record schedule known as a GRS. Next slide. So if agencies validate that they have digitized permanent records according to NARA's digitization standards, then agencies can transfer the digitized records to NARA under the existing permanent record schedule and destroy the source records under GRS 4.5 item 10 provided the records do not fall under any of the exclusions. GRS 4.5 digitizing records covers the disposition of source records that have been digitized and documentation related to digitization projects and processes. I now turn the presentation over to John. Thanks, Mike. Hello, I'm John Martinez. As Lisa said, I'm supervisor of the policy and standards team. And as you saw on the slide, we've got the whole team here today. You just heard Mike, who's one of the senior electronic records policy analysts on the team. The other senior policy analysts who are going to speak as well are going to be Kevin Divorsi and Mason and Andy Potter all coming up. So for my section, I'm going to talk about questions relating to digitized records that do not meet the standards and the regulations. And specifically, the three or four paths we discuss, common paths options that are discussed in the FAQ. Next slide, please. So under that sort of umbrella of what if digitized records do not meet the standards, the first option, first path addressed here is to submit a new record schedule. In this case, it would be to submit a new record schedule to supersede the disposition instructions and the existing record schedule. So in this case, an agency would submit a new schedule with a specific instruction allowing the agency to transfer the previously digitized records to NARA and to destroy the source records. Although the records that were digitized earlier may not, likely will not meet the current standards, NARA may upon review determine that the digitized records could effectively serve as archival records. And the process, the purpose of the process of submitting a new schedule is to determine if NARA can accept the previously digitized records as permanent and to determine if we can schedule the source records as temporary. Going through the process allows agencies, NARA, and the public to have confidence in the processes used to digitize the permanent records and to clearly understand what records NARA will be accepting at the time of transfer. And it gives the public an opportunity, obviously to review the proposed record schedule by the federal register process. Related to this, in previous discussions we've had this and other venues, I think at the last bridge meeting in particular, we were asked if NARA is going to expedite the scheduling process in this kind of scenario for these types of schedules. And the answer is no. Is there going to be a fast track? No, there's not going to be a special track for these. But we also wanted to emphasize that the goal on these, when we talk about submitting a new record schedule, the goal is to update the disposition instructions, not a complete reevaluation of whether or not the records are permanent. Next slide, please. So the next option here discusses re-digitizing and validating the source records according to the standards of the regulation. And in part, this option acknowledges that past digitization efforts were made with different goals and assumptions about the status of the records. But digitizing records for easier access or to manage business processes is different from digitizing records to preserve them as part of the nation's history in the National Archives. Agencies may decide, may decide to re-digitize records for several reasons, such as meeting litigation or access requirements or obtain higher quality images that meet agency business purposes. And it may be necessary because it's the same quality management and intellectual control processes and requirements for archival preservation could be needed for, could also meet these purposes. By choosing this option, agencies can then destroy the source records according to GRS 4.5 and then transfer the newly digitized records to NARA as permanent. And the previously digitized records would likely then be considered temporary records based on an apical GRS or other agency records schedule. Next slide, please. So this third option would be to transfer the born digital records. So this acknowledges that most records printed in the last 30 years or so were created on computers. It's rare today to have paper records that are handwritten or done with a typewriter. Usually the digital records were then printed out as part of an agency's business processes and such as getting a handwritten signature. If the agency is able to access the born digital records that were printed out to create the paper records, if they can be used for the same purposes, if the born digital records can be used for the same purposes as those printout paper records, then the agency should consider transferring those born digital records to the National Archives holdings. If going on that path, you should consider that, must ensure that digital records then are equivalent to the paper records that they're going to carry the same context, content and structure needed to understand the records. And in addition, the transfer of born digital permanent records then a born digital permanent electronic records would have to meet in our existing guidance on transferring permanent records including file formats, metadata requirements and file lists. And in this option, where the born digital records can be used for the same purposes as a paper, they would be permanent. Both the printed records and previously digitized records would likely then be considered temporary records and could be disposed of according to an apical GRS or other agency records schedule. Next slide please. So the next one addresses what about sending the source records to NARA instead of the digitized records? So agencies can send the source records, the original analog records to NARA before the M2307 deadline of June 30th, 2024. This would allow agencies to transfer the source records as permanent records. The digitized records, if there are any, could be destroyed as temporary records then under an apical GRS or agency records schedule. And sending source records to NARA would include in the case of sending the source records to NARA to a federal record center before the deadline of June 30th. In that option, agencies would only pay for the cost of storage and services. Once the permanent records have been transferred to NARA to the National Archives through the annual move process, NARA would then assume responsibility for providing access to the records, including any future digitization of them. And then in the case of transferring source records as a direct offer to the National Archives holdings before the June 30th deadline, if your agency cannot send records to NARA before that deadline, there is another aspect of this where you could submit an exception. If approved, an agency may continue sending source records to federal record centers or continue transferring source records as direct offers with an approved exception. Information about the exception process is outlined in NARA Bolton 2020-01. I think I've got the link on the slide there. However, the goal remains for the federal government to transition to digital records. Exceptions are typically limited and should be part of an overall business case or agency strategy to transition to digital records. And the 2020-01 addresses that. It talks about what agencies should consider, sort of what to include in exception requests. It gives an outline of what's expected to be submitted. If your agency cannot send records, source records to NARA before the deadline, and if an exception is not approved, then the first three options I've talked about so far, those would still remain as options for the agency to manage your non-compliant scanned records. Next slide, please. And the first one I talked about, how NARA would go through a process of determining whether to accept previously digitized records in a new schedule. And the process for that, in that case, when an agency records officer submits a new record schedule to supersede an existing distribution authority with new distribution instructions, NARA then will review this new schedule. And in terms of process, we may, we will request specific data from the agency regarding processes, validation methods, technical specifications, and metadata standards that were used for your agency's digitization process. As part of that, NARA may follow up for clarification with further questions, if needed. Then NARA will do a larger assessment of the agency's digitization processes to inform the appraisal, the review, and decision on the schedule. If NARA determines the digitized records are acceptable for permanent preservation, NARA will recommend approval of the schedule. If NARA determines the digitized records are not acceptable, NARA will return the schedule without action. If NARA can't accept the previously digitized records, again, the other options, the three or four options discussed here would still remain available to the agency. And as part of that, the agency would need to take additional action to appropriately manage and transfer the permanent records. So those are sort of the main, like I said, the main three or four options that are discussed in the FAQ. Lisa mentioned the beginning, and I mentioned in passing here, we wanted to talk a little bit about some media neutrality topics. I'm going to pass it now to Andy Potter, who's going to take the next section. John, pretty much see the next slide, please. Yeah, I just wanted to actually quickly look at a policy known as media neutral. NARA in 2007 published a regulations which established the media neutral approach, which was essentially where agencies could provide a notification that they were digitizing records, and then there would be a note, essentially disposition instruction on the schedule would be pen and ink changed, and those records could come in as digital records. The amendments that happened in 2012 to the Federal Records Act essentially created a situation where we began the shift from essentially that was could accommodate media neutral more towards a media specific environment. In other words, the establishment of the standards for the reproduction of records, source records into digital records. So now, as was mentioned earlier in the presentation, agencies can transfer their digitized records either under a media neutral schedule or the schedule that controlled the source records. And once it's digitized to these standards, then those records, the source records are then under the general record schedule 4.5 as long as it meets the requirements in that schedule. So basically that shift is where media neutral schedules can be used as long as they're in compliance with established standards in any schedule. Next slide, please. Part of the following on the heels of the regulation came policy and procedure process. And that was spelled out in NARA Holotin 2010-04, which established and refined a notification requirement and also included a NARA form 13171, which certified that transition. And the process had NARA reviewing the notification form and agencies could then transfer permanent electronic records instead of the paper records. Again, as part of the shift in the landscape, Holotin 2010-04 has been revoked formally. We no longer have a form 13171. And if you have any questions regarding any previously submitted NA13171 forms, agencies should contact their appraisal archivist. And with that, I will hand it over to my colleague, Anne Mason. Thanks, Andy. If we can go to the next slide, please. So now what if agencies have already destroyed the source records and only had the digitized versions that aren't compliant with the regulations? So if you have destroyed source records without the authority to do so, via an agency's record schedule or the GRS, it may be an unauthorized destruction and it should be reported as such. You can find more information about reporting requirements on our unauthorized disposition webpage, as well as an email there to contact the team that deals with those. And next slide, please. So now we're going to talk about, is there anything that agencies can do to make previously digitized records comply with the standards? The regulations have numerous requirements covering everything from records management to metadata to quality management. And if a digitization process didn't meet these requirements when the initial digitization was done, trying to retroactively take actions to fix it are generally not feasible. So as an example, if assessing the performance of scanning equipment was not done as part of the original digitization process, there really is no way to do that assessment post digitization. And there possibly is one exception. And if we go to the next slide, we're going to talk about metadata. So should agencies update metadata on previously digitized records to comply with the standards? Depending on the metadata, it may be possible to update or add metadata, although caution should be used that you're not overriding existing metadata or unintentionally deleting or altering what you don't want to alter. If agencies want to explore whether updating the metadata would work, we suggest they contact NARA to determine if doing so will be enough to meet the regulation requirement. We'd hate to see resources committed to updating the metadata only for agencies to discover later that there was something else about the digitization process that would make those records unsuitable for being the archival record. And if updating the metadata is not possible or will not be enough to bring the images into compliance, then there's the four options John talked about earlier with submitting a new record schedule, re-digitize, transfer born digital records or submit before the deadline to submit these source records before the deadline. And next slide please. And so should agencies convert bitonal images to grayscale or otherwise alter the images to comply with the regulation? So as stated in the regulations, agencies may not alter the technical parameters such as color mode or resolution. Upsampling or interpolating an image to change it from say black or white to grayscale or from 200 PPI to 300 PPI doesn't work. I actually experimented with this several years ago, I was kind of interested to see what would happen. I was working with images that were documenting historic buildings and I had things like the brick pattern change. And in one instance, a small basement window on a house actually disappeared and was bricked over when I tried to upsample the image. So that image that was sent, you know, no longer accurate representation of the building. So imaging editing software may attempt to do this for you, but kind of the bottom line is you cannot add information that was never in the image in the first place. And with that, I will turn it over to the next speaker. Thank you, Ann. Can we go to the next slide, please? So I'm Kevin Divorsi and the question is what about previously digitized film records are other media not yet covered by the digitization standards? And so we've released 36 CFR, 1236 E, which covers all paper and printed photographic records, but we have not released yet standards for other special media types. We are currently working on a regulation that covers film and other types of records that are captured using transmissive digitization techniques. And that is going through an internal review at NARA and we plan on posting that for agency review on the Federal Register during 2024. If you have specific questions about digitization of these record types, you can contact us at rmstandards.nara.gov. And if you've already digitized film records or other special media records not covered, John has gone through the process for what you should do in that case. If you have not started yet, it's probably a good idea to wait for us to publish those standards. So can we go to the next slide, please? So what other guidance or resources related to digitized records are available? And as it was mentioned, we've pulled together a lot of resources relating to digitization and it's available on our website. And once you get these slides, these are live links that you can go to. Relating to this conversation about previously digitized records, we've called out three things of particular interest. One being a decision tree of the steps that you follow, but then also the two FAQs for the GRS 4.5 and 5.2. And now I'm going to turn it over to Andy who's going to talk about the decision tree that you see here. Thank you, Kevin. If we can look at the next slide. So just really briefly, I wanted to point to the decision tree that was developed as we put together this FAQ. And I should step back for a moment and thank Tommy Lee, Records Officer over at Air Force, who when he took a look at our first draft of the FAQ came back with a proposed decision tree based on his understanding of the FAQ and we took that and worked through it. I really want to thank Tommy for that, giving us the impetus to develop this product. You see the link there, the link is also included on the web page with the FAQ. I don't have the whole, it would be difficult to display the entire decision tree here, but basically it walks you through some decision points around previously digitized or non-compliant permanent records and then what steps, what options are available. And really it's all based on what we've been talking about here with the FAQ. So hopefully that will be useful to folks as they work through some of this stuff. Next slide, please. And with that I will ask questions. I see we have a lot of questions. I'll hand it back to Ari as we navigate through the question portion of our presentation. Thank you. Thank you Andy and thank you all the presenters. At this point we'll do a housekeeping change. We'll pause for a moment to stop the webinar, stop the recording of this webinar before we address the questions. Absolutely, so we have to Q&A, the recording will now be turned off.